Our Third Impact Report

Driving Impact with Sustainable Chemistry

By most estimates, we have less than a decade to mitigate many of the devastating effects that climate change is inflicting. Alongside the need to drastically reduce our carbon footprint, we must also urgently address the interrelated environmental crises that receive less attention: the massive loss of biodiversity and the degradation of water sources across the planet. By building ZDHC competence centres on greenhouse gas emissions (climate change), biodiversity, circularity and water stewardship, we are tackling these interrelated problems head on. We must remember that chemistry will be part of the solution: it can help us understand, monitor, protect and improve the environment around us.
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Frank Michel
Executive Director, The ZDHC Foundation

By most estimates, we have less than a decade to mitigate many of the devastating effects that climate change is predicted to inflict. Alongside the existential need to drastically reduce our carbon footprint, we must also urgently address the parallel and interrelated environmental crises that are already severely afflicting our planet but receive less attention: the massive loss of biodiversity and the degradation of water sources across the planet. These are not abstract ecological problems and they are already impacting humanity as a whole. The scale and complexity of the global crisis we face is almost unfathomable.
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By building our competence centres on greenhouse gas emissions (climate change), biodiversity, circularity and water stewardship, we are tackling these interrelated problems head on. We must remember that chemistry will be part of the solution to these emergencies. It can help us to understand, monitor, protect and improve the environment around us.

At ZDHC, our mission is to make these sustainable chemical management practices universal in the fashion industry and help brands, manufacturers and chemical suppliers reduce their environmental footprint.

The more we can connect brands, manufacturers and chemical companies and enable them to work together to improve their sustainability, the faster we can drive innovation and change. Encouragingly, our call to action is being heard: our community is growing by leaps and bounds – 16 new Contributors and 11 new Friends of ZDHC joined in 2021

Globally scaling the Roadmap to Zero Programme is key to the success of our mission. The more we can connect brands, manufacturers and chemical companies and enable them to work together to improve their sustainability, the faster we can drive innovation and change. Encouragingly, our call to action is being heard: our community is growing by leaps and bounds – 16 new Contributors and 11 new Friends of ZDHC joined in 2021. Significantly, we are also seeing our reach beyond contributorship increasing swiftly: the uptake of our platforms and tools has nearly doubled over the last year, as you will see in this report. But with this progress comes a dilution in results, as new joiners affect not only the appearance of progress but also the availability of enough consistent data. We continue to focus on accurate data as one of the key tools to catalyse change, and encourage an increase of sharing and transparency of data to accelerate the realisation of our goals.
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As such, it is also our responsibility to provide transparency on our programme progress and how we hold our Contributors accountable for implementation – while we continue to raise the bar. To that end, we have launched the Detox Fashion Radar. It benchmarks brands that are on their Roadmap to Zero journey to detox fashion based on their engagement levels and progress of implementing our Roadmap to Zero Programme. By visualising and publicising the progress that brands have made so far, the radar also acts as an incentive for providing transparency to the interested audience.
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To act as an independent, mission-driven multi-stakeholder organisation, ZDHC has introduced an engagement journey for our key stakeholders. We have increased the diversification of income streams and reduced our reliance on contribution fees over the last year through an increase in transactional revenues collected from our external platform users (e.g. ZDHC Gateway). This enables Suppliers and Chemical Formulators to utilise our Roadmap to Zero implementation infrastructure worldwide.
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We thank you for your engagement with our programme and hope for your ongoing support in accelerating our efforts in driving sustainable chemical management in the apparel and footwear value chain.

Best regards,
Frank Michel
ZDHC Executive Director

Continuing Our Conversation
with Greenpeace

Viola Wohlgemuth, Greenpeace Circular Economy and Toxics Campaigner, talks to ZDHC about the key findings covered in Greenpeace’s recent report Self-Regulation: A Fashion Fairytale, and the need for greater regulation, the myth of circularity and a new definition of fashion.

Can you please tell us about the 2021 "Blind Check" that Greenpeace conducted on 29 brands detoxing their value chains? What were the positives and negatives?

The assessment on hazardous chemicals was mostly positive for what the "Detox My Fashion" campaign demands on the elimination of the use and discharge of hazardous materials in the global textile supply chain, and in the public transparency of wastewater data. For me, that was a basic goal for the detox campaign and it’s very important to see that it’s still going on. So, on the whole, the momentum that was started by the campaign is being maintained.

That’s one of the main messages. With leading companies and several industry stakeholders taking responsibility for not only securing the 2020 goals [Set by Greenpeace’s original Detox myFashion campaign], but also promoting them through the entire textiles sector, that for me is definitely one of the most positive things.

I see the role of ZDHC as crucial, as one of the stakeholders here, together of course with the other players, such as CID Detox consortium, or the group of textile suppliers in Italy. I think that is the most important part, seen here in our report. The big question for the future is, however, the assessment of how "slowing the flow" and "closing the loop" resets the progress on chemicals. The successes we just discussed are undermined by the failure of the fashion industry to address its overproduction and overconsumption problem. So, in a sentence, the progress we are making is being eaten up by the huge amount of textiles being produced.

GP's view on "self-regulation" is of particular interest to ZDHC since we coordinate industry-wide self-regulation. How does GP envisage organisations like ZDHC operating in a future with a more robust regulatory framework?

ZDHC has increased the impact of the Greenpeace Detox Fashion campaign, especially after its active push, by adding new members and commitments. Especially important for me is ZDHC’s role in providing practical tools, such as waste-water guidelines and Detox.Live (the ZDHC site for reporting wastewater data), as well as support for implementation. That is crucial. All this makes it easier for companies and suppliers that want to do the right thing. I think that ZDHC and similar organisations are so important to have as front-runners to show what is possible and to show that there really is the possibility to implement solutions. However, the uptake of these programs has only been from around 15% of the industry. So if you don’t have regulations, there won’t be the big shift necessary. But we need to work together for regulations. There are alarm signals of a new race-to-the-bottom, with the same pollution practices we found in Asia and central-America at the start and during the Detox campaign, now starting to shift to Africa when the clothing industry should be building on the best practices instead. This is the main reason why it’s necessary for regulation, to level the playing field through binding regulation. We cannot have some companies taking action and investing money and starting to change, while others are making a lot of money by polluting the whole country, or the whole planet, actually.

How would regulation (e.g. in the EU) positively impact manufacturing in Tanzania or other places?

I’m working with Greenpeace in Germany. We’ve worked on supply chain regulation a lot. I think these supply chain laws have to be a standard. I’m very hopeful that regulation on a European level will be much stronger than the German one. I was so disappointed to see the German one was so weak. In Germany, in public debate, everyone is saying it’s up to the consumers to get all the information about the products they are buying from. I totally disagree. I say that it shouldn’t be allowed that any textiles can come to German or European markets which are not fairly and ecologically produced. This basic idea has to be a standard. We need a strong supply chain law that is enforceable in the courts. I also think that we should have an international textile tax that would fund the clean-up of places already contaminated by textile and fashion production.

"There are alarm signals of a new race-to-
the-bottom, with the same pollution practices we found in Asia and Central America... now starting to shift to Africa, when the clothing industry should be building on the best practices instead... It’s necessary for regulation to level the playing field."

In the report you mention ZDHC's and others' successes in maintaining the momentum of the original Detox My Fashion campaign. Which factors have been key in ZDHC's success so far?

For me, the provision of practical tools have been key, such as the possibility to have waste-water guidelines organised as much as possible, so you really can use them on the ground. Then there is the Detox.Live homepage, where it’s easy to report the waste-water data, so you can see them. Everything that makes implementation as easy as possible has really been the key point. It’s a problem if you have just demands and you are standing in a factory in Bangladesh, where you have to explain how it works. You have to make solutions as accessible to people as possible. You need a usable set of tools.

Where can ZDHC improve?

We continue to be disappointed that the public can’t always access waste-water data. I think NGOs and the wider public should be considered as an ally, because increasing visibility adds to the pressure to continuously improve, and would also help for the objectives of ZDHC. As long as the wider public is not able to reach this data, they can’t be allies, and they can’t put pressure on those brands who are not doing it.
ZDHC: Regarding ‘Closing the Loop’ and ‘Slowing the Flow’, in the report, Greenpeace says that circularity is more of a myth than a practical solution. Can you explain why that’s true? Honestly, most circularity claims today are just greenwashing. Only 3% of the textiles on the market contain recycled material and less than 1% of clothes are actually made from recycled textiles. The rest [of the 3%] is just using recycled polyester from waste PT bottles from the food industry. It’s a kind of greenwashing that’s recently been called out as inaccurate by the EU in its textile strategy. It’s so obvious, we only have to examine the labels in our clothes to see that they are not made to be recycled. The whole idea of the whole industry is high volume and single-use, not built around recycling, which they don’t even think about during the design. Most products are made from mixed materials, making recycling impossible. There is little evidence of the intention to recycle beyond the commercial spin, of course. In contrast, I have seen the consequence of this flood of disposable fast-fashion in Tanzania and Kenya. I have stood literally by a river on a pile of textiles-waste, looking at riverbanks made up of layers of textiles, watching old clothes floating downstream to the Indian Ocean. This is what the circularity of the textile industry really looks like. I actually think there is no industry that is further away from recycling and circularity than the textile industry.

ZDHC: As the report makes clear, ‘slowing the flow’ is key to creating a significantly more sustainable fashion industry. What key strategies does Greenpeace want to see major brands and producers adopt internally to achieve this? For us, the key strategy to slowing the flow is business model change. Companies just cannot maintain the linear production line of disposable fashion. Clothing needs to become a service. Successful, sustainable companies need to become service providers. We need a switch from producing textiles to service providers. In Germany we are asking that, by 2030, at least 10% of retail space in public space be set aside for alternatives such as second-hand clothes stores and services that share, rent and repair clothes, and not for the sale of new goods. Unfortunately, selling new products has to be just 40% of the market, and 60% of the market for clothing has to come from second-hand, sharing, renting, and other models. So brands need to improve the quality, durability, and of course recyclability of their new clothes. This is actually not enough on its own. We also have to change the mentality of throwing away perfectly good clothes and the meaning of fashion. Brands have barely started to address this, the report shows.

Changing the meaning of fashion, that for so long has revolved around the ‘new’ is is a huge task, especially as in the fast-fashion section of the market, the cycles of production and marketing have been hyper-accelerated, mainly facilitated by the use of social Tik-Tok, Instagram and social media…

I totally agree, and it’s a very crucial point. What we need – and it’s not just Greenpeace that has to do it – is a common creative effort! Thinking about the younger generations, it’s interesting, because on the one side are those who are buying from fast-fashion brands that are growing like never before, showing people that it’s totally OK to buy and click away, but on the other side we have another demographic involved in, for example, Fridays For Future, not using their Fridays to invest in their own future and career, but using them to fight for a better climate and for the future. We have both. What we need is to connect those ideas and actions. Make people who are active on climate aware that fast-fashion, that linear business models, are actually the problem. Now in Germany, it is very uncool to fly - we have a new word Flugscham meaning ‘flight shame’. We now need something like this for textiles and fashion. We really need to change the meaning of fashion so that it’s not cool anymore to get hearts and likes if you are buying textiles from fast-fashion brands. Instead of that, we need to work with influencers, with the movement of new ecological people and the whole generation, to make sure that the alternatives are actually sexy and interesting. That’s why we also need other ways of communication. It’s not enough to have a report, and explain ‘By the way…’ That is a problem. You have to engage the people. You have to make this new world and new vision so attractive. It has to be cool on Instagram! It’s not like sitting in a dark corner and fixing your broken shoes on a Friday night! You’re going out to an event with the most popular influencer of your city and the clothes you are wearing have been made by remaking old clothes, stitched together with, say, golden thread and you’re so happy and proud with it afterwards that you’re showing it on Instagram. That’s what we need.

Since we’re talking about social media and the power it has to change people’s mindsets and even to change the norm, how can you apply that to chemistry? Chemistry is not a very approachable topic for the general public. Is there a way perhaps to make the consumer a bit more aware, and make chemistry more approachable?

That is a very interesting question that I ask myself quite often! [Laughs]. The key is to make the information on chemicals as clear and as visible as possible and to connect the facts with people's lives. It has to be so easy that, say on Instagram, when people look at things so briefly, you don’t use long chemical formulas and explanations. It just should be: ‘Destroyed river - textile’ and the information connecting these things is in your hands. It has to be very easy and visible for people to understand. I still think, and I’d connect these points, that the necessary change in the textile industry is, beyond chemicals, a new way of consuming textiles through alternative business models. We have to show this new world to be as attractive as possible and connect this to the idea of clean nature, compared to chemicals. You have to draw people in. You have to show them the wonderful future possible.

2021 Impact Results

_{Chemicals are Everywhere!}

In the air we breathe, the water we drink, in every molecule in our body… However, the word “chemical” has become synonymous with dangerous and “natural” with risk-free. Mercury, arsenic, and even snake venom are all natural chemicals, but extremely toxic! Even the most necessary chemical in existence for humans – oxygen – is deadly in large amounts. So rather than referring to all chemicals as good or bad, we try to see them in terms of what are acceptable – or hazardous – amounts for people, biodiversity and the planet. And that essentially defines what we do: ensuring that hazardous chemicals or hazardous amounts of certain chemicals are never used.
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ZDHC’s mission is to continuously drive the fashion industry towards a supply chain free of hazardous chemicals. We guide brands, manufacturers and chemical suppliers to use sustainable chemical management practices. Our approach controls which chemicals are used in the manufacturing process while accelerating the formulation (with the chemical industry) of safer, cleaner chemicals being sold in the market.
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We evaluate textile, apparel, footwear and leather brands’ and manufacturers’ effect on wastewater, air emissions and solid waste to ensure harmful substances are not released into the environment. We also help drive behaviour change through collaboration and education towards better, more sustainable wastewater practices.

Data Disclaimer 98%

Directly comparing aggregated wastewater data for all facilities to previous years is difficult as more and more suppliers join the ZDHC community and report their wastewater data to the ZDHC Gateway platform.

Following the introduction of the ZDHC Wastewater Guidelines, we have seen an increase of over 85% in suppliers following our guidelines and reporting their wastewater test results since 2019.

Each supplier is at a different stage in its journey to full adoption and implementation of both the ZDHC MRSL and Wastewater Guidelines. This means that suppliers who have been engaged in ZDHC’s Roadmap to Zero Programme have made improvements towards phasing out the use of harmful chemicals and fewer MRSL compounds are detected in their wastewater. It seems logical that while others have progressed on their journey over the years, suppliers joining the Roadmap to Zero are on their way to fully phase out the usage of chemicals listed on the ZDHC MRSL.

Therefore, until the majority of suppliers who report to the ZDHC Gateway are well established in their Roadmap to Zero journey, our comparisons and statistics for this Impact Report are calculated using only suppliers who have reported wastewater test results since April 2020 - in other words for a minimum of two annual reporting periods.

For context:
Last year's disclaimer:Since we identified the areas of impact in our first Impact Report 2019, more stakeholders have joined the ZDHC community and platforms. Therefore this Impact Report 2020 uses data that does not present a like-for-like comparison with the previous year.

Additionally please note:‍

In 2020, ZDHC completed an improvement project on published wastewater test reports. The project included a two-step approach; data audit and cleansing of the published wastewater data and development of electronic data reporting (EDR) and data validation for future data entries.The completion of the project resulted in better quality data and a more complete set of wastewater test reports making the 2020 data analysis more robust
The Impact Report 2019 leveraged the analysis based on a sample of Suppliers that had consecutive testing between 2017-2019. The same sample could not be used in 2020 as for the above mentioned data quality improvements. The Impact Report 2020, therefore, leverages the analysis including all Suppliers that conducted testing of wastewater for the April 2020 testing period.

In This 2021 Impact Report

The focus of this report is on manufacturers’ wastewater testing from 2021, how ZDHC drives the

Programme, as well as an update on the progress of our community of Brands, Manufacturing Suppliers and Chemical Suppliers.

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To learn more about our mission, our history, and the original Greenpeace report that demanded a “fashion detox,” check out About Us.

Helping Guide an Industry

We want to help protect the planet by reducing the fashion industry’s environmental impact. At ZDHC we focus on increasing the industry’s use of safer and more sustainable chemicals. We work with global brands, manufacturing facilities that make the clothes for the brands, and the companies that supply the chemicals that the manufacturers. We analyse every step of the manufacturing process, innovate improvements and work hand-in-hand with everyone involved to help them phase-out hazardous chemistry.

A Clear Path to Phase-Out

ZDHC’s Roadmap to Zero Programme outlines a clear path for brands, manufacturers and chemical suppliers to follow in order to phase hazardous substances out of their supply chains. The programme comprises in-depth guidelines, tools and educational modules – focused on the chemicals and chemistry used in manufacturing and sustainable water management – and accelerates the industry’s progress towards our ultimate goal: safer production that results in cleaner water and cleaner air, globally. Any company that commits to our Roadmap to Zero programme becomes a Contributor, but the knowledge we share is open to anyone on our ZDHC Gateway. In order to drive real industry change faster, we believe in sharing knowledge with the world. That’s why any company can use our information and tools even if they are not part of the Roadmap to Zero.

Our History

A Wakeup Call from Greenpeace

Eleven years ago, Greenpeace issued a wake-up call to the fashion industry with its “Detox My Fashion” campaign. It revealed the disastrous impact the manufacturing of clothes and shoes has on the environment. Especially alarming was Greenpeace’s “Dirty Laundry” report that exposed how suppliers in China working for global fashion brands were polluting their local water sources by dumping toxic wastewater into rivers and streams.
The industry immediately took action. A coalition of leading fashion brands pledged to eliminate hazardous chemicals from their supply chains and stop polluting waterways by 2020. This was the start of the “zero discharge of hazardous chemicals” movement, known today as ZDHC.
Now, more than a decade on, ZDHC is an established multi-stakeholder organisation based in Amsterdam, the Netherlands, with a clear mission: guiding brands, manufacturing suppliers and chemical suppliers throughout the industry to detox their supply chains and implement safer chemistry in order to protect workers, consumers, and the planet. To achieve this we created our Roadmap to Zero Programme through which we are engaging and working with an ever growing number of stakeholders.
At the end of 2019, as we approached our initial milestone of our roadmap 2020, we published our first Impact Report. We found that we’d created a mindshift in the fashion industry by moving the focus from assessing the impact of harmful substances in finished products, to eliminating hazardous chemicals throughout the manufacturing process. Our wastewater testing data showed that 98% of facilities following our programme had no detections of chemicals included on our MRSL (manufacturing restricted substance list) wastewater parameters clear evidence that our programme is working. Building on this initial success, we have shifted gear by coordinating a renewed industry commitment to the Roadmap to Zero Programme as a permanent framework for implementing sustainable chemistry throughout global supply-chains. Additionally we are constantly expanding ZDHC’s reach by bringing more stakeholders on board, improving the quality of our tools and use of our data, converging initiatives and brand programmes to minimise duplication of effort across the industry and to enable the rapid scaling of the Roadmap to Zero Programme.
Keep reading the rest of this 2021 Impact Report to learn about what we’ve achieved so far, and the goals we’re working on for the way ahead.

What is the Roadmap to Zero?

A Clear Path to Phase-OutZDHC’s Roadmap to Zero Programme outlines specific activities for brands, manufacturers and chemical suppliers to follow in order to phase hazardous substances out of their supply chains. It provides a clear path – through guidelines, tools and education – focused on chemicals used in manufacturing and sustainable water management – and accelerates the industry’s progress towards our ultimate goals: cleaner water, cleaner air, and safer production.

To learn more about what we do every day, who we work with and how we try to drive positive change, check out Our Scope.

Who We Work With: Brands, Manufacturing (Clothing) Suppliers & Chemical Suppliers

We are a multi-stakeholder collaboration of brands, manufacturing suppliers and chemical suppliers. We call the latter two suppliers, because they supply clothing and chemicals, respectively (no, most brands don’t make their own clothing or run their own factories nowadays like in the past!). Chemical suppliers provide manufacturers with the dyes, solvents, etc. for producing the shoes and clothing.

Brands & Retailers
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Trademarks/clothing labels owned by companies

Manufacturing Suppliers
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Factories that create clothing for the brands

Chemical Suppliers
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Chemical companies that make or formulate chemicals used in fashion production

Our Contributors and Our Broader Community

Any of the above groups that decide to commit to our Roadmap to Zero Programme is called a Contributor. And we’re growing! We are touching more and more manufacturers that make our clothes and more chemical companies who supply chemicals to the manufacturers. There are also other interested parties, associates, and Friends of ZDHC (groups on track to being a Contributor) who benefit from our approach, that we consider part of our wider community.
For more information on who is involved and more details on what we assess our Contributors on, check out "Our Community is Growing."

Full Disclosure:
It's An Enormous Job

Chemical management and water stewardship are a relatively small part of the industry’s negative effects on the planet, but one that takes a huge effort to reduce. Toxic air emissions, mountains of waste and labour practices are also major considerations. But we need to start somewhere, and for ZDHC, our initial focus has been on reducing the hazardous chemicals used in manufacturing. We are a young organisation and we are growing quickly. With time, we plan to expand our scope beyond fashion (check out our story

Why Only Fashion?

). But for now, this is our playground, and we are working hard to help keep it clean.

Why Only Fashion?

So why JUST fashion? We only work with the fashion industry at the moment… but it doesn’t mean that every company we work with only owns clothing. For example, Target has committed to ZDHC’s implementation framework but it only applies to their clothing and footwear, not all their other products. Likewise Inditex, the group that owns Zara, is one of our Contributor Brands, but Zara Home is not participating in the Roadmap to Zero Programme.

At times this can be confusing given the complexity of business nowadays! The reason is that neighbouring industries like furniture, home goods and the car industry that use fabric and leather may be subject to different chemical and safety regulations (like flammability). While currently we are not working with these neighbouring supply chains, we may be able to in the future.

From the outside (and even the inside!), it makes navigating these waters difficult. But we believe in being fully transparent so that it is clear what we do and whom we do it with so that each respective (part of an) industry is carefully considered. After all, each business comes with its own set of chemical requirements, so it’s important that these chemicals and their impact are properly assessed and addressed.

Expanding Our Scope
Our goal is to include neighbouring industries by 2025. This ambition is beginning to take shape but requires additional ZDHC resources to make it possible. Of course, the other industries also need to be willing to participate and implement the Roadmap to Zero programme.

Our Approach to Creating Change

Our approach is to work with the fashion industry, not demonise them. We believe the only way to create lasting (sustainable) change is to understand the current issues they are facing, including what is preventing them from doing better. Is it a lack of knowledge? Expertise? Time? Oversight? Our goal is to learn what they need and then help them improve. We believe through transparency, simplification, cooperation and education we can drive real change.

Empowering Behaviour Change, Not Policing It

ZDHC doesn’t have the ability to police the industry; we were founded and are funded by the fashion industry because they, collectively, want to do better. And policing enforces rules but doesn’t create systemic change.
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Where we add value is by guiding organisations, i.e. brands, manufacturers and chemical companies, to learn what is important — like how to use safer chemicals, reduce waste and use fewer resources. Particularly energy and water (specifically how to better clean it and use less of it). After all, they live on this planet too!

Our Focus

Our role is to help educate the companies and workers operating within the (fashion) value chain on how to handle chemicals safely, and then share what works well and what doesn’t with others; essentially bringing the change to more and more businesses (scaling up) and eventually — we hope — the entire industry. We focus specifically on:

Water stewardship
Standardisation
Improving supply chain transparency
Chemical inventory management
Training & education
Collaboration, or knowledge sharing, across the industry
Continuous improvement

Keep reading in Our Impact to see what we do specifically in each of these areas and what Contributors are accountable for.

Our Mission: Phasing Out Hazardous Chemicals

Large amounts of freshwater are often used to manufacture and process apparel, textile and footwear products. At the end of the production line, wastewater gets released. If the wastewater is not properly treated, it poses a threat to the environment, biodiversity and human health.

What We Measure: Water Quality

Water quality testing, whether it’s from a manufacturing plant or from a city’s water treatment facility, is traditionally measured according to a set of “conventional” limits, or parameters, that test temperature, pH, colour, total suspended solids, heavy metals, an excess of certain harmful bacteria, and the oxygenation level of the water. Analysis of this kind of testing helps us to understand whether the water treatment process in question is operating correctly.

Manufacturing suppliers in ZDHC’s Roadmap to Zero Programme are evaluated based on two distinct areas of wastewater testing: these Conventional Parameters (water quality) and conformity to ZDHC’s Manufacturing Restricted Substances List (MRSL).
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Conventional testing measures treated wastewater by an effluent treatment plant. These can be run by the city, municipality or regional government, or by manufacturers themselves. Manufacturers committed to the ZDHC Roadmap to Zero Programme are expected to stay within advised local limits of water quality.

Going Beyond Conventional Wastewater Testing:
The ZDHC Manufacturing Restricted Substances List

Instead of trying to remove hazardous chemicals towards the end of the manufacturing process, or from the final consumer product, we believe in preventing them from being used in the first place.
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The ZDHC Manufacturing Restricted Substances List (ZDHC MRSL) bans certain chemical substances from intentional use in textile and leather manufacturing (including rubber). The ZDHC MRSL is the foundation of our work. It offers the industry a harmonised list of banned chemical substances. They can also find a list of safer alternative chemicals, ranked into tiers of the most preferable, that they can use instead.

Read more about ZDHC’s Manufacturing Restricted Substances List.

Getting a Clear Picture: Sampling Untreated Wastewater

Understanding whether manufacturing facilities are successfully implementing ZDHC’s Roadmap to Zero Programme requires raw effluent or untreated wastewater testing. Testing of untreated water typically provides a clear picture of what chemicals are actually being used in the manufacturing processes. For the sake of this report, we test twice per year, but advise factories to test in line with sustainable wastewater practices (often several times per day).

The ZDHC Manufacturing Restricted Substances List

ZDHC created their MRSL to stop the intentional use of certain harmful chemicals in fashion manufacturing. The ZDHC MRSL identifies harmful substances banned from entering the factory at all, and it puts the industry on a better and faster path towards improving their environmental footprint.
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Three years into the programme, a subset of suppliers are making great progress. Of the suppliers that tested and published their wastewater reports in October 2021, 98% are no longer using these banned chemicals in their manufacturing.

Top 5 Exceeded ZDHC MRSL

Below are the five substances that most commonly exceed the acceptable limits determined in the ZDHC Manufacturing Restricted Substances List.

1. 4-chloroaniline AND (3) 4,4’-methylenedianiline – Part of the “Azo Dyes: Forming Restricted Amines” group in the ZDHC MRSL Azo dyes are so called because they contain the azo structure, a specific molecular bond. Some Azo Dyes have the potential to release toxic carcinogenic aromatic amine(s) if they are used. There are approximately 2000 Azo dyes available, and only a few cause concern. Azo dyes represent the most important class of textile dyes because they are so widely used to dye many different natural and synthetic textile fibres, as well as leather, plastics and paper. Luckily many azo dyes, whose azo bond can be cleaved, are already restricted in some parts of the world. They can be avoided by making careful dye selections. These restricted amines, notably 4-chloroaniline and 4,4’-methylenedianiline (#3 below) may cause cancer.

2. Perfluorooctanoic acid (PFOA) – Part of the Perfluorinated and Polyfluorinated Chemicals (PFC) group in the ZDHC MRSL ‍Perfluorinated and Polyfluorinated Chemicals (PFCs) are man-made chemicals that have been used since the mid-20th century have been used for making non-stick surfaces (like cooking pans), making fabrics water and stain repellent along with hundreds of other industrial uses. This family of chemicals includes, per- and polyfluoroalkyl substances (PFAS). These PFAS may be long-chain (with 8 carbon atoms (“C8”) or more) or short-chain (with 6 carbon atoms or fewer).

The very property that makes them useful chemicals, a strong carbon-fluorine bond, also makes them very persistent. Bacteria, light, water or air do not help break them down. They remain in the environment for a very long time and because of this they are found in water and soil all over the globe.

PFOA is a long chain (C8) PFAS banned in many parts of the world because it may cause harm to human health and the environment. It is known as a PBT chemical (persistent, bioaccumulative and toxic to the environment). It is persistent in the environment, and accumulates in water, plants and animals, especially in top predators. ZDHC MRSL bans the use of PFOA and all long-chain PFAS which were historically used in some products to make them water or oil repellent.

‍Short chain PFAS (“C6”) were created as an alternative to the long chain PFAS for making water and oil-repellent clothing. They are not currently restricted but in Version 3 of the ZDHC MRSL to be released in late 2022, the deliberate use of all short-chain PFAS will also be banned. Exceptions will be made for some protective work clothing (e.g. fire-fighting coats) where the highest levels of repellency are required for safety of the worker.

3. 4,4’-methylenedianiline – Part of the “Azo Dyes: Forming Restricted Amines” group in the ZDHC MRSL (See #1 above, which applies here as it is part of the same family).

4. Mono-, di- and tri-methyltin derivatives - Organotins Group in the ZDHC MRSL Organotins are a group of substances that are composed with, or contain tin. There are lots of organotins, and the group has many functions in the apparel and footwear industry. They may be used as preservatives for wood, paper, textiles, polyurethane, leather, and glass. They may be used to provide protection to heat and light in PVC plastics. Some are used as catalysts in the production of polymeric materials, such as polyurethane (PU)-coated fabrics, or in plastisol prints, rubber and adhesives. Silicone-based finishes (e.g., for elastomeric properties and water repellency) may also contain organotins. Because there are so many organotins, the potential harm depends on the specific organotin. Certain organotin compounds are endocrine disruptors and are toxic to reproduction. Some are classified as very persistent, bioaccumulative, and toxic; certain organotins can be toxic to aquatic life.

5. Nonylphenol Ethoxylates (NPEOs) are part of the Alkylphenol (AP) and Alkylphenol Ethoxylates (APEOs): including all isomers, group of the ZDHC MRSL. NPEOs are surfactants that are used in detergents to improve their effectiveness. They can cause skin and eye irritation in people who work with them, and therefore personal protective equipment such as gloves and eye goggles should be worn. NPEOs quickly degrade to nonylphenols, (NPs) which have a potential role as an endocrine disruptor and xenoestrogen. They are also extremely toxic to aquatic life, accumulate in the environment, and take a long time to break down. Their main use as a detergent in textiles, paints, pesticides and plastics lead to widespread release into aquatic environments. Detergents without the presence and addition of NPEOs are widely available and should be used.

A Journey of Continuous Improvement

So despite many suppliers’ best efforts, why are (ZDHC MRSL) restricted substances still showing up?

Sustainable chemical management is a long journey towards continuous improvement. So progress continues to be made, but the challenge continues, and needs to be dealt with one step at a time. One way we do so is by ensuring our ZDHC MRSL is a living document.

Why not 100%?

what is the reason behind the continuing presence of hazardous chemicals in wastewater, in small frequencies? While we can say with confidence that a majority of the ZDHC community is no longer intentionally using the ZDHC MRSL chemical substance groups, the issue that’s preventing us from phasing out 100% of MRSL listed substance groups is that of unintentional use.

Intentional Use refers to chemicals that are used deliberately in a chemical product by the textile supply chain to achieve a desired look or functionality. For example, indigo is a dye intentionally added to create denim colour.

Unintentional Use means that the chemical has not been intentionally added for producing the garment. But there may be sources of this chemical that result in it being found at low levels in the product or wastewater.

Main types of unintentional use:

Use by non-ZDHC engaged brands – Banned chemicals may be used for non-ZDHC contributors using the same supplier factory for manufacturing resulting in the continuing detection during testing of low concentrations of hazardous chemicals in the wastewater.

Chemical impurities and contaminants – Banned chemicals may exist as impurities or contaminants formed during production of the textile chemical formulation.

Inconsistent regulations – Some chemicals are regulated in some countries and not in others, and therefore may be used at some manufacturing suppliers’ sites in certain locations. This may result in the first example where contamination occurs when non-ZDHC engaged brands use them because they are not yet subject to a local legal restriction.

Maintenance and Cleaning Chemicals – Some of the chemicals on the MRSL are still used in oils for maintenance or cleaning suppliers. These may find their way into the wastewater through normal use and disposal. The ZDHC MRSL applies to these chemical products as well so we are working to eliminate these as sources.

Liquid Tanks and Piping System – A typical wet processing facility for textiles has tanks and piping systems for mixing and transferring the dyes and other chemicals. Phthalates may be present in flexible plastic tubing used or lead may be in the solder used for connections. These could then slowly leach small amounts into the tanks and pipes during normal operations which would then find their way into the wastewater. These sources are difficult to control. But as new facilities are built, older phthalate or lead-contaminated piping can be removed and replaced with safer alternatives.
Now that you know the difference between Intentional and Unintentional Use, you might ask yourself: which ZDHC MRSL parameter limits are most often exceeded? For more on that, check out the Top 5 Commonly Exceeded MRSL Parameters.

Commodity Chemicals: Opportunity and Risk

Commodity chemicals are those chemicals produced and purchased in large amounts by the textile industry. Typically these are not materials with a trademark. Acids, bases, bleach and salts are purchased in bulk from either global, regional, or local suppliers. Sometimes these offer the opportunity to use recycled chemicals from other industries – such as pharmaceuticals or electronics – which help move us towards a circular economy. However, this must be done with the knowledge that these commodity chemicals do not contain trace levels of ZDHC MRSL-listed compounds. The large quantities of commodity chemicals used mean that these impurities might show up in the wastewater.

Always Improving: The ZDHC MRSL Candidate List

The ZDHC Candidate List is how the ZDHC MRSL constantly evolves and improves. The Candidate List is a list of high-priority chemical substances that don’t yet have safer alternative chemicals (or processes) commercially available. The list is meant to highlight where innovation is needed to create safer alternatives – both in the manufacturing industry and in the chemical one.

How It Works

Chemicals or substances that are suspected to be potentially harmful or that have safer alternatives can be added to the Candidate List. The candidate substances are then researched and may be added to the ZDHC MRSL. By living on the ZDHC MRSL, the industry stays up-to-date on newly discovered or better alternatives to current substances.

Keeping the MRSL Current

Since its initial release in 2015 the ZDHC MRSLhas been regularly updated. The update process is a science-based evaluation that involves:

Collecting a list of chemicals proposed to be banned for use in fashion. Anyone can propose a chemical that should be banned to a website ZDHC created specifically for this purpose: the ZDHC MRSL Submission
platform. It’s a way to amend a limit or propose a new substance or a process that should be added to the ZDHC
MRSL. If we are missing information, we want to know about it. This platform allows people to submit their
suggestions quickly and easily.
Review of the proposed chemicals by an expert panel. The MRSL Council is an independent group composed of technical experts from diverse segments of the textile, apparel, leather, and footwear industry, and other
significant stakeholders with relevant industry knowledge and experience. They use an objective, science-
based approach to review proposed substances and then recommend whether ZDHC should include the
chemical on their MRSL and the Candidate List.

Transparency and Sharing Knowledge: The Keys to Driving Change

As mentioned,the ZDHC MRSL is a living document – anyone can propose a chemical for consideration to be added to the MRSL. The complete list of restricted substances and safer alternatives are available not only for our Contributors (ZDHC participating brands, manufacturers, chemical suppliers) but for anyone. Any company can use the lists and the Gateway with the hope of sharing knowledge. The more suppliers, chemists and businesses can learn from one another, the faster we can create better manufacturing practices for people and the planet.

The ZDHC MRSL is a living document – anyone can apply to add a substance to the Candidate List for consideration.

While the ZDHC MRSL is not meant to be a silver bullet to solve all the problems within industrial chemistry and manufacturing – particularly issues around conventional parameters – it is a great start in solving this complex global environmental crisis. By raising the bar and applying a precautionary approach to chemicals we are working with, it pushes the industry to continuously innovate to create new chemical formulations and manufacturing processes that are safer and more sustainable.

Positive change, for people, ecosystems and the environment, will only happen through a combination of leadership, corporate social responsibility, environmentally responsible business practices, legislation, and education for (and by) manufacturing and chemical suppliers. With new information, innovation, research, the influence of brands and pressure from consumers and governments, safer alternatives will become available, allowing the entire industry to shift to more sustainable chemistry.

For more on this, check out our section on “Shifting an Industry”.

Continuing to Drive Positive Impact in 2021

These statistics are based on a subset of manufacturing suppliers who tested and reported all of their wastewater results on the ZDHC Gateway in October 2021.

98% of manufacturing suppliers within our community had no detection of ZDHC MRSL restricted substances in their wastewater. Metals follow the same trend, leading to the conclusion that metals are not intentionally being used in the textile supply chain.

95% of

listed on the ZDHC Wastewater Guidelines has been eliminated in facilities conducting wastewater testing.

PFAS, PFCs, & DMFa Definitions

What is DMFa?
Dimethylformamide is a universal chemical solvent which can be a carrier for inks and dyes in printing and fiber dyeing. It is often used in textiles because it looks and feels like natural material. For example, when manufacturing shoes and handbags, textiles can often be used to imitate the look and feel of natural leather. DMFa is extremely toxic and is on the ZDHC MRSL candidate list because now there are DMFa-free materials available for use.

What are PFAS?
Per- and poly-fluoroalkyl are man-made chemicals that have been used since the mid-20th century for making non-stick surfaces, like Teflon cooking pans, or for making fabrics water- and stain-repellent. They also have hundreds of other industrial uses. The very property that makes them useful chemicals – a strong carbon-fluorine bond – also makes them very persistent.These highly toxic fluorinated chemicals build up in our bodies and cause reproductive and immune harm, cancer and other diseases. They also can wreak havoc on the environment: bacteria, light, water and air do not help break them down so they remain in the environment for a very long time and are found in water and soil all over the globe. These PFAS may be long-chain (with 8 carbon atoms (“C8”) or more) or short-chain (with 6 carbon atoms or fewer).

What are PFCs?
Perfluorinated and Polyfluorinated Chemicals (PFCs) are part of the per- and polyfluoroalkyl substances (PFAS) family, or class, of chemicals mentioned above. Since they are part of the same family of substances, the terms PFAS and PFCs are commonly confused. For the sake of this report, we refer to PFAS, which include PFCs.

For more information on DMFa, PFAS and other hazardous chemicals that we are trying to find alternatives for, see the Top Five Substances that Commonly Exceed MRSL.

79% of brands require their suppliers to adopt and implement ZDHC’s Wastewater Guidelines.

85% increase in facilities’ following ZDHC’s Wastewater Guidelines since 2019. The number of wastewater reports nearly doubled from April 2019 to October 2021.

Performance is continuing to improve with ZDHC MRSL
We are continuing to see positive results with more and more suppliers reporting their conformity to the ZDHC MRSL, particularly in Asia where we have our largest number of manufacturers.

1. Bangladesh — 315 suppliers

97% met the ZDHC MRSL Parameters
83% conformed to all Conventional Parameters
The percentage was low (which is good) for suppliers with “at least one parameter on alert” – 3% for MRSL Parameters and 10% for Conventional.*

2. India — 237 suppliers

The second-best performers were from India, although the patterns were a little less consistent. Out of 237 suppliers:

94% conformed to the ZDHC MRSL Parameters
46% conformed to all Conventional Parameters
“At least one parameter on alert” was 18% for MRSL Parameters and 6% for Conventional.

3. Turkey — 259 suppliers

Turkish suppliers did not perform well with Conventional Parameters – only 2% – which is extremely low; but did well with MRSL.

49% met all MRSL requirements
31% met the requirements for Conventional Parameters
50% of them had “at least one MRSL parameter on alert” and 56% had at least one Conventional Parameter on alert. Again, this needs to improve.

4. China* — 462 suppliers

Chinese suppliers’ performance is equally divided.

49% met all MRSL requirements
31% met the requirements for Conventional Parameters
50% of them had “at least one MRSL parameter on alert” and 56% had at least one Conventional Parameter on alert. Again, this needs to improve.

*It is not possible to see on Detox.Live data on China because Google Analytics, which we use for our reporting, is not available in China.

5. Italy

52% of suppliers conformed to the ZDHC MRSL Parameters
8% conformed to all Conventional Parameters
39% had at least one ZDHC MRSL Parameter on alert and 68% had at least one Conventional Parameter at an unacceptable level.

Conventional Parameters
Are Not Improving

While manufacturers have succeeded in removing restricted substances listed on the ZDHC MRSL, Conventional Parameters are not where they should be.
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Meeting conventional parameters is not improving year on year. The percentage of suppliers meeting conventional parameters is significantly lower than the percentage meeting MRSL parameters. This means there are fewer hazardous chemicals in the tested wastewater, but overall water quality is not where it should be, even after being treated.

Suppliers with Parameters on Alert

Conventional Parameters

ZDHC MRSL Parameters

48% of suppliers had at least one Conventional Parameter on alert compared to 22% of suppliers for ZDHC MRSL Parameters during the same period. (Remember: a lower number is better in this case!)

This can be caused by several things, including contaminants (e.g. on equipment) or poor water treatment systems at manufacturing sites or in the local community. While ZDHC’s work focuses on MRSL instead of Conventional Parameters, we believe it’s important to report on the total wastewater impact to have an accurate picture to drive real change across the industry.
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Read more about how “clean water” is conventionally defined and the five areas
that commonly exceed conventional limits.

Defining “Clean” Water: How Wastewater Is Typically Measured

Conventional testing measures whether a water treatment process or plant is operating correctly. A manufacturing facility can meet ZDHC’s MRSL requirements (more on that in the MRSL section) by avoiding banned chemicals, but to meet Conventional requirements they need to have a skilled wastewater operator to clean the water effectively. This is why ZDHC provides education and created guidelines listing the minimum qualifications for wastewater treatment system operators.

Conventional parameter testing is done on treated wastewater and measures parameters like: Biochemical oxygen demand (BOD) and chemical oxygen demand (COD), which are indicators of the oxygenation level of the water, temperature, pH, colour, total suspended solids (TSS), foaming potential, heavy metals, and levels of certain harmful bacteria. These are what most people would recognise as pollution: things that make the water cloudy, or have an odd colour, or cause algae blooms.

Below are the five Conventional Wastewater Parameters that were most often exceeded by suppliers in their 2021 reporting, and a definition of each – including the environmental consequences and the potential sources of these excesses.

5 Most Commonly Exceeded Conventional Parameters, Definitions & Environmental Consequences

1. Biological Oxygen Demand (BOD)
A freshwater lake or river becomes unhealthy when there is not enough dissolved oxygen to sustain aquatic life. BOD is a water quality indicator that indicates if the dissolved oxygen might become too low because of the wastewater.
‍Example: BOD is used, often in wastewater-treatment plants, as an index of the degree of organic (e.g. sewage, plant, animal) pollution in water.
‍Potential causes: High levels of organic matter in discharged wastewater will result in high BOD or COD values. The organic matter may come from yarn sizing, excess dyestuffs and auxiliaries or from processes involve steps that release organic matter such as natural waxes and oil from cotton and wool (e.g. lanolin) before they are dyed.
‍Environmental consequences: A higher BOD means oxygen can be more rapidly depleted. This means less oxygen is available to aquatic life which may suffocate and die resulting in a loss of biodiversity or impacts to local fisheries.

2. Chemical Oxygen Demand (COD)
‍Like BOD, COD is also an indicator of water pollution and indicates if the dissolved oxygen might become too low because of the wastewater. If is also an indicator of the total amount of organic matter being discharged.
‍Examples: Industrial effluent that contains chemicals, petroleum, cleaning chemicals, solvents.
Potential causes: High levels of organic matter in discharged wastewater will result in high COD values. The organic matter may come from yarn sizing, excess dyestuffs and auxiliaries or processes involving steps that release organic matter such as natural waxes and oil from cotton and wool (e.g. lanolin) before they are dyed. The COD to BOD ratio indicates how easily the organic matter can be oxidised.
‍Environmental consequences: Like BOD, a high COD means oxygen can be more rapidly depleted. This means less oxygen is available to aquatic life which may suffocate and die resulting in a loss of biodiversity or impacts to local fisheries.

3. Total Suspended Solids (TSS)
Total suspended solids in water are defined as any solid that is larger than 2 microns (for comparison, the width of a human hair is about 50 microns). The small particle size means that these particles do not easily settle out in the water which means the water will be the less clear and more cloudy.
‍Example: Silt, clay, some bacteria and algae can all contribute to the TSS concentration, as well as organic particles from decomposing materials.
Potential causes: Many factors cause high TSS. Specifically in the textile industry, pumice stone used in denim finishing as well as textile fibres may increase the amount of TSS in water.
Environmental consequences: TSS, if not removed, can block sunlight from entering the water and reduce photosynthetic activity, which reduces dissolved oxygen. This can impact biodiversity. It may also impact the visual aesthetics of the water.

4. Coliform
‍Coliform bacteria are organisms that are present in the environment and in the faeces of all warm-blooded animals and humans. Their presence in water indicates that disease-causing organisms (pathogens) could be in the water system.
‍Potential causes: Coliform can enter water through groundwater, surface water run-off, cracked or broken equipment, poor construction, and leaking septic tanks, if applicable. In industrial water systems bacteria can enter if domestic (i.e. water from kitchens and bathrooms in a dormitory or office area) is mixed with the industrial effluent from the textile processes.
‍Environmental consequences: Most coliform bacteria are not harmful, however, some can make people ill. A person that has been exposed to these bacteria may have an upset stomach, vomiting, fever, or diarrhoea. Children and the elderly are more at risk from these bacteria.

5. Colour
‍Highly coloured water has significant effects on aquatic plants and algae growth. Light is critical for the growth of aquatic plants, and coloured water can limit the penetration of light. A highly coloured body of water cannot sustain aquatic life, which could lead to the long-term impairment of the ecosystem.
The science: 620 nm (nanometers, which measures colour through wavelengths), or testing within the orange range, is an indication of polluted water.
Potential causes: Excess dyes that are rinsed from textiles during preparation may not be removed in the water treatment process and may contribute to unwanted colour in the wastewater. In addition, the amount and type of TSS in water can influence colour. Normally water in lakes and streams with a low accumulation of dissolved materials appears blue. Environmental consequences: Generally, coloured water imparts adverse effect on human health and aquatic environment. Light is very critical for the growth of aquatic plants and coloured water can limit the penetration of light. A highly coloured body of water cannot sustain aquatic life, which impairs the ecosystem.

How ZDHC Adds Value:
Water Stewardship & Driving Behaviour Change

What is water stewardship? Stewardship means the responsible management of resources. Water stewardship is defined as using water in a way that is socially equitable, environmentally sustainable and widely economically beneficial. On a process level, water stewardship can include resource efficiency (focussing on using less water) as well as cleaning up the quality of water that is used through wastewater treatment at manufacturing sites and water catchment locations. In essence, it is about water advocacy.

Implementing Sustainable Water Management Practices in Manufacturing
‍
ZDHC educates brands and specifically their manufacturers on the importance of water stewardship. Specifically (but not limited to):

Frequent, consistent water sampling

Training wastewater operators at treatment plants

Reducing wet processing.

Read more about some of our Water Stewardship Education for Brands and Manufacturers.

The Importance of Frequent, Consistent Water Sampling

Wastewater testing is complex and expensive; choosing the right wastewater sample to test is critical. One of ZDHC’s goals is to increase the frequency and consistency of wastewater sampling by all manufacturers. Enforcement by brands and legislation is key to achieving this.

1. Biological Oxygen De‍

Educating Wastewater Operators

While controlling chemical inputs by only using chemicals meeting the ZDHC MRSL will eliminate these harmful chemicals from entering the wastewater and ultimately being discharged, the water must still undergo a treatment process to bring it to a quality suitable for environmental discharge.

Depending on the wet processes at the facility, this may involve removing solids, salts, nutrients such as phosphate and nitrogen as well as adjusting the pH. Only then can the water be returned to the environment.

Water quality often depends not only on the proper operation and equipment of an effluent treatment plant – including not overloading its capacity – but also on the skill of the wastewater treatment operator. A skilled operator must look at the incoming water every day and alter their processes multiple times a day depending on the water’s needs.

For example, treating the wastewater from your dishwasher is slightly different than treating the water from your washing machine. Just like if you add the wrong detergent to your dishwasher you could have a sudsy disaster at home, it’s the same at a water treatment facility. The WW operator is constantly trying to balance these incoming needs.

These processes require the specialised skill of a qualified wastewater treatment operator. They will frequently check water quality before water is discharged and then adjust the treatment process as needed to ensure water is returned to the environment meeting all the requirements. The goal of every facility should be to have water treatment operators with the right training and experience to run the water treatment plant efficiently while treating the water effectively. Each facility should also have multiple trained operators and/or succession plans in place in case a skilled operator leaves or has multiple positions in a factory (which often can be the case with highly skilled technical employees – the best wastewater operator is also often the person who can find that perfect blue in a dyeing process!).

How We Help Create Other Water Stewards
ZDHC holds training sessions for operators as well as shows brands what they should look for. We also guide manufacturers on the importance of monitoring their chemical inventories.

Reducing Wet Processing

Textile processing uses vast amounts of water. Even changing yarn into a dyed piece of cloth requires chemicals to be added and then removed after each step – usually by rinsing with a lot of water. For example, a fabric needs to be scoured and bleached with natural enzymes before dyeing; the bleach then needs to be neutralised and washed off and the detergents rinsed out before the dye can be added.
ZDHC is identifying ways to use less water during textile processing. Fortunately there are many ways to do just that. Some include:

Dyeing polyester with carbon dioxide using a water-free process
Using specially formulated dyes which are designed to colour cotton with far less water while achieving the same quality
Using bleaching agents based on natural enzymes that don’t require a neutralisation step
Finishing jeans with stones, lasers, and sandpaper – all without water! (Stone washed jeans are notorious for using vast
quantities of water).

The result: better resource efficiency. The less water used, the less water there is to clean up!

Creating Standardisation Drives Manufacturing Improvement

“If we can’t measure it, we can’t prove it.” How creating standardisation and data reporting drives better results.

The ZDHC Gateway is the world’s largest database of chemical products with safer choices for the textile, apparel & footwear industry, aimed at cleaning up supply chains and eliminating harmful substances.

In 2019, Roadmap to Zero manufacturing facilities started to inventory their chemicals and report their results on the ZDHC Gateway

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in order to monitor their conformity to the ZDHC MRSL. Just like the MRSL stops certain toxic chemicals from entering the manufacturing process, an inventory keeps these restricted substances from even entering the factory gate.

In the three years since we began collecting this data, we have seen a significant increase in the use of ZDHC’s “toolkit” (the various materials ZDHC provides for suppliers to help implement improvements) which parallels an improvement in the quantity and quality of the captured chemical inventory data.

“The inventory keeps these restricted substances from even entering the factory gate.”

Particularly the number of suppliers who track their chemical inventory has improved dramatically.

11,921 Chemical Inventory Reports were created via ZDHC Gateway in 2021.

There was an 172% increase in facilities creating regular reports since 2019.

Read more about how chemical inventories drive better visibility for suppliers.

There are a lot of companies out there who want to do the right thing but may not have the professional tools or data in place. For some, they are monitoring so many suppliers across continents it can be hard to keep track of everything in a consistent way. By giving them a helping hand in standardising their data management, and sharing an approach that everyone uses across the industry (harmonising), we can help suppliers not only keep track of everything they are responsible for but have better visibility on the impact of what they are doing. So not only will they have better business practices, but also better results – which is not only good for the environment but also their bottom line.

The Importance of a Chemical Inventory

ZDHC has a tool which provides a standardised way for manufacturers to create and maintain a chemical inventory (even down to their cleaning products!) to keep track of what chemical substances they are using in their facilities. It also helps drive one way of doing things for factories who work with multiple suppliers and multiple countries.

What are the benefits?

It helps promote transparency and helps their purchasing team make informed decisions
It helps to prevent cross-contamination by keeping banned products from even entering the factory gate
It helps make the factory more efficient and consistent in operations by reducing the possibility of ordering the wrong chemical or running out of a critical chemical product.

Status of Chemical Inventory Reporting
Suppliers’ conformity to using the chemical inventory increased throughout 2021.

In January 2021, approximately 65% of chemical formulations conformed to the ZDHC MRSL and were uploaded to the ZDHC Gateway

By December this increased to 81%.

This indicates that more textile chemical formulations are improving and meeting ZDHC MRSL requirements. There is also evidence that suppliers are also using other ZDHC tools to make informed decisions about the chemicals that they buy and use. These tools help them to self-assess their processes and their compliance to ZDHC MRSL. With time, education and experience their performance should continue to improve.

Collaboration Thrives on Transparency & Sharing

So how do we intensify our impact even further? By sharing what we are doing (collaboration) and approaching things in a similar way (standardisation).

We believe in being transparent and want our supplier community to do the same. However, transparency isn’t only about ethics, it is also about keeping track of complex information and sharing knowledge and data so that everyone who needs information can access it – and relevant groups from the outside can learn what is relevant for them – giving life to our movement beyond our contributorship.

To encourage this, we launched Detox.Live – a website with the exact locations and real-time reporting of all the brands and manufacturers who have committed to ZDHC’s Roadmap to Zero Programme.
‍
Click below to learn more about Detox.Live and our other efforts towards collaboration and transparency.

How We Measure the Impact of ZDHC’s Roadmap to Zero Programme

Our community measures its progress towards the phasing out of hazardous chemicals from their value chains by:

Collecting data on chemical inventories
Conducting wastewater tests in their manufacturing facilities
Verifying their wastewater tests via ZDHC-accredited third party laboratories
Sharing their data and results via the ZDHC Gateway

Practical Ways of Promoting Transparency and Reporting
‍So how do we do this? By providing tools and education on how to do things better and platforms that encourage the sharing of information that our community needs to do better.

A few of our key tools and platforms:

The ZDHC Gateway – The world’s largest database of sustainable chemical products for textile and leather manufacturing. It supports manufacturing facilities to identify safer chemicals to use in their processes that conform to the requirements of ZDHC’s Manufacturing Restricted Substance List ( ZDHC MRSL).

DETOX.Live – An interactive map launched by ZDHC in 2018 that discloses brand’s supply chain relationships and the conformity of their manufacturing facilities with ZDHC’s Wastewater Guidelines. Highlighted on the map is the geographic location of facilities with the colour-coded status of their wastewater testing results.

Third-party verified – Wastewater reports that are generated by ZDHC-accepted laboratories and uploaded to the ZDHC Gateway. You can read more about ZDHC’s criteria for approving and accepting credible and qualified third-party
organisations such as labs here.

Wastewater Test Reports — ZDHC Guidelines require wastewater testing to be done and reported twice per year, in April and October. The test data is uploaded and published to the Gateway and Detox.Live.

What is DETOX.Live?

DETOX.live shows Contributors’ (suppliers) locations and their real-time compliance* to the Roadmap to Zero Programme.

What can you see on Detox.Live?

Compliance — Colour-coded indicators on the map show if suppliers meet ZDHC’s requirements. Green means they got there, red not yet, and yellow they are taking corrective action.
Supplier details — Including address and reports. This helps everyone to learn more, especially brands in search of sustainable suppliers.
Verified Data — Suppliers can submit verified test results to DETOX.Live. That data is checked in line with ZDHC’s requirements, so it’s transparent, accepted by everyone and easily shared.
Industry Connections — DETOX.Live lets you flag relationships between brands and their suppliers. It highlights connections between facilities and brands from the ZDHC Community.

Check it out here
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Be sure to use the filter on the left to view the relevant information!
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*Note: “Compliant/compliance” refers to brands and suppliers meeting the requirements outlined in the ZDHC Roadmap to Zero Programme. It does not infer legal or regulatory compliance.

Helping Shift the Industry

Based on the results, the entire apparel and footwear industry appears to be shifting, even outside active participation in the ZDHC Roadmap to Zero Programme.

When the programme started in 2019, only 38% of new suppliers met all Conventional Parameters upon joining. Now, after only three years, in October 2021, nearly 60% of new suppliers already meet them upon joining.

In October 2021, 76% of new suppliers met all ZDHC MRSL parameter requirements before even joining the Roadmap to Zero, compared to 70% in 2019.

So what is driving this shift? Accelerating the demand for chemical formulations

While we can’t take all the credit, we believe we are having a positive influence. The increasing availability of better

Chemical formulations – The scientific “recipe” of substances used, as well as the safe, acceptable amount that a chemical company should follow when creating a chemical substance for sale.

which can be found on our ZDHC Gateway, makes it easier for (brands and) manufacturers to avoid the use of restricted substances, which in turn leads to safer processes in fashion apparel and footwear products. Additionally, the more shared (reported) chemical inventories and regular engagement between brands, manufacturers and chemical suppliers, both on the ZDHC Gateway and offline, will further amplify the positive impact.
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Read more about how chemical formulators around
the world are sharing their chemical formulations on
the Gateway and connecting with brands and manufacturers.

Conventional testing usually measures things like: temperature, pH, colour, total suspended solids, heavy metals, an excess of certain harmful bacteria, and the oxygenation level of the water. It is done on discharged (already-treated) water, which helps assess whether the water treatment process is operating correctly.
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Just like us, fish need oxygen to breathe, and they get it from water in the form of dissolved oxygen. The higher the temperature and saltier the water, the less dissolved oxygen is present – which means less available for fish to breathe. Fertiliser run-off can cause too many nutrients (like nitrogen and phosphorus) to enter the water, and combined with pollution, can encourage bacteria and plant growth. When the plants die, they decay in the freshwater and use up all of the dissolved oxygen in the process.
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Below are the five Conventional Wastewater Parameters that were most often exceeded by suppliers in their 2021 reporting, and a definition of each – including the environmental consequences and the potential sources of these excesses.

How We Measure the Impact of ZDHC’s Roadmap to Zero Programme

1. Biological Oxygen Demand (BOD)
A freshwater lake or river becomes unhealthy because there is not enough oxygen to sustain life. BOD is a water quality indicator that indicates how much oxygen is needed to break down organic (biological) matter in water. A high BOD means that too much oxygen is being removed from water, which means that there is less available for aquatic life, and a sign of lower water quality.
Example: BOD is used, often in wastewater-treatment plants, as an index of the degree of organic (e.g. sewage, plant, animal) pollution in water.
Potential causes: Many factors affect BOD. Pollution in the form of nutrients such as nitrogen and phosphorus often come from fertiliser runoff.
Environmental consequences: A high BOD indicates unhealthy water that can not sustain life because there is not enough dissolved oxygen for fish to breathe. This means that less fresh water is available and can lead to huge water shortages across the globe.

2. Chemical Oxygen Demand (COD)
‍COD is also an indicator of water pollution and is defined as the amount of dissolved oxygen needed in water to oxidise chemical organic materials and pollutants.
Examples: Industrial effluent that contains chemicals, petroleum, cleaning chemicals, solvents, etc.
‍Potential causes: Industrial manufacturing. If water isn’t correctly treated, the COD will be high.
‍Environmental consequences: Like BOD, a high COD indicates unhealthy water that can not sustain life because there is not enough dissolved oxygen for fish to breathe. This means that less fresh water is available that leads to huge water shortages across the globe.

3. Total Suspended Solids (TSS)
Total suspended solids in water are defined as any solid that is larger than 2 microns. The more solids that are present in the water, the less clear and more cloudy the water will be.
Examples: Silt, clay, some bacteria and algae can all contribute to the TSS concentration, as well as organic particles from decomposing materials.
Potential causes: Many factors cause high TSS. Specifically in the textile industry, pumice stone used in denim finishing as well as textile fibres may increase the amount of TSS in water.
Environmental consequences: TSS, if not removed, can block sunlight from entering the water and reduce photosynthetic activity, which reduces dissolved oxygen.

4. Coliform
‍Coliform bacteria are organisms that are present in the environment and in the faeces of all warm-blooded animals and humans. Their presence in water indicates that disease-causing organisms (pathogens) could be in the water system.
Potential causes: Coliform can enter water through groundwater, surface water run-off, cracked or broken equipment, poor construction, and leaking septic tanks, if applicable.
Environmental consequences: Most coliform bacteria are not harmful, however, some can make people ill. A person that has been exposed to these bacteria may have an upset stomach, vomiting, fever, or diarrhoea. Children and the elderly are more at risk from these bacteria.

5. Colour
‍Highly coloured water has significant effects on aquatic plants and algae growth. Light is critical for the growth of aquatic plants, and coloured water can limit the penetration of light. A highly coloured body of water cannot sustain aquatic life, which could lead to the long-term impairment of the ecosystem.
The science: 620 nm (nanometers, which measures colour through wavelengths), or testing within the orange range, is an indication of polluted water.
Potential causes: TSS in water influence colour, and the colour of the water depends on the type of TSS. Transparent water with a low accumulation of dissolved materials appears blue. Dissolved organic matter, such as humus, peat or decaying plant matter, can produce a yellow or brown colour. Some algae produce reddish or deep yellow waters. Water rich in phytoplankton and other algae usually appears green and soil runoff produces a variety of yellow, red, brown and grey colours.
‍Environmental consequences: Generally, colored water imparts adverse effect on human health and aquatic environment. Light is very critical for the growth of aquatic plants and colored water can limit the penetration of light. A highly colored body of water cannot sustain aquatic life, which impairs the ecosystem.

The ZDHC Gateway’s Chemical Module is an online platform that helps with registering and finding chemicals that conform to the ZDHC MRSL, which gives chemical formulators guidance on substances they must avoid using, and offers better, safer chemical alternatives. Chemical companies throughout the world are registering themselves and their products on the ZDHC Gateway. We only report on companies that have been active over the last 12 months. The ZDHC Gateway provides useful material (tools) that brands, suppliers and chemical formulators can use and facilitates an exchange of information between them.

Connecting all of this information (data) at one central point increases the overall visibility of the chemicals being used throughout the industry. It also provides an opportunity to connect, learn and collaborate with one another: one of the key ways to create positive change.

Brands & Retailers

Brands can engage with their supply chain, communicate their requirements for safer chemistry and strengthen relationships with their suppliers. They can also use the platform to get visibility of what their suppliers are doing. Reporting to multiple interested parties (their stakeholders) is also made easier, through one online repository.

Manufacturing Suppliers

Manufacturing suppliers also benefit because they must find and buy chemical formulations they will use to manufacture their products. Using the ZDHC Gateway ensures that they are conforming to our industry standards and avoiding chemicals on the ZDHC MRSL. They see their customers’ (the brands) requirements, when and where they have been defined for them. It also helps them demonstrate their commitment to safer chemistry to the brands and the results of their work. As many manufacturers create products for multiple brands, they can use brand-specific filters to be sure to stay on top of the requirements provided for them. Manufacturers can also choose to publish their wastewater results on the Gateway, bringing more transparency to the industry and helping suppliers learn from each other.

Chemical Suppliers

Chemical companies (formulators) register themselves on the ZDHC Gateway. They hire 3rd party assessors who review, audit and assign each formulation to ensure it confirms to the ZDHC MRSL requirements. These chemical formulations are then uploaded to the Gateway for everyone who has access to see and use. It also helps chemical companies position themselves as leaders to brands and manufacturers in reducing hazardous chemical use, especially if the formulation has a better/higher rating.

For more on our chemical levels and ratings, and more on the ZDHC Gateway, check out this video.

How Brands and Suppliers are Driving Impact and Connecting on the Gateway

Collecting supply chain and factory data via ZDHC’s Gateway helps generate our Impact data. The data allows us and our community to track Roadmap to Zero implementation progress and identify areas for improvement. We are improving our collection and analysis of data every year to provide better information for the decisions we make on the ZDHC’s direction and the continual improvement of our guidelines, platforms and solutions.
‍
For more information check out: https://www.zdhc-gateway.com/

45% increase of active suppliers who are active on the Gateway for a total of 6372 suppliers in October 2021

44% increase in Chemical Suppliers’ participation in ZDHC’s Gateway

45% increase in Chemical Formulations meeting ZDHC requirements on the ZDHC Gateway

40% of the brands are connected to more than 60% of their suppliers’ share in the ZDHC Gateway

85% of brands require suppliers to register to the ZDHC Gateway Chemical Module and 75% even encourage their sub-suppliers to register

54% of brands set brand filters on the ZDHC Gateway Chemical Module (either Level 1: Foundational, Level 2: Progressive, or Level 3: Aspirational)

47% of brands require ZDHC Performance InCheck to be done at least annually

A Ripple Effect

The combination of market forces, shaped by ethical and sustainable guidelines, is a powerful engine for change. As the impact of ZDHC’s work spreads throughout the industry in a ripple effect, we have seen that many brands, suppliers and manufacturers are beginning to improve their processes or value chains, including using more sustainable chemicals, even before they formally join the ZDHC Roadmap to Zero Programme; thus accelerating a genuine, industry-wide shift towards sustainability.
‍
Be sure to check out the last section of this Impact Report to see more about our vision for the future.

Our Movement is Growing!

The Broader Our Reach, the Lower the Industry’s Chemical Footprint
‍
We are a multi-stakeholder collaboration of fashion brands and retailers, manufacturers and chemical suppliers. To be successful, strong engagement within our community is key. Since we started our work in 2015, our community has grown rapidly every year and continues to do so. And we actually have two communities! Our ZDHC Contributor community consists of companies that have committed to implementing our Roadmap to Zero Programme across their value chains while also developing and improving the programme itself in collaboration with us. Our wider community, outside of contributorship, consists of companies that have access to the ZDHC Gateway and its vast library of safer, alternative chemical formulations (often suppliers of suppliers) – all of which conform to the ZDHC MRSL.

Read more about our communities and their engagement in the Roadmap
to Zero Programme.

In 2021 there was a 37% increase in active suppliers on the ZDHC Gateway.

A large increase indicates that the impact is spreading farther and wider. Additionally, ZDHC’s (and other NGOs) water stewardship education and efforts are raising awareness about responsible corporate practices (Be sure not to miss our section on Water Stewardship and training wastewater operators).

ZDHC also focuses on reducing complexity and sharing the best practices in the industry. The more educated the workforce, and the more companies adopt these practices, the better the chemical and textile formulations. So the results will continue to grow. And along with it, the positive impact.

Brands Are Driving Adoption of the ZDHC Wastewater Guidelines with their Manufacturers

The rates of adoption, monitoring and correction plan follow up have doubled in a year:

96% of brands communicate the ZDHC Wastewater Guidelines to some or all of their suppliers

75% of brands require suppliers to adopt and implement the ZDHC Wastewater Guidelines

75% of brands set the requirement for wastewater testing result to meet – at a minimum – the ZDHC Wastewater Guidelines Foundational level limits for Conventional Parameters

82% of brands require suppliers to follow-up by creating corrective action plans on non-conformity in wastewater test results

67% of brands impose consequences if suppliers do not commit to adopt the ZDHC Wastewater Guidelines

75% of brands impose consequences if suppliers do not follow-up on non-conformity as indicated in wastewater test results

86% impose consequences for suppliers who do not commit to the ZDHC MRSL

75% require suppliers to substitute non-conforming MRSL substances with safer alternatives.

What we are working on for the future

Only 43% require chemical management training; only 25% ZDHC training

96% monitor performance to MRSL; 50% use ZDHC’s monitoring system, their own system or a 3rd party system

How companies can get involved with ZDHC

Brands

Become “Friends of ZDHC” for a trial 18-24 months maximum and then can commit to Contributorship.

Manufacturers

Join the Supplier to Zero Programme and qualify to become Contributors when achieving the Aspirational Level.

Chemical Suppliers (Formulators)

Register in the Gateway and upload MRSL-conformant chemical products. They can qualify to become a Contributor when they achieve certain eligibility criteria which proves they have responsible production practices.

More Community Engagement on the Roadmap to Zero
Equals More Success!

Here are some numbers reflecting community engagement in 2021:

16

new Contributors joined in 2021

178 contributors — seven times the number we started with.

We are improving our impact as new contributors join ZDHC and engage on the Roadmap to Zero.

‍View our global coverage.

260%

more traffic

Our publicly available resources (on the ZDHC Knowledge Base) are consulted daily! Website visits were up every month to 70k.
‍
A majority of the visitors was from Bangladesh and Pakistan.
‍
Our customer support team answered over 5000 queries.

our number of events

Tripled

We organised more than 30 events in 2021, increasing awareness and education among ZDHC stakeholder worldwide.

2.000

learners in the ZDHC Academy

The number of people going through training was back up and at an all-time high.

50%

increase in published Wastewater Test Reports on the ZDHC Gateway

45%

increase in published chemical products on the ZDHC Gateway

The ZDHC Gateway has nearly

doubled

in size since 2020

As of of May 2022 we now have 11.500 active participants/registrants

+31% chemical formulators

+44% Suppliers

We reached

10.000

participants in 2021!

Our Third Impact Report

Driving Impact with Sustainable Chemistry

A Word from Our Executive Director

Continuing Our Conversation with Greenpeace

Interview with GP Toxics Campaigner Viola Wohlgemuth

Can you please tell us about the 2021 "Blind Check" that Greenpeace conducted on 29 brands detoxing their value chains? What were the positives and negatives?

GP's view on "self-regulation" is of particular interest to ZDHC since we coordinate industry-wide self-regulation. How does GP envisage organisations like ZDHC operating in a future with a more robust regulatory framework?

How would regulation (e.g. in the EU) positively impact manufacturing in Tanzania or other places?

In the report you mention ZDHC's and others' successes in maintaining the momentum of the original Detox My Fashion campaign. Which factors have been key in ZDHC's success so far?

Where can ZDHC improve?

2021 Impact Results

Chemicals are Everywhere!

In This 2021 Impact Report

About us

Preserving Our Planet

Helping Guide an Industry

What is the Roadmap to Zero?

A Clear Path to Phase-Out

Our History

So what does Greenpeace think of ZDHC’s progress so far?

Our Scope: Fashion, Apparel, Textile, Footwear and Leather... for Now

Who We Work With: Brands, Manufacturing (Clothing) Suppliers & Chemical Suppliers

Our Contributors and Our Broader Community

Full Disclosure: It's An Enormous Job

Our Approach to Creating Change

Empowering Behaviour Change, Not Policing It

Our Focus

Our Mission: Phasing Out Hazardous Chemicals

What We Measure: Water Quality

Going Beyond Conventional Wastewater Testing:The ZDHC Manufacturing Restricted Substances List

The Foundation of Our Work: ZDHC’s Manufacturing Restricted Substances List

Getting a Clear Picture: Sampling Untreated Wastewater

The ZDHC Manufacturing Restricted Substances List

Top 5 Exceeded ZDHC MRSL

A Journey of Continuous Improvement

Always Improving: The ZDHC MRSL Candidate List

How It Works

Keeping the MRSL Current

Transparency and Sharing Knowledge: The Keys to Driving Change

Continuing to Drive Positive Impact in 2021

Our Top Performing Countries in 2021

1. Bangladesh — 315 suppliers

2. India — 237 suppliers

3. Turkey — 259 suppliers

4. China* — 462 suppliers

5. Italy

Conventional Parameters Are Not Improving

So What Are Conventional Parameters?

Defining “Clean” Water: How Wastewater Is Typically Measured

5 Most Commonly Exceeded Conventional Parameters, Definitions & Environmental Consequences

How ZDHC Adds Value: Water Stewardship & Driving Behaviour Change

Educating Manufacturers on Wastewater Management

The Importance of Frequent, Consistent Water Sampling

Educating Wastewater Operators

Reducing Wet Processing

Creating Standardisation Drives Manufacturing Improvement

“The inventory keeps these restricted substances from even entering the factory gate.”

The ZDHC Inventory List: A Step Towards Better Visibility

The Importance of a Chemical Inventory

Collaboration Thrives on Transparency & Sharing

Transparency Drives Impact & Collaboration

How We Measure the Impact of ZDHC’s Roadmap to Zero Programme

A few of our key tools and platforms:

What is DETOX.Live?

What can you see on Detox.Live?

Helping Shift the Industry

So what is driving this shift? Accelerating the demand for chemical formulations

The ZDHC Gateway: The Backbone of ZDHC’s Roadmap to Zero Implementation

How We Measure the Impact of ZDHC’s Roadmap to Zero Programme

How Brands and Suppliers are Driving Impact and Connecting on the Gateway

A Ripple Effect

Our Movement is Growing!

Our Community is Growing!

In 2021 there was a 37% increase in active suppliers on the ZDHC Gateway.

Brands Are Driving Adoption of the ZDHC Wastewater Guidelines with their Manufacturers

What we are working on for the future

How companies can get involved with ZDHC

More Community Engagement on the Roadmap to Zero Equals More Success!

16

260%

A Word from Our
Executive Director

Continuing Our Conversation
with Greenpeace

Interview with GP
Toxics Campaigner Viola Wohlgemuth

_{Chemicals are Everywhere!}

Full Disclosure:
It's An Enormous Job

Going Beyond Conventional Wastewater Testing:
The ZDHC Manufacturing Restricted Substances List

Conventional Parameters
Are Not Improving

How ZDHC Adds Value:
Water Stewardship & Driving Behaviour Change

Educating Manufacturers
on Wastewater Management

The ZDHC Gateway: The Backbone
of ZDHC’s Roadmap to Zero Implementation

More Community Engagement on the Roadmap to Zero
Equals More Success!