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Annual Risk Assessment

RSL

PLNTmatter Restricted Substances List (RSL)
Applicable to MMCF Lyocell Fiber Manufacturing Facilities

 

 

📅 Version: Draft 1.0

Effective Date: January 1st 2025
Policy Owner: SVP Product and Strategic Growth
Review Frequency: Annual or as regulatory changes require

 

 

📖 Purpose

This Restricted Substances List (RSL) defines banned or restricted chemical substances in PLNTmatter’s fiber production processes. It aligns with EU regulations (including REACH), ZDHC MRSL v3.0, and industry best practices for Lyocell-based MMCF (man-made cellulosic fiber) manufacturing. All third-party manufacturing partners must comply fully with this list to ensure environmental integrity and product safety.

 

 

⚖️ Scope

Applies to all input chemicals, processing aids, finishing agents, and residual substances associated with Tier 4 operations of Lyocell fiber production.

 

 

🔢 Regulatory References

  • EU REACH Regulation (EC 1907/2006)

  • ZDHC MRSL v3.0 (Zero Discharge of Hazardous Chemicals)

  • OEKO-TEX® Standard 100 Annex 4

  • European Chemical Agency (ECHA) SVHC Candidate List

  • GOTS and OCS chemical input standards

 

 

⚠️ Restricted Substances Categories

1. Aromatic Amines (from Azo Dyes)

  • Benzidine, 4-Aminobiphenyl, o-Toluidine — Not permitted

2. Chlorinated Solvents and Carriers

  • Pentachlorophenol (PCP) and derivatives — Banned

  • Trichloroethylene, Tetrachloroethylene — Prohibited

3. Heavy Metals (Applies to processing inputs and effluents)

  • Lead (Pb), Cadmium (Cd), Mercury (Hg), Chromium VI — Must be non-detectable (< 0.1 ppm)

  • Antimony (Sb) — Limited to < 30 ppm in final fiber

4. Formaldehyde and Formaldehyde-Releasing Agents

  • Free formaldehyde must not exceed 16 ppm in finished fiber

5. Phthalates (Plasticizers)

  • DEHP, DBP, BBP, DIBP — Banned from any stage of processing

6. Nonylphenol (NP), Nonylphenol Ethoxylates (NPEs)

  • Must not be used or present in formulations or effluent (Limit: < 0.01% weight)

7. Fluorinated Compounds / PFAS

  • PFOA, PFOS, PFHxS — Strictly prohibited

8. Organotin Compounds

  • TBT, DBT, DOT — Banned entirely

9. Solvents & Process Aids

  • Methanol — Allowed only if fully recaptured (Lyocell)

  • N-Methyl-2-pyrrolidone (NMP) — Prohibited

  • Dimethylacetamide (DMAc) — Prohibited

 

 

📅 Testing and Compliance Requirements

  • All facilities must maintain chemical inventories verified against this RSL

  • Third-party testing must be performed at least annually for residual levels in finished fiber and wastewater

  • Suppliers must submit Safety Data Sheets (SDS) for all input chemicals and processing aids

  • Violations will trigger mandatory corrective action and re-certification audits

 

 

Statement of Responsibility
Suppliers and production partners are required to uphold this RSL and actively pursue safer chemical alternatives in line with PLNTmatter’s regenerative materials philosophy.