Formaldehyde in clothing and textiles
Note: The guidance on formaldehyde in clothing and textiles was developed prior to introduction of the Product Safety Policy Statement provisions (section S30A) in the Fair Trading Act 1986.
This government policy statement for product safety sets out the limits of formaldehyde in clothing and textiles considered acceptable by the government.
The government product safety policy statement is intended to provide clear guidance to manufacturers and importers as to acceptable limits of formaldehyde. It is intended to complement the Consumer Guarantees Act by setting out what is considered acceptable quality and fit for purpose. The Consumer Guarantees Act guarantees to a consumer that goods must be of acceptable quality and fit for the particular purpose for which they are supplied, including that products must be safe to use.
Voluntary compliance with the policy statement will be monitored by the Ministry of Consumer Affairs Measurement and Product Safety Service. The Ministry will not have the power to take enforcement action under the Fair Trading Act if a breach with the guidance is identified. However, any evidence of failure to meet the limits set out in the policy statement will support the need for mandatory regulation under section 29 of the Fair Trading Act 1986 or even a product recall or ban under sections 31 and 32 of the Act.
Acceptable Limits of Formaldehyde in Clothing and Other Textiles
Formaldehyde limits considered acceptable in clothing and textiles are as follows:
- For clothes for babies and infants under 2 years of age: no greater than 30ppm (30mg/kg);
- For clothing specifically designed and marketed as for people (both children and adults) with sensitive skin or to avoid any sensitive reaction with skin: no greater than 30ppm (30mg/kg);
- For clothing and textiles in direct contact with skin: no greater than 100ppm (100mg/kg), or no greater than 100ppm (100mg/kg) after wash if there is a label or instruction recommending to "wash before first use";
- For clothing and textiles not in direct contact with skin: no greater than 300ppm (300mg/kg).
A product is deemed to be in direct contact with skin if a large proportion of its surface comes into direct skin contact when used as intended (e.g. shirts, underwear, bed linen). A product where no part or a small proportion of its surface comes into direct skin contact is deemed to be not in direct contact (e.g. jackets, curtains, rugs).
The acceptable testing method is EN ISO 14184-1:1999 Textiles – Determination of Formaldehyde – Part 1: Free and Hydrolyzed Formaldehyde (Water Extraction Method) which is the internationally recognised standard for testing of formaldehyde in clothing.
Why a Government Product Safety Policy Statement
As noted, the government product safety policy statement is intended to provide clear guidance to manufacturers and importers as to acceptable limits of formaldehyde without the need for regulation, and is intended to complement the Consumer Guarantees Act by setting out what is considered acceptable quality and fit for purpose.
There is no regulation of formaldehyde or other chemicals in clothing and textiles and there is no evidence to suggest that regulation is needed. However, there have been a number of possible product safety scares. These have identified that in some areas there are not clear guidelines about what are acceptable product safety standards.
Some Background on Formaldehyde
The Australian National Industrial Chemicals Notification and Assessment Scheme1 has identified that the critical health effects of formaldehyde exposure from any sources are:
- sensory irritation via inhalation exposure to formaldehyde gas (vapour), aerosol or mist;
- skin sensitisation following dermal exposure to formaldehyde solutions; and
- carcinogenicity via inhalation exposure to formaldehyde gas (vapour) or mist.
Formaldehyde is classified as a hazardous substance under the Hazardous Substances and New Organisms Act having a number of hazardous properties, including skin and eye irritation, skin sensitisation and carcinogenicity.
Formaldehyde resin products used in the textile industry include printing inks, dyes and textile finishing products. The concentrations of free formaldehyde in these products are generally less than 2%.2 These formaldehyde-based materials help bind dyes and pigments to fabrics, prevent colours from running, improve a fabric's resistance to wrinkles, ease clothing care and maintenance and prevent mildew.
Formaldehyde is also used, at low levels, in a variety of cosmetic and consumer cleaning products, in some medicines and dental products, and in some bank note paper. It is found in outdoor ambient air from combustion processes related to vehicles and from industry emissions. It is found in ambient indoor air from sources such as pressed wood (e.g., particle board), cooking and heating appliances and tobacco smoke.
Scientific Studies of Acceptable Levels of Formaldehyde in Clothing and Other Textiles
The adverse health effects from formaldehydes in textiles are likely to be skin irritations related to "free or easily hydrolyzable (reacts with water) formaldehyde."4 However, the threshold level of formaldehyde on garments that will produce dermatitis is not known.5 Neither is the reaction threshold for already sensitized subjects.
From the few studies located in recognised scientific journals, the suggestion is that only a very few people (1-4%) are sensitive to formaldehyde concentrations of 1-2% and higher (10,000ppm-20,000ppm). For sensitised people, studies show decreasing reactions with decreasing formaldehyde concentrations but that even 30ppm may elicit a reaction, if only rarely, in some already sensitized subjects.
The Australian National Industrial Chemicals Notification and Assessment Scheme6 review notes that the European Union (EU) Expert Group on sensitisation categorised formaldehyde as a strong skin sensitiser. The review indicates that formaldehyde solutions can induce skin sensitisation at very low concentrations and may elicit a dermatological reaction in individuals who have been sensitised. The skin sensitisation noted occurs from exposure to formaldehyde solution rather than to gaseous formaldehyde.