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Azocolorants in Textiles and Toys
Enclosure 2
Regulations
The German Regulations
At present the German legislation consists of the Regulations on Commodities and five amendments.
The Regulations do not only contain a prohibition of aromatic amines in textiles, but only that subject shall be mentioned in this project.
On account of the many amendments it can be difficult to see through the Regulations on Commodities. Therefore the deadlines for the manufacture and sale of consumer goods are listed in the two tables below.
Table 9.1
link to tabel
Manufacture of consumer good (ETAD, 1995).
Table 9.2
link to tabel
Sale of consumer goods.
The goods, which the Regulations apply to, are specified in Table 9.3. Futhermore, the analysis, to determine the aromatic amines has to be carried out using a certain analytical method mentioned in (German competent authorities, 1996). The German Regulations specify a limit value of 30 mg/kg textile for any of the aromatic amines listed in Table 9.3.
The Regulations established a ban on the use of azo dyestuffs, which can split off the aromatic amines listed in Table 9.3. Garments, which are produced after March 31st 1996, are fully covered by the Regulations, and a deadline of December 31st 1998 is established for the sale of garments manufactured before March 31st 1996.
Table 9.3
link to tabel
The list of the 5th amendment containing the banned aromatic amines (Bundesrat) (chemical constitution, se enclosure 3).
The deadline for second-hand goods, protective clothing and uniforms, not for private use, was revoked, with the argument, that gradually fewer articles containing the banned aromatic amines will be on the market because of the prohibition in the German Regulations against the use of azo dyestuffs, which can split off the banned amines.
The deadline for both manufacture and sale of recycled textiles is December 31st 1999. This also include furs, leather, accessories.
The deadline for azo pigments is March 31st 1998 for both manufacturing and import, and for the retail the deadline is September 30th 1998.
Table 9.3 contains essentially the same amines as the German MAK-IIIA1 and A2 list, annually published in Bundesarbeitblatt. The amines are classified as follows:
A1: Clearly proven to be carcinogenic
A2: Shown by experience to be carcinogenic
B: Justified suspicion of carcinogenic potential
The MAK-list contains two additional aromatic amines. One belongs to the MAK-IIIA2 group and the other has not been classified yet. These two amines are not included in the Germarm Regulations (AQUIRE DATABASE, 1993).
At present, an analytical method for determining aromatic amines in textile products (cotton, viscose, wool, silk, leather) has been established. For other materials a test method will be established.
The Dutch Regulations
The Regulations came into force August 1st 1996
The Dutch Regulations seems to be derived from the German Regulations, but the Dutch Regulations do not include azo pigments. The reason given is, that pigments are insoluble and only migrates under forced conditions. It is not defined, what is meant by such conditions.
The Regulations are valid for:
 | clothes |
| footwear |
| bedding |
As far as the manufacturing industry is concerned, the following categories of companies are involved:
| Producers of textiles and textile products, for use in the manufacture of clothing and bedding
| Producers of leather and leather articles, for use in the manufacture of footwear and clothing
| |
The trade in the above mentioned product groups includes importers, mail order companies, the wholesale trade, chain store businesses and the retail trade.
As already mentioned, the Regulations also contain a list of banned azo dyestuffs. lt should be noted, that according to (Staatscourant, 1996) this list is incomplete. The list also includes other aromatic amines than the 20 banned amines.
The following deadlines are established:
| any clothing, footwear and bedding which contain the azo dyes referred to in article 3, subsection 1 (the same as the 20 banned aromatic amines in the German Regulations) and which were put onto the market prior to the date of commencement, or with regard to which the seller can make a reasonable case through the production of documentary evidence, that they were ordered before said date, can be sold up to 1 September 1997. |
| Second-hand clothing, footwear and bedding, as well as any clothing, footwear and bedding that also serve as personal means of protection as referred to in article 1 subsection a of the Netherlands Consumer Goods Act Degree governing personal means of protection and clothing, footwear and bedding made from recycled fibres that contain the azo dyes referred to in article 3, subsection 1, can be sold up to and including 31 December 1999. |
The analytical method referred to in the Regulations to determine the banned aromatic amines is identical with the German analytical method.
The French Regulations
The French Regulations appear to be the same as time equivalent legislation in Germany and the Netherlands. The French test method has not yet been published, and it is not clear, whether colorants include pigments. The French Regulations have already been notified. There has been some comments and objections and before the end of September the French Regulations have to be modified.
Regulations in other countries
EU also considers guiding rules banning the use of azo dyes based on those aromatic amines categorised as carcinogenic in EU (AQUIRE DATABASE, 1993) for dyeing of clothes and shoes,
Futhermore, in Turkey and at the latest also in India it has been prohibited to manufacture, import and use dyes based on the forbidden aromatic amines in the German Regulations (AQUIRE DATABASE, 1993).
In Turkey there is a proposal for a contract, which shall be used between the dye manufacturer and the buyer.
The contract is used in connection with disputes about the 20 aromatic amines banned in the 2nd amendment to the German Regulations. The contract also contains a confirmation from the dyestuff manufacturer of compliance with the rules in the above-mentioned 2nd amendment (Turkish Clothing Manufactures’Association, 1996).
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