Golf Refugees are actively lobbying the EU to increase consumer awareness and devise new regulations for combination testing of the highly toxic chemicals used in sports apparel.

From the EU.

This is to reply to your follow-up e-mail of 20 May to our communication of 16 May 2013, where you have raised a number of additional questions as regards the protection and information of consumers about chemicals in textiles they are buying.

EU legislation includes several approaches to limiting quantity of these chemicals in textiles. For example, the REACH Regulation, Water Framework Directive (WFD), the Industrial Emissions Directive (IED) impose restrictions on the use of dangerous substances in textile products marketed in the EU or on the discharges and emissions of such substances to air, soil and water during the production of textiles products.
The implementation and/or enforcement of that legislation fall to Member State’s competent authorities.

Golf Refugees response.

From your statement it falls upon individual member states competent authorities to enforce existing EU legislation with regard to the level of toxic chemicals used in textiles marketed in the EU. Can you please provide a list of those EU member states competent authorities?  How are individual member states expected to enforce current EU legislation? Is there a staggered testing programme across EU member states for testing of textiles to make sure they are compliant with existing legislation? If yes, how often are individual member states expected to test for levels of toxic chemicals used in textiles; annually, bi-annually, every five years, ten years and where do they publish their results?

From the EU.

As regards to lead compounds being used in sports apparel, in addition to the numerous pieces of legislation already regulating them, in December 2012 a number of lead compounds have been identified under REACH as substances of very high concern.
The listing of these ‘very high concern substances' in the candidate list imposes obligations on suppliers of such substances (on their own or in mixtures) to provide their customers and recipients with safety data sheets. It also implies obligation on suppliers of articles containing the listed substances to provide recipients and consumers (the latter upon request) with information about the presence of the substances in articles.

Being aware of the importance and complexity of the issue of chemicals in textiles, the Commission is in the process of reviewing the existing legislative instruments and approaches used for addressing chemicals in textiles in order to consider whether they merit a revision.

Golf Refugees response.

With regard to toxic lead and other very highly toxic chemicals your statement states it falls upon the customer to request information from the supplier. An example could be a customer purchasing a golf shirt from a leading sportswear brand.

This raises a significant concern. How many consumers are aware sports brands use highly toxic chemicals such as lead in their apparel? If as we suspect the vast majority of consumers who buy sports apparel in the EU are unaware, and are unable to find out by simply looking at textile labels or on brands web sites. It is highly unlikely consumers are going to request this information from brands on the toxic substances they use.

Can we therefore request you to consider a voluntary scheme for brands to list the toxic chemicals they use in consumer goods on their web sites for customers to access?

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