Transformers Foundation Guidelines on Chemicals Management

This report calls for collaboration and alignment around a single set of rules: sound chemicals management systems should be a ticket to play, not a market differentiator.

The Transformers Foundation, a non-profit organization representing the denim supply chain, has released its investigative report titled Fashion’s Chemical Certification Complex: Unnecessarily Complicated, Terribly Inefficient which gives fashion professionals the actions they can take to reform the management of chemicals in the fashion industry.

“Fashion has a chemical certification problem,” says the Foundation. “Dozens of private sector auditors, consultants, labs and certifications provide a costly and inefficient form of supply chain oversight on behalf of brands.”

Many of these organizations offer nearly identical services. While brands and retailers use chemicals management as a differentiator, a marketing tool and a way to shirk their responsibilities, it’s the supply chain – from chemical companies to denim laundries –who pays for the testing, certification, and management of these overlapping security protocols.

Alberto De Conti, head of marketing and fashion at Rudolf Group, said: “I don’t see why we shouldn’t have a globally accepted RSL. Can you think of a reason why Diesel jeans should have different environmental requirements than Levi’s jeans, Pepe jeans or Calvin Klein jeans? There is a bad need for alignment.

This document calls for collaboration and alignment around a single set of rules, funding research, increasing testing and enforcement, increasing transparency and information sharing, reducing the number and the amount of hazardous chemicals in circulation and improve the global health of consumers, communities and ecological systems.

The report’s recommendations are as follows:

Brands and retailers

  • Assign the ZDHC MRSL and AFIRM RSL: Calling on brands to align with the industry’s most respected MRSL (Manufacturing Restricted Substance List) and RSL (Restricted substance list) lists. This simple step will reduce confusion and inefficiencies, so chemical management is standardized and (more importantly) done right, regardless of brand or supplier. Additionally, brands and retailers should align on the equivalence of certifications.
  • Develop internal technical expertise: An RSL is only good if a brand can figure out how to achieve it. Every major brand should have at least one in-house chemical engineer and/or toxicologist who can oversee chemical management and interface with suppliers to ensure their chemical safety, MRSL and RSL standards are met. These experts can also work with the design team to set parameters that ensure suppliers don’t feel pressured to use hazardous chemicals to meet brand demands.
  • Treat your suppliers ethically: Suppliers cannot join an MRSL unless the brands create the economic conditions for them to do so. A brand’s own KPIs should be aligned with the KPIs set for its manufacturers, with a view to shared profitability rather than race to the bottom on price. Brands should select their suppliers based in part on their chemical management systems, commit to long-term contracts and share the financial burden of product testing, equipment upgrades and safe chemicals more expensive.
  • Lobby the government to incorporate the standards into law: Strong chemical management systems should be a ticket to play, not a market differentiator. Brands and retailers should lobby the governments of the countries where their products are sold to make the ZDHC MRSL and AFIRM RSL law as the minimum legal standard applicable to all.
  • Provide ingredient lists to consumers: Every consumer fashion product must carry a label or code that lists all known carcinogenic, mutagenic, reproductively toxic, bioaccumulative, persistent, allergenic or sensitizing chemicals.


  • Fund and empower governing bodies to focus on chemical safety of consumer products: Call for additional funding for the Consumer Product Safety Commission and the EPA, to expand their mandate to research, test, approve or disapprove the use of new chemicals.
  • Align with other countries to unify chemical guidelines: Ideally, chemical standards would be harmonized and there would be only a few RSLs that differed only by product category, material or, in rare cases, religious beliefs. To achieve this, governments must work together to agree higher standards of chemical safety, with regulations aligned on both what can be used in fashion production and what can be on the final product. The toughest RSLs from a handful of brands show what is possible – their limits should be the standard that governments aspire to.
  • Pass due diligence laws that hold fashion companies accountable for worker exposure: We have a good understanding of the health risks for workers exposed to substances such as powdered indigo with aniline, potassium permanganate, hypochlorite and formaldehyde. We support due diligence legislation, which is currently under consideration in several European countries and at EU level. This would allow workers in production facilities to hold brands accountable for injuries, illnesses and deaths due to poor practices in a factory that the brand sources from.

Chemical companies

  • Collaborate on a collective position on chemical complexity: ZDHC’s success to date has been based on the industry’s willingness to collaborate within an organization with a clear governance structure. Chemical manufacturers and formulators should get together and decide which chemicals should be officially removed from the market. This working group could also work on language that is more accessible to advocates, journalists, and legislators not trained in chemistry.

Last month, the clothing industry presented joint recommendations in a letter supporting the commitment of EU policymakers to implement a regulatory approach to due diligence, to ensure companies live up to their responsibility to respect human rights and the environment throughout their value chains.

You can access the full report here.

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