Restricted Substances List

2017
 Primark’s Commitment to
Zero Use and Discharge of Hazardous Chemicals

UPDATES SINCE PREVIOUS VERSION: Due to the significant change of including both the Product
Restricted Substances List (RSL) and Manufacturing Restricted Substances List (MRSL) in this
updated document, individual changes are not listed and all Suppliers are required to review this
document in full

As an international retailer, Primark is committed to reducing the environmental impact of our

products at every stage of their life. We recognise the importance of reducing the environmental
impact throughout the manufacturing process, and for that reason, we are committed to
continuously improving our chemical management programme, in line with evolving industry
standards, product specifications and technological developments.

To achieve this, Primark committed to working with other brands, retailers and industry stakeholders, to
phase out hazardous chemicals from our supply chain and to achieve the goal of ‘zero discharge’ by
2020. Further details on Primark’s Detox Commitment can be found here.

In line with this commitment, Primark’s Restricted Substances List (RSL) has been updated to align with
the ZDHC Manufacturing Restricted Substances List (MRSL).

This updated document, now details Primark’s chemical restriction limits for:

1. Chemical formulations used within the manufacturing process (MRSL limits)

2. Any finished product and/or raw material used within Primark products (PRSL limits)

Wherever possible, the substances and limits defined by ZDHC have been maintained. However,
additional substances were included to align with our existing product compliance limits and in such
cases, Primark MRSL limits have been defined. The MRSL limits constitute a full ban on the intentional
use of these substances. Primark applies acceptable limits in the process of elimination.

It is the Supplier’s responsibility to ensure that all Primark products meet the defined limits set out in
this document. Compliance is regularly assessed through due diligence testing.

All Primark Supplier’s and manufacturing sites must commit to these requirements and return the
signed DETOX Policy in Appendix 2, to the Primark Environmental Sustainability Team:
environmental@primark.co.uk

This document will be reviewed every 12 months to support elimination beyond the DETOX 11 priority
chemicals.

For any assistance, please notify Primark by way of email to: environmental@primark.co.uk

REMINDER: Primark has had an absolute ban on the use and discharge of Per and Polyfluorinated
chemicals (PFC’s), Alkylphenols/ Alkylphenol-ethoxylates (APEO’s) and Phthalates, since 2014.

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Fig. 1 Matrix - Product Material Type vs. Chemical Substance
The below matrix shows 19 priority chemical substances (beyond the DETOX 11 priority chemicals) that Primark has highlighted for elimination from its supply chain, and the
likelihood of finding these chemical substances within the material types used within Primark production: Red: extremely likely to be found, Amber: moderately likely to be found,
Green: unlikely to be found. Suppliers should use this matrix as a reference guide for their own material testing due diligence and should confirm with their mills and chemical
manufacturers that the substance groups in red are NOT to be used for Primark production.
*This matrix is intended to be used as a reference guide only

Soft
Plastics
Natural/ (inc.
Synthetic Hard Surface Paper & Wooden Oils & Glues & Foams
Chemical Substance Cellulosic
Textiles
Leather Plastisol
Plastics Coatings
Rubber Metallic
Board Items
Ceramics Glass Waxes Adhesives
Electronics
(inc.
Cosmetics
Textiles prints &
synthetic EVA)
leather)
Formaldehyde
Dimethylfumarate
Alkylphenol &
Nonylphenol
Alkylphenol & Alkylphenol
Ethoxylates
Azo Dyes forming
Restricted amines
Chlorobenzenes
Chlorotoluenes
Chlorophenols
Dyes with carcinogenic or
similar concerns
Dyes – Disperse &
Sensitising
Flame Retardants
Per & Poly Fluorinated
Chemicals
Metals
Phthalates
Polycyclic Aromatic
Hydrocarbons
Chlorinated Solvents
Organotin Compounds
Glycols
Volatile Organic Compounds
(VOCs)

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Restricted Substance Limits
The table on page 4 onwards, summarises the restricted substance limits for Primark production.

Limits are split by:

1. Manufacturing Restricted Substances List (MRSL) limits: for chemical products

2. Product Restricted Substances List (PRSL) limits: for Primark goods for resale
Primark Suppliers are required to apply these limits to all upstream supply chain manufacturing sites for Primark
production. To manage compliance, Suppliers are required to follow the process as tabled below.

Policy All Suppliers must sign and return the DETOX Policy in Appendix 2, to
environmental@primark.co.uk

Policy Suppliers must communicate the Primark RSL 2017 document to all upstream
manufacturing sites and they must also sign the DETOX Policy in Appendix 2.
Signed copies of the DETOX policy for all sites, including their own and the sites of their
suppliers, must be kept on file

Management Each Supplier and manufacturing site must have a designated person responsible for this
policy, an Environmental, Health and Safety Manager

Management All manufacturing sites must maintain an active chemical inventory using the Chemical
Inventory List (CIL) format and guidelines in Appendix 3

Management Suppliers must ensure that all factories implement the requirements of the guidance document.
In particular, that they:
 Maintain an up to date chemical inventory list
 Purchase only MRSL compliant chemicals (using the ZDHC Chemical Gateway or
Chemical Supplier ‘Positive Lists’)
 Perform regular chemical management training

Monitor/Review Suppliers and manufacturing sites must perform regular due diligence testing,
especially in case of major changes in raw materials, to assure RSL compliance

Monitor/Review Manufacturing sites must regularly test wastewater to confirm compliance, and report
results to Primark Environmental Sustainability Team, by way of email:
environmental@primark.co.uk It is expected that facilities will discharge wastewater
that is, as a minimum, legally compliant and meets or exceeds the foundational limits
for conventional parameters in Table 1 of the ZDHC Wastewater Guidelines

All manufacturing sites will be audited at least annually by Primark and all Primark Suppliers must maintain and make
available, records of all upstream manufacturing sites for Primark production.

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Appendix 1: Testing methods by chemical substance type

Chemical Substance Testing Method

Solvent Extraction:
Phthalates Gas Chromatography-Mass Spectrometry Liquid
Chromatography-Mass Spectrometry

Alkyphenol & Alkylphenol Solvent Extraction:

ethoxylates Gas Chromatography-Mass Spectrometry Liquid
Chromatography-Mass Spectrometry

High-performance Liquid Chromatography Liquid

Glycols Chromatography-Mass Spectrometry

Solvent Extraction:
Gas Chromatography-Mass Spectrometry Liquid
Flame Retardants Chromatography-Mass Spectrometry
Gas Chromatography – Negative Chemical Ionization

Solvent Extraction:
Per and Poly Fluorinated Liquid Chromatography- Mass Spectrometry/ Mass
Chemicals (PFCs) Spectrometry

Metals ISO 105 E04 (Textile)

Antimony Acid Digestion
Inductively Coupled Plasma

Inductively Coupled Plasma – Optical

Arsenic Emission Spectrometry
Atomic Absorption Spectroscopy

Inductively Coupled Plasma – Optical

Emission Spectrometry
Atomic Absorption Spectroscopy
Cadmium

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 Inductively Coupled Plasma – Optical
Cadmium Emission Spectrometry
(Pigments) Atomic Absorption Spectroscopy

ISO105 E04 (Textile)

ISO17075 (Leather)
Inductively Coupled Plasma – Optical
Chromium
Emission Spectrometry
(Total)
Atomic Absorption Spectroscopy

ISO105 E04 (Textile)

ISO17075 (Leather)
Chromium VI Inductively Coupled Plasma – Optical
Emission Spectrometry
Atomic Absorption Spectroscopy

Metals Contd.
Cobalt ISO 105 E04 (Textile)

Copper ISO 105 E04 (Textile)

Inductively Coupled Plasma – Optical

Lead Emission Spectrometry
Atomic Absorption Spectroscopy

Manganese ISO 105 E04 (Textile)

Inductively Coupled Plasma – Optical

Emission Spectrometry
Mercury Atomic Absorption Spectroscopy

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 Inductively Coupled Plasma – Optical
Metals Contd. Mercury Emission Spectrometry
(Pigments) Atomic Absorption Spectroscopy

ISO 105 E04 (Textile)

Nickel EN 1811 & EN 12472 (Metal)

Zinc ISO 105 E04 (Textile)

Volatile Organic
Compounds (VOCs) Gas Chromatography – Mass Spectrometry

Polycyclic Gas Chromatography – Mass Spectrometry

Aromatic Liquid Chromatography
Hydrocarbons

DIN 54232
Chlorotoluenes Gas Chromatography – Mass Spectrometry

EN ISO 17070
Chlorophenols Solvent Extraction:
Gas Chromatography – Mass Spectrometry

DIN 54232
Chlorobenzenes Gas Chromatography – Mass Spectrometry

ISO 14184-1 (Textile)

Formaldehyde ISO 17226-2 (Leather)

Solvent Extraction:
Dimethylfumerate (DMF) Gas Chromatography – Mass Spectrometry

DIN 54231
Liquid Chromatography
Carcinogenic Dyes

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 DIN 54231
Disperse & Sensitizing Dyes Liquid Chromatography

EN 14362-1 (Textile)
ISO 17234-1 (Leather)
EN 14362-3 (Textile)
Azo Dyes (Forming
ISO 17234-2 (Leather)
Restricted Amines)
Liquid Chromatography
Gas Chromatography

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Appendix 2: DETOX Policy

Supplier: [COMPANY NAME] Location:

[COUNTRY] Date: [XX/XX/XXXX]

[COMPANY NAME] are committed to the elimination of hazardous chemicals in all manufacturing processes
associated with Primark production.

We commit to the ZDHC MRSL requirements and implementation of the Primark MRSL Guidance Document.

This commitment extends to all upstream suppliers of products and services associated with Primark
production.

The representative for the ownership of this policy and chemical management in this organisation is as follows:

Chemical Manager: [FULL NAME]

Contact: [EMAIL]

We believe in the importance of eliminating these chemicals for the health of our employees, the
environment and the public.

Signed:

PRINT
NAME POSITION

Date:

Email a signed copy to the Primark Environmental Sustainability Team at: environmental@primark.co.uk

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Primark Chemical Inventory List (CIL) – Guidelines for Use

Primark have developed a CIL template to support Primark Suppliers and their mills/wet processing facilities, in effective
chemical management and the elimination of the use and discharge of hazardous chemicals.

Primark Suppliers are asked to appoint a relevant person to manage the distribution and review of Primark’s CIL template to
all sites using chemicals for Primark production.

Primark requests a complete and up-to-date CIL document from each mill/wet processing facility, to be submitted through
each Primark Supplier every six months, from the date of initial distribution.

A copy of Primark’s Chemical Inventory List (CIL) – Microsoft Excel template can be found here

*Please Note: All sections of the CIL template must be completed

Section 1 – Basic Data

Step 1 – Adding Chemical Supplier(s) to the CIL - Fill out Chemical Supplier information located within Chemical Supplier(s)
worksheet at the bottom of the CIL page

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Step 2 – Select chemical supplier name from the drop down list in main CIL worksheet

Once supplier details have been entered into

the Chemical Supplier(s) worksheet above,
‘Chemical Supplier Name’ can be selected
from the dropdown list

Step 3 – Insert Chemical Product Name & choose ‘Chemical Type’ from dropdown list;

Chemical Type:

 Auxiliary
 Coating & Lamination
 Dyestuff
 Others – including
o Laboratory; Analysis Chemicals, Trial Chemicals
o Household; Toilet detergent, Paint Oil, Painting Solvent
o Equipment; Boiler Fuel, Pump Oil, Water Purification
o Waste Water; Treatment Chemicals
 Raw Chemicals
o Acids
o Alkalis or Bases
o Salts
 DWR (Durable Water Repellant) Treatment

Product Name should be the same name as listed on Material

Safety Data Sheet (MSDS)

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Step 4 – Insert the Date of the MSDS on file for the chemical product and if information is listed in Section 2 of MSDS,
choose ‘Environmental Hazard Data’ from dropdown list. If no information is listed, please select N/A

Step 5 – Insert Average Consumption per month (kg or litres), volume of chemical product currently in stock (kg/litres), storage
location of chemical product, any specific hazards listed within section 2 of MSDS and the job title of person responsible for
maintaining the CIL

Average chemical consumption/ month Average chemical consumption per month (kg/litre)
Volume in stock Current stock of chemical (based on inventory book or ERP)
Storage Location Clearly identify where in the facility the chemical is stored
Specific Physical Hazards Select from drop down list (according to section 2 of MSDS) – If no
physical hazards indicated, please select N/A
Job title of person completing the Job title of person responsible for maintaining CIL
assessment

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Section 2 – Intermediate Data

Step 1 – Have you obtained confirmation form your chemical supplier, that the chemical substance is compliant with
Primark’s RSL and the ZDHC MRSL?

If you have a declaration from your chemical supplier

that the chemical is compliant with Primark’s RSL and
the ZDHC MRSL, please select ‘YES’ from the drop
down list, otherwise please select ‘NO’

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Step 2 – Select from dropdown lists in accordance with hazards listed in section 2 of chemical product MSDS, if no hazards
are listed, please select N/A

Control Measures: Free-entry to describe the control measures in

place, to minimize risk from hazards e.g. Personal Protective
Equipment (PPE: goggles, gloves)

Section 3 – Advanced Data

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Step 1 – Consumption in last 6 months, % of Hazardous Substances reported in MSDS, CAS or CI number and calculation of
Hazardous Substance volume in last 6 months

Enter consumption of chemical product in last

6 months (kilograms or Litres)

Enter % of hazardous substances within

chemical product, as shown on MSDS

Fill in Chemical product CAS or CI number, as

shown on MSDS

Volume of chemical substance used in the last

6 months will be calculated here (kilograms or
Litres)

Step 2 – Typical % of formulation remaining in treatment bath and Formulation volume in effluent

This data needs to be provided from a reliable source e.g. your chemical
manufacturer. Care must be taken to ensure their capability and reliability
in providing such data. Alternative sources of this information may also be
suitable, but it is highly recommended to discuss with your chemical
manufacturer in the first instance.

In general, chemical products used in treatment baths will fall into three
categories:

 Those with high affinity to the fibre, such as dyes – input 10 (%)
 Those with low affinity to the fibre, such as processing aids – input
90 (%)
 If no data is available – input 50 (%)

This value will be calculated automatically

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Step 3 – Aquatic Toxicity

‘Environmental Hazard Data’ will be automatically populated in this

column, from the information inputted within the ‘BASIC DATA’ section

Step 4 – Enter COD Value, as noted within chemical product MSDS

Enter COD Value, as noted within Section 12 of chemical product MSDS

COD is the amount of oxygen required to fully oxidize the chemical

product. It is scientifically much more reproducible than BOD (Biological
Oxygen Demand) and is therefore frequently one of the key parameters in
establishing effluent treatment charges.

The expected loading will be calculated automatically based on

multiplying the “relative volume of formulation in the effluent” and the
“COD value” entered

COD Loading value will be calculated automatically

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CIL – Reviewer Guidance Notes

1. Sort the “Date of the Material Safety Data Sheet (MSDS) on file” column, to identify MSDS’ which are missing, or more
than 5 years old.
• Any missing or outdated MSDS must be obtained from the chemical supplier.

2. Sort the “Environmental Hazard Data” column to identify any blanks.

• Missing data must be obtained from the chemical supplier along with an updated MSDS.

3. Sort the “Physical Hazard Data” column to identify any blanks.

• Missing data must be obtained from the chemical supplier along with an updated MSDS.

4. Sort the “Compliance with Primark’s RSL” column to identify any blanks.
• Missing data and an updated statement of compliance must be obtained from the chemical supplier.

5. Sort the “Compliance with ZDHC MRSL” column to identify any blanks.
• Missing data and an updated statement of compliance must be obtained from the chemical supplier.

6. Sort the “Eye & Inhalation & Skin Contact & General Health Hazard Data” columns (4 in total) to identify any blanks.
• Missing data must be obtained from the chemical supplier along with an updated MSDS.

7. Sort the “Typical % of formulation remaining in the treatment bath” column to identify any blanks.
• Missing data must be obtained from the chemical supplier.

8. Sort the “COD” column to identify any blanks.

• Missing data must be obtained from the chemical supplier.

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