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Spotlight on the use of NPEs

The Global Organic Textile Standard and our quality assurance system ensures that all prohibited substances (including NPEs) are excluded from the GOTS certified supply chain through a combination of complementary control measures.

NPEs are mostly used as surfactants and wetting agents but also as emulsifiers, dispersants and finishers in formulations of chemical inputs in the textile industry. Once released to surface water (even if the effluent is treated in functional wastewater treatment plants) NPEs degrade to nonylphenol (NP). NP is known to be a persistent, toxic and bioaccumulative substance, able to act as a hormone disruptor. Even though legal restrictions are in place for the use of NPEs in various regions and in the EU that products containing more than 0.1% of either NPE or NP are prohibited since 2005, the Greenpeace reports indicate that NPE containing textile auxiliaries are still widely used in manufacturing countries such as China, Vietnam and Turkey. Textiles produced using these inputs are then sold throughout the EU and other regions where their use is banned.

Residue analyses published in the Greenpeace report Dirty Laundry-Reloaded reveal that a single wash (with standard laundry) can wash out a substantial fraction of NPE residues present within textile products (more than 80% NPE had been washed out in half of the plain fabric samples). This highlights the fact that residue testing on textiles according to Restricted Substance Lists (RSL)  - often the only tool used to monitor the absence of hazardous substances in the conventional textile industry – is (as in many other cases) inadequate to ensure that NPE containing auxiliaries are not used in (wet) processing.

In the GOTS quality assurance system several complementing control measures are in place to survey the ban on prohibited substances (including NPEs):

-        For GOTS, all compounds that belong to the broad group of chemicals, known as alkylphenol ethoxylates (APEOs) are prohibited, this includes all chemical inputs that contain NPEs as well as OPEs (Octylphenol ethoxylates) that have similar critical properties.

-        All chemical inputs (dyes and auxiliaries) used in the processing chain of GOTS certified textiles are subject to approval by a GOTS Approved Certifier prior to their usage. The basis for their assessment is the Material Safety Data Sheet (MSDS) that must be compiled according to a recognised norm or directive. The Approved Certifiers require further sources of information in the assessment - including additional toxicological and environmental data for specific components of the auxiliary agents, test reports and independent laboratory analysis. This means that for GOTS approved chemical inputs the presence of prohibited substances is subject to laboratory testing already before their use is released to the textile processors. In practice only the Indian laboratory Texanlab has already tested more than 3000 chemicals (about 1000 dyestuffs and pigments as well as more than 2000 auxiliaries) that have been applied for GOTS approval on the presence of NPEs and OPEs. 
Update Feb 2013: A statistical report based on these analyses, assigned by GOTS, showes that although most of the applied and tested chemical inputs have been APEO around 10,5% of the applied colourants around 4,5% of the applied auxiliaries contained APEOs and accordingly have not been approved for use under GOTS. 

-        The approved dyes and auxiliaries are compiled on positive lists that are available to all entities participating in the GOTS certification programme through their certifier. Inputs not included on the positive list may not be used.

-        As part of the on-site inspection that all businesses participating in the GOTS certification programme must undergo, the use of compliant chemical inputs is verified by examination of the recipes used. GOTS control measures in this context include inventory checks of the chemical store as well as the review of records and accounts for chemical inputs (invoices, delivery notes) to ensure that the declared and approved chemical inputs have been purchased in sufficient quantity to produce the given amount of GOTS Goods.

-        GOTS also requires testing of textile materials and finished products, in accordance with a risk assessment. Certifiers may take additional samples if there are specific risk factors or in the case of suspicion that prohibited substances have been used. While the limit values for residues in intermediate and final textile products listed in GOTS focus specifically on substances known to have a harmful effect on humans, it is not known that residues of APEOs in textiles would represent a risk to human health. However, GOTS always takes a precautionary approach and the mentioned recent investigations and publications on the use of NPEs/APEOs in textile processing and their presence in final textile products have prompted GOTS to define appropriate strict residue limits in textile products for APEOs to ensure and demonstrate that such substances do not appear in any GOTS certified textile product. The European Committee for Standardization (CEN) is currently working on establishing the first internationally recognised method for testing APEO residues in textiles, which then could be taken as the applicable reference testing method for GOTS.
Update June 2013: The 1st Revision Draft of GOTS V4 proposes a strict limit value for traces of APEOs of 20mg/kg as sum parameter for NP, OP, NPEO and OPEO