CORPORATE RESPONSIBILITY

Closet Clothing is committed to working closely with its partners to ensure all suppliers of products supplied to the company act with utmost fairness, honesty and responsibility in all aspects of their business.

Anyone supplying Closet needs to ensure they fully comply with all legal requirements relevant to the conduct of their business.

In particular, but not exclusively; business partners must:

  • not use forced, prison, indentured or bonded labour in any part of their supply chain.
  • Not employ children under the age of 15, or less than the age for compulsory education in the country of manufacture.
  • Not discriminate in recruitment or employment practices. Decision for hiring, salary, benefits, training, work assignments, discipline and termination must be based solely on ability to perform the job and not on personal characteristics such as (but not exclusively) race, creed, gender, age, disability, marital status, sexual orientation or political opinion.
  • Ensure staff are able to exercise freedom of association and collective bargaining without recourse.
  • Ensure wages must equal or exceed the minimum wage required by local law.
  • Working hours of all employees must not exceed local legal requirements.
  • All partners must practice a safe and hygienic working environment, for all employees.

Closet clothing is committed to making sure our products are sourced in line with our policies.

As a supplier to Closet Clothing, we ask for you to commit to these standards to ensure animals are treated in a humane and ethical way; and you keep to any relevant laws, such as those on hygiene and waste disposal.

For this reason, we ask all our suppliers to sign a declaration that means:

  • You must only supply leathers, skins or feathers that are by-products of the meat industry, and not the sole reason for the slaughter of any animal. Global standards agreed by the OIE (world organisation of Animal Health) must be followed in best practices for the protection of animals at the time of slaughter.
  • You must not supply any goods from endangered species on the CITIES (Convention of International Trade in Endangered Species) or IUCN (international Union for the Conservation of Nature) list.
  • No fur or feathers to be used in any products supplied to Closet Clothing.
  • You must not supply wool or woollen products that contain wool from mulesed sheep, in line with the British Retail Consortium (BRC). We reserve the right to check sources and national Wool declarations (NWD) where required.
  • Any cotton products supplied to Closet Clothing should not contain any cotton from Uzbekistan. Please ensure you can trace the origin of the cotton

Closet Clothing and brands recognises its responsibilities to protect the environment and is committed to minimising the environmental impact of its activities.

Suppliers of garments, fabrics, trims or services to Closet Clothing should ensure that they are aware of prevailing environmental legislation and that they comply with all the relevant requirements concerning emissions and use of prohibited or restricted substances.

Closet clothing will work with suppliers to help them eliminate the usage of such substances.

Restrictions on the use of certain substances are outlined below. This list is not exhaustive and does not alter the supplier’s responsibility to be aware of all prevailing legislation and must be used as a guideline only, as permitted tolerances are liable to change.

Closet Clothing reserve the right to test, or check any order, or request proof that any order complies with current regulations and legislation in all countries in which it trades. This includes, but is not exclusively the UK, EU, Canada, USA and India.

This may be done at any stage of production, delivery and sale or after sale. Suppliers should be aware of current audits taken on delivery and from shop floors. Closet will cancel any order that does not comply with legislation, or our specified limits.

If the order has already been delivered, the goods will be returned or in the case of direct imports, the full value of the goods and any claims incurred will be re-claimed, in all cases without prejudice to any other rights which Closet may have against the suppliers.

REACH is the European Union Legislation for the Registration, Evaluation, Authorisation and restriction of CHemicals. Its aim is to protect the environment and human health against the increased use of chemicals.

REACH covers Chemicals in preparations (containers of loose chemicals) and articles (Products that contain chemicals).

Any products supplied to Closet Clothing must be REACH compliant.

Please make sure you check your products do not contain any substances of very high concern (SVHC’s) as listed on the European Chemicals Agency website (ECHA).

Closet Clothing does trade within the USA under its own brand and through wholesale and departments outlets. California Proposition 65 is a constantly evolving piece of legislation designed to stop drinking water from being contaminated. It currently lists substances of concern and high concern and their permitted limits.

Products that do not meet these requirements may not be able to be sold in the USA or may have to carry a warning.

Please ensure no product is supplied to Closet Clothing that exceeds the permitted limits without the expressed permission of Closet Clothing buyer.

What is Formaldehyde?

Formaldehyde is used as a cross-linking agent for easy care finishes, in print pastes and tanned leather. It may also be found in interlinings and bonded fabrics. Formaldehyde on textiles occurs in two forms that are measured differently:

  • Free – the amount of unbound, water soluble formaldehyde derivatives
    (Test to BS EN ISO14184 part 1: 1999)
  • Released – the extent to which materials release formaldehyde into the environment
    (Test to BS EN ISO14184 part 2: 1998)

High levels of formaldehyde can cause allergic reactions and irritation/inflammation of the skin and also to the respiratory tract.
Limits
Suppliers must ensure that levels of formaldehyde are kept below the stated limits. Finishes containing Formaldehyde must not be used on fabrics or components for underwear or nightwear (refer to Fabric Performance Tables 2, 4, 5 and 14)

Adult limits:

  Limits Item
Free formaldehyde 75ppm All items
Released formaldehyde 300ppm All Items

What is Nickel?

Nickel is a metal used to improve the hardness of alloys, particularly associated with a bright metal finish. These are often present in accessories for garments, such as zips, buttons and rivets.

Risks

  • Nickel may cause sensitisation in humans and may lead to allergic reactions
    (Nickel Dermatitis)
  • Legislation has been introduced setting out control measures to reduce the incidence of nickel contact allergy and sensitisation.
  • EU Directive 76/769/EEC (12th amendment 94/27/EC)
  • UK legislation: The Dangerous Substances & Preparations (Nickel) Safety Regulations 2005.

Limits

Legislation gives three sets of requirements, depending on product end-use:

British Standard Product Limit
BS EN 1811
1999
For products in prolonged
contact with the skin
 
BS EN 12472
1999
For plated/coated products
**
< 0.5µg/sq.cm/week


** (wear simulation to represent two years wear and then tested to BS EN 1811)

Closet Clothing requires suppliers to confirm that all garments, having metal components which are likely to come into direct and prolonged contact with the skin, comply with the Nickel Directive.

Random testing should be used to confirm compliance. The Nickel Screening Kit available from the Sheffield Assay Office may be used as a spot check, but this is only indicative of the presence of Nickel. Compliance with the Regulations requires testing to the British Standard methods.

What are Azo Dyes?

Azo Dyes are a group of synthetic dyestuffs based on nitrogen. Azo Dyes are used in textile and leather products including clothing, bedding, towels, leather gloves, toys, yarns and fabrics intended for final use by the consumer.

Risks

  • Separated products of certain Azo Dyes are classified as carcinogenic and they pose a risk for the consumers and workers.

Limits

  • EU legislation has been introduced banning the use of these azo dyes or pigments in textiles and leather articles that have the potential of coming into direct and prolonged contact with human skin.
  • The restricted azo dyes are those that have the capacity to release any of the 24 aromatic amines listed in 19th amendment of the EU Council Directive 2004/21/EC(See chart at the end of this section)
  • Azo dyes or pigments, which may breakdown into banned amines, must not be used. The limit is set at 30ppm (the detection limit of the test method). Testing is set by BS EN 14362-1 or BS EN 14362-2.
  • Specific testing of individual fabrics is not required at present, providing that suppliers can certify the absence of banned azo dyes. Suppliers should confirm with their fabric manufacturers, dyers and finishers that they are aware of these banned substances and that they are not used in any process.
Banned amines of Azo Dyes CAS no
4-aminobiphenyl 92-67-1
Benzidene 92-87-5
4-chloro-o-toluidine 95-69-2
2-napthylamine 91-59-8
o-aminoazotoluene 97-56-3
5-nitro-o-toluidine 99-55-8
4-chloroaniline 106-47-8
4-methoxy-m-phenylenediamine 615-05-4
4,4-methylenedianiline 101-77-9
3,3-dichlorobenzidine 91-94-1
3,3-dimethoxybenzidine 119-90-4
3,3-dimethylbenzidine 119-93-7
4,4-methylenedi-o-toluidine 838-88-0
6-methoxy-m-toluidine 120-71-8
4,4-methylene-bis-(2-chloro-aniline) 101-14-.4
4,4-oxydianiline 101-80-4
4,4-thiodianiline 139-65-1
o-toluidine 95-53-4
4-methyl-m-phenylenediamine 95-80-7
2,4,5-trimethylaniline 137-17-7
4-amino-azo-benzene 60-09-3
2-methoxyaniline 90-04-0
2,4-xylidene 95-68-1
2,6-xylidene 87-62-7

Some dyes can create an allergic reaction if not adequately fixed during dyeing. Under an EU Commission Directive (1999/178/EC) for a Community eco-label, certain dyes can only be used if the Colour Fastness to Perspiration (acid & alkali) is a minimum Grade 4.

We will only allow a limit of 30ppm on finished product.

Restricted Substance CAS no.
Disperse blue 1 2475-45-8
Disperse blue 3 2475-46-9
Disperse blue 7 3179-46-9
Disperse blue 26 3860-63-7
Disperse blue 35 12222-75-2
Disperse blue 102 12222-97-8
Disperse blue 106 12223-01-7
Disperse blue 124 61951-51-7
Disperse brown 1 12236-00-9
Disperse red 1 2872-52-8
Disperse red 11 2872-48-2
Disperse red 17 3179-89-3
Disperse orange 1 2581-69-3
Disperse orange 3 730-40-5
Disperse orange 11 82-28-0
Disperse orange 37 12223-33-5
Disperse orange 76 51811-42-8
Disperse yellow 1 119-15-3
Disperse yellow 3 3832-40-8
Disperse yellow 9 6373-73-5
Disperse yellow 23 6250-22-3
Disperse yellow 39 12236-29-2
Disperse yellow 49 54824-37-2

Dye Carriers

Dye carriers are not to be used on any of our products without prior consent from the departmental technologist.

Carriers are used to lower the dyeing temperature of certain fibres, in machinery not designed for high temperature high pressure dyeing.

Carriers are generally toxic, can cause irritation and are suspected carcinogens

Following is a summary of other hazardous chemicals that should be noted because of Directives restricting their use and/or for their effect on the environment.

Pentachlorophenol (PCP) and Tetrachlorophenol (TCP)

These are chemicals used as a preservative on leather to combat mould growth. Also known as ingredients in print pastes as thickeners and preservatives in sizing mixes. They are carcinogenic and can be absorbed through skin contact.

Combustion of PCP/TCP releases dioxins, which can be extremely dangerous. Any item treated with them should be disposed of but should not be burned. Expert advice should be sought.

Test standards: Refer to BLC ID – 149
Limits < 5ppm

Chrome VI

Chrome VI (hexavalent chromium) is a by- product generated during the leather tanning process and should not be detectable in finished leather.

This is a heavy metal that is non-biodegradable and is carcinogenic. Commonly found in dyes and pigments, dye additives and pre/after treatments in dyeing processes, particularly associated with the leather industry. Testing: Refer to CEN TS 14495.
Limits < 3ppm

Organo Tin Compounds

Any product containing organo tins should not be used

Used in antibacterial finishes (mainly for natural fibres) and in some print inks.
Namely TBT, DBT, TPhT, TPT, TOT, TcyHT.
Testing for the presence of these substances would be by ISP WD 17353
= or < 0.5 ppm

Heavy Metals

The 8 heavy metal groups listed below (EN 71-3, Migration of certain elements) are not to be used in any part of any product, which can be worn by a minor under the age of 14. The following metals are toxic when ingested.

Lead Compounds Arsenic Compounds
Mercury Compounds Antimony Compounds
Barium Cadmium
Chromium Selenium
   

Mercury / Mercury Compounds

Must not be used in any textile products.

Lead

Closet Clothing trade in the USA and lead is not to be used in any products above the following limits as listed in California Proposition 65.

  • Rainwear (Fabric) < 30ppm
  • Rainwear (Non fabric components) < 200ppm

Cadmium

Can be found in textile and hard goods, and although it is listed as a toxic heavy metal when ingested, it is potentially dangerous when disposed of in effluent.

Current legislation limits Cadmium levels to 100ppm in 91/338/EC.

pH

The acceptable limits should be 4.0 – 7.5

Products with pH values outside these limits can cause skin irritation and even burns. Unacceptable pH levels can arise from inadequate finishing/washing off processes at the dye house and it is the Supplier’s responsibility to ensure this does not happen.

APEO / NPEO

Used widely as detergents and emulsifying agents in the textile manufacture. APEO / NPEO’s are know to contain endocrine disruptors, that have been responsible for sex changes in aquatic species.

All chemicals used in good supplied to this group must be below 1000ppm when tested in accordance with EU Directive 2003/53/EC.

Phthalates

Found in PVC as a plasticiser and in some prints as a softener.

The European Commission has issued directive 2005/84/EC, restricting the certain use of phthalates in toys and childcare articles.

Phthalates in any products must not exceed 0.1% by weight or >600ppm
There are six named phthalate plasticisers that are banned:

DINP DEHP DNOP
DIDP BBP DBP

Chloro-organic compounds

Found as solvents in dyeing and printing. Also finishing agents, flame-retardants and plasticisers. Solvents for fats and oils used as stain removers and scouring assistants.

These substances exist as liquid or gas and can affect the nervous system, with irritating effects on skin and mucous membranes.

Banned in several EU countries with general legal restrictions stipulating producer/supplier responsibility for the products.

Organic solvents

Solvents used in dyeing and printing processes (often known as kerosene or white spirit).

Inhalation can affect the nervous system and cause headaches, fatigue and nausea. Also cause irritating effects on skin, eyes and mucous membranes.

There are legal hygienic limits for workers in many countries, which must be adhered to.

Fire retardants

Certain chemicals that cause allergic reactions and are carcinogenic (e.g. ‘Tris’), are banned under the Dangerous Substances and Preparations (Safety) Regulations 1980.

The use of brominated flame-retardants and chloro-paraffins is also restricted.as listed below:

Restricted substance CAS no.
Tris, (2-3-dibromopropyl) Phosphate (TRIS) 136-72-7
Polybromobiphenyls (PBB’s) 59536-65-1
Tris – (Aziridinyl)- phosphinoxide (TEPA) 5455-55-1
Pentabromodiphenylether (PentaBDE) 32534-81-9
Octabromodiphenylether (OctaBDE) 32534-81-9

Water Repellent Finishes

PFOS / PFOA water repellent finishes are classed as very environmentally persistent, highly bio-accumulative and toxic. Their major use is in grease, oil and water resistance for textiles

The proposal has recently been accepted by the European Parliament (2006/122/EC) and restricts the presence of PFOS / PFOA textiles or other coated materials to a maximum concentration of < 1µg/m².

It is imperative that suppliers to Closet Clothing keep up to date with changes in Legislation and Legal/ technical advice should be sought as appropriate.

The following contacts will be able to provide you with the latest information referred to in this document. Browsing the Web by using the www.google.co.uk search engine will also provide some useful information.

The Independent UKAS Accredited Laboratory websites are also a good source of information for topical issues.

The Consumer Protection Act 1987 –
www.dti.gov.uk/files/file22866.pdf

The General Product Safety Regulations 2005 –
www.dti.gov.uk/files/file22713.pdf

The Trade Descriptions Act 1968 –
www.dti/gov.uk/files/file8156.pdf

The Dangerous Substances and Preparations(Nickel)(Safety) Regulations 2000 -
www.dti.gov.uk/files/file23045.pdf