Chemicals Watch List
A Common Reference Framework for Chemical Transparency
The first sector-specific Chemical Watch List for textile, leather, apparel, and footwear manufacturing, developed through collaborative expert input and aligned with EU sustainability regulations.
Key principles
Intended use and target audience
The Chemical Watch List supports multiple stakeholder groups in advancing sustainable chemical management:
Brands
Use the list to identify SoC present in their value chain, enabling transparent reporting, informed materiality assessments, responsible sourcing decisions, and enhanced product stewardship.
Suppliers
Use the list to identify SoCs in manufacturing processes, identify substances potentially subject to future restrictions and initiate risk assessment or substitution where relevant.
Chemical Formulators
Reference the list to understand which substances may require disclosure or reporting and align with sustainability expectations from brands and supply chain partners.
Auditors and platforms
Use the watchlist as a harmonised reference for verifying chemical disclosures, supported by validated SDS data.
Policy makers and standard-setting bodies
Recognise the watchlist as a sector-specific contribution to harmonised chemical transparency and reporting.
ZDHC
Use the watchlist to inform the future development of the MRSL, ensuring it remains scientifically grounded, forward-looking, and aligned with both industry practice and regulatory developments.
Sustainability regulatory context
ZDHC recognises that credible, transparent chemical management is essential for achieving broader sustainability goals, such as:
- reducing pollution;
- promoting safer production practices;
- enabling informed decision-making throughout the value chain.
The Chemical Watch List supports these goals by serving as a common reference that fosters alignment across industry stakeholders.
Regulatory Response This sustainability commitment also responds to the increasing regulatory momentum seen in frameworks like the CSRD and the ESPR, development that acted as the catalyst for ZDHC to strengthen its role in promoting chemical transparency and harmonised reporting practices across the industry.
Regulatory Response
The CSRD and ESRS require companies to disclose impacts, risks, and opportunities across environmental, social, and governance dimensions. Out of the five ESRS environmental standards, two are particularly relevant to the ZDHC Sustainable Chemical Management Framework: E2 Pollution and E3 Water and Marine Resources
E1 — Climate Change
E2 — Pollution
E3 — Water and Marine Resources
E4 — Biodiversity and Ecosystems
E5 — Resource Use and Circular Economy
Pollution Disclosure (E2)
Under E2, companies must disclose the use and emissions of hazardous substances, including Substances of Concern (SoC) and Substances of Very High Concern (SVHC).
ESPR and Digital Product Passport
Parallel to this, the ESPR introduces product-specific requirements, including the mandatory use of a Digital Product Passport, which must include chemical composition data, including SoCs as defined in Article 2(27).
Current Industry Challenge
Despite these obligations, there is currently no sector-specific list of SoCs for textile, leather and footwear manufacturing. Companies are left to interpret regulatory definitions independently, leading to inconsistencies and inefficiencies.
Development process
A structured, multi-step methodology ensuring both regulatory alignment and sectoral relevance.Step 1
Source aggregation
ZDHC compiled a Master List of 6,948 unique substances that meet the ESPR Article 2(27) criteria (points 1–3), drawing from multiple hazard-based sources, including:
ZDHC MRSL REACH SVHC Annexes XIV/XVII Regulation (EU) 2019/1021 (POPs) ChemSec SIN List GOTS RSL bluesign BSBL Oeko-Tex
Step 2
Relevance screening
To determine sectoral relevance, a filtering process was applied:
5,051
substances shared with Technical Expert Group for relevance screening
1,673
substances shared with Technical Expert Group for relevance screening
224
substances shared with Technical Expert Group for relevance screening
Step 3
Technical review and consensus
To determine sectoral relevance, a filtering process was applied:
The SoC Technical Expert Group, comprising representatives from various networks and associations, contributed individual input and coordinated feedback, which was synthesized to assess the relevance and validate the sector-specific applicability of substances not already flagged by existing RSLs.
Technical Expert Group
Dr Andreas Bayer (Chemical industry, Tegewa), Dr Pierfrancesco Fois (Dyes & pigments, ETAD), Assunta Tralongo (Adhesives & varnishes AVISA), Marcello Taglietti (Adhesives & varnishes, AVISA), Lisa Clerici (Brands, AFIRM), Dr Tony Yu (Textile industry CNTAC), Jerker Lieghart (NGO, Chemsec)
Step 4
Outcome
The result of this work is a provisional ZDHC Chemical Watch List containing approximately 2,000 substances relevant to the textile, leather, apparel and footwear industry, aligned with the ESPR SoC definition.
Around 5,000 substances still require review. Initial feedback from the TEG has been received on many of these, though differences of opinion remain for a subset, and additional information or clarification is needed in some cases.
Next steps
The Chemical Watch List is intended as a living document, updated regularly as new information becomes available and regulatory expectations evolve.
Pre-register for ZDHC Chemicals Watch List
ZDHC will publish the Chemical Watch List as a minimum viable reference product for stakeholders to use in their CSRD and ESPR preparations.
Ongoing Collaboration
The ZDHC SCM Competence Centre will keep working with the SoC Technical Expert Group to review remaining substances and resolve outstanding questions.
Regular Updates
Future updates to the list will be issued in a transparent, iterative process.