ZDHC MRSL — Manufacturing Restricted Substances List (wet-processing chemical restrictions list)
A private closed list of chemical substances prohibited in textile wet processing, administered by the ZDHC Foundation (v3.1). Unlike the SVHC (final product), the MRSL regulates the production process.
Context
The ZDHC MRSL (Manufacturing Restricted Substances List) is a private closed list of chemical substances prohibited and restricted in textile wet processing (dyeing, finishing, washing, printing) administered by the Zero Discharge of Hazardous Chemicals (ZDHC) Foundation, a non-profit organisation headquartered in Amsterdam founded in 2011 by pioneering textile-sector brands after the Greenpeace Detox campaign (2011). The current version is the ZDHC MRSL v3.1 published by the ZDHC Foundation and documented on its roadmaptozero.com platform.
Conceptual difference MRSL vs SVHC and RSL
A PROCESS list. It indicates which chemical substances may NOT be used in the wet-processing phases (dyeing, finishing, washing, printing). It applies to the chemical formulations that the chemical supplier sells to the textile facility, NOT to the final product.
A PRODUCT list. It indicates which substances may NOT be present in the finished textile product (t-shirt, trousers) above an analytical threshold. It is the logic of OEKO-TEX Standard 100 and of REACH Annex XVII.
An EU REGULATORY list of extremely concerning substances under Reg. (EC) 1907/2006 REACH Art. 59. It generates obligations under REACH (Art. 33 notification to customers, Art. 31 safety data sheet, Art. 7 registration). The MRSL covers them all but adds additional precautionary restrictions.
Structure and compliance modes
The ZDHC MRSL v3.1 lists more than 240 chemical substances or groups of substances classified into 11 categories (APEOs, chlorobenzenes, chlorophenols, brominated flame retardants, phthalates, PFAS, heavy metals, carcinogenic azo dyes, chlorinated solvents, etc.). Each substance has a maximum concentration threshold in the chemical supplier’s formulation. Compliance is verified at three ascending levels: Level 1 (self-declaration by the chemical supplier against the MRSL), Level 2 (sample audit carried out by an independent accredited laboratory), Level 3 (full audit of the supplier’s chemical management system plus analysis of formulations).
ZDHC Gateway and the Roadmap to Zero Programme
MRSL compliance is managed operationally through the ZDHC Gateway, a digital platform where chemical suppliers upload their audited formulations and where brands and textile facilities can consult which products meet the MRSL levels. The ZDHC Roadmap to Zero Programme integrates the MRSL with other instruments of the programme (ZDHC Wastewater Guidelines on discharges, ZDHC InCheck on chemical use in the factory, ZDHC ClearStream on public discharge transparency). Bluesign Technologies AG and other textile standards (including Cascale Higg FEM) operate as partners of the programme.
Articulation with European regulatory frameworks
The MRSL is not an official EU certification but it converges operationally with several European instruments. Against Reg. (EC) 1907/2006 REACH and the SVHC candidate list (Art. 59) the MRSL covers them all plus an additional percentage of precautionary substances not yet listed as SVHC. Against REACH Annex XVII (specific restrictions) the MRSL anticipates future restrictions by incorporating substances of concern under a precautionary criterion before their regulatory inclusion. Against Reg. (EC) 1272/2008 CLP the MRSL uses the harmonised hazard classifications as input but tightens the criteria. Against the future ESPR textile delegated act Art. 7 + Annex III Reg. (EU) 2024/1781, MRSL compliance will be able to function as operational evidence of the datapoint on substances of concern documented in the textile DPP.
Applied case
A European textile brand with EUR 65,000,000 of turnover articulates the ZDHC MRSL with its ESPR textile DPP and its CSRD reporting.
Tier 2 chain diagnosis. It audits its chain of tier 2 suppliers (dyeing, finishing) and identifies that 14 of the 32 tier 2 facilities are already registered in the ZDHC Roadmap to Zero Programme. The other 18 are outside.
Upstream roadmap over 18 months. It sets the objective: that 100 per cent of the chemical formulations used at its tier 2 facilities meet ZDHC MRSL v3.1 Level 2 minimum, with Level 3 for the 5 highest-volume facilities. It negotiates with chemical suppliers the progressive substitution of non-MRSL-compliant formulations.
SVHC and REACH Annex XVII articulation. It verifies that MRSL v3.1 covers all the substances currently listed as SVHC under REACH Art. 59 (candidate list) and all the REACH Annex XVII restrictions applicable to textiles, plus an additional 40 per cent of precautionary substances not yet listed as SVHC (including short-chain PFAS and new azo dyes).
ESPR textile DPP articulation. It documents in the technical dossier of the textile DPP that the product is manufactured in tier 2 facilities with MRSL v3.1 compliance verified through the ZDHC Gateway. The MRSL level (Level 1, 2 or 3) and the list of MRSL-compliant formulations function as operational evidence of the datapoint on substances of concern and chemical processes of the future textile delegated act based on Art. 7 and Annex III Reg. (EU) 2024/1781 ESPR.
Common mistakes
The MRSL is a PROCESS list, NOT a product list.
If a chemical supplier declares ZDHC MRSL compliance for a formulation, that does NOT amount to saying that the finished textile product is free of substances of concern. Compliance of the final product is verified with product lists (RSL OEKO-TEX Standard 100, REACH Annex XVII) through analysis of the finished product. The MRSL and RSL are complementary: the MRSL controls the input, the RSL controls the output.
The MRSL does NOT replace SVHC obligations under REACH.
Although the MRSL covers all the SVHCs currently listed under REACH Art. 59 and adds additional precautionary substances, compliance with the MRSL does NOT exempt the textile producer from the regulatory SVHC obligations under REACH: notification to customers with SVHC greater than 0.1 per cent w/w in the article (Art. 33), safety data sheet (Art. 31), notification in the SCIP database (Art. 9.1.i Directive 2018/851 operational since 5 Jan 2021).
MRSL Level 1 is NOT equivalent to MRSL Level 3.
Level 1 is self-declaration by the chemical supplier (an initial basis without external audit). Level 2 is a sample audit by an independent accredited laboratory. Level 3 is a full audit of the supplier’s chemical management system plus analysis of formulations (the maximum level of assurance). Communication to the customer or consumer must specify the concrete level achieved, NOT confuse Level 1 (self-declaration) with Level 2 or Level 3 (external audit).
The MRSL is NOT an official EU certification.
The MRSL is a private standard administered by the ZDHC Foundation (a non-profit organisation in Amsterdam). Although it converges operationally with REACH, CLP, SVHC, REACH Annex XVII and the future ESPR textile delegated act, it is NOT an official EU certification. MRSL compliance is voluntary and when communicated to the final consumer it must meet the certification-scheme requirements under the ECGT Dir. (EU) 2024/825.
Frequently asked questions
What is the ZDHC MRSL?
A private closed list of chemical substances prohibited and restricted in textile wet processing (dyeing, finishing, washing, printing) administered by the Zero Discharge of Hazardous Chemicals (ZDHC) Foundation headquartered in Amsterdam. Current version: ZDHC MRSL v3.1. It covers more than 240 chemical substances or groups of substances classified into 11 categories. It is an operational pillar of the upstream textile sector and an international reference for chemical management in wet processing.
What is the difference between the MRSL and the RSL and SVHC?
The MRSL is a PROCESS list: it indicates which substances may NOT be used in wet processing (the chemical supplier’s formulations). The RSL is a PRODUCT list: it indicates which substances may NOT be in the finished textile product above an analytical threshold (the logic of OEKO-TEX Standard 100 and REACH Annex XVII). The SVHC is an EU REGULATORY list of extremely concerning substances under REACH Art. 59 with specific obligations. The MRSL covers all the SVHCs plus additional precautionary restrictions.
What are the MRSL compliance levels?
Three ascending levels. Level 1 (self-declaration by the chemical supplier against the MRSL, an initial basis without external audit). Level 2 (sample audit carried out by an independent accredited laboratory, an intermediate level). Level 3 (full audit of the supplier’s chemical management system plus analysis of formulations, the maximum level of assurance). Communication must specify the concrete level achieved by each formulation or facility.
How does the MRSL articulate with the ESPR textile DPP?
MRSL compliance verified through the ZDHC Gateway will be able to function as operational evidence of the datapoint on substances of concern and chemical processes documented in the textile DPP (future textile delegated act based on Art. 7 and Annex III Reg. (EU) 2024/1781 ESPR). The MRSL level (Level 1, 2 or 3) and the list of MRSL-compliant formulations provide upstream traceability that the textile DPP will require as verifiable data.
Does the MRSL exempt from SVHC obligations under REACH?
No. Although the MRSL covers all the SVHCs currently listed under REACH Art. 59 and adds additional precautionary substances, compliance with the MRSL does NOT exempt the textile producer from the regulatory SVHC obligations under REACH: notification to customers with SVHC greater than 0.1 per cent w/w in the article (Art. 33), safety data sheet (Art. 31), notification in the SCIP database (Art. 9.1.i Directive 2018/851 operational since 5 Jan 2021).
Fuentes oficiales
- ZDHC Foundation2025-2026Voluntary standard
- ZDHC Foundation2024-2026Compliance platform
- European Parliament and Council · OJEU2025-2026Regulation in force
- European Parliament and Council · OJEU L 39630 dic 2006 · texto consolidadoBinding EU standard
