The Vietnam Industry and Trade Ministry recently released Circular 21/2017/TT-BCT, which promulgated QCVN 01:2017/BCT on contents of formaldehyde and certain aromatic amines derived from azo colourants in textile products has switched the effective date from May 1, 2018 to January 1, 2019.
According to the regulation, formaldehyde in textile products are not allowed to exceed the following limits:
- 30mg/kg in products for children under 36 months
- 75mg/kg in products which come into direct contact with skin
- 300mg/kg in products which do not come into contact with skin
In addition, aromatic amines derived from azo colourants is limited to under 30mg/kg.
Prior to sales of the good in Vietnam, all goods must have their conformity self-declared based on (i) self-assessment of manufacturers or (ii) certification/testing results from accredited certification/testing bodies.
Why formaldehyde and some aromatic amines derived from azo colourants in textile products are restricted
Scientists have studied the carcinogenic properties of formaldehyde since 1978. In 2006, the International Agency for Research on Cancer (IARC) officially classified formaldehyde as a known human carcinogen. In 2016, it was re-classified as carcinogenic - category 1B under the European CLP directive (1272/2008).
Formaldehyde is also a known sensitiser and may trigger allergic reactions in sensitive people, and was hence classified as skin sensitising category 1. As formaldehyde is synthesised in small amounts in humans, the human body has developed mechanisms to metabolise certain concentrations of the substance. All in all, this allows toxicologists to define a threshold level.
However, as formaldehyde enters the body in multiple ways (e.g. through furniture or food contact materials or through textiles), the overall concentration of exposure is challenging to estimate and has often lead to more conservative limits.
The critical concern for azo dyes relates to their potential carcinogenic effects following dermal exposure in adults and children, or the mouthing of products containing particular dyes. Some azo dyes reduce to form aromatic amines, including benzidine, a known carcinogen. Dermal exposure to benzidine-based dyes could occur though prolonged and direct contact with dyed textiles and leather articles. The release of carcinogenic aromatic amines is exacerbated by body heat, sweat and saliva.
In 1999 the 7th European Scientific Committee on Toxicity, Ecotoxicity and Environment assessing the risk of cancer caused by textiles and leather goods coloured with certain azo dyes concluded that, while consumer exposure is likely to be ”very low“, the associated cancer risks give cause for concern.
What are the opportunities for Vietnam textile products?
Manufacturers who export products to EU may already know that azo colorants in textile and leather articles that may come into direct and prolonged contact with the human skin are restricted under entry 43 of Annex XVII in REACH Regulation (EC) No. 1907/2006; and now QCVN 01:2017/BCT is applicable to all products sold in Vietnam. The implementation of this new regulation has mandated manufacturers to enhance the quality of their products, not only for the international but domestic market as well.
Consumers now pay more attention to products which are safe for human health. Compliance with regulation is your chance to open new market opportunities and position your brand well.
Test now and declare your products safe!
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