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OEKO-TEX® Limit values: New regulations 2024

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Overview

This OEKO-TEX® Service GmbH customer-information notice, dated 09 January 2024, announces the OEKO-TEX® Association’s annual update of test criteria, limit values, and requirements across its certification labels for the 2024 cycle. The new limit values come into force on 01 April 2024 after a three-month transition period. The notice is not a contamination measurement study; it documents the textile- and leather-industry standard-setting body’s revised test catalogue. Heavy-metals content in the notice is concentrated in the STeP (Sustainable Textile/Leather Production) Annex 3 Group 11 update for wastewater and sludge testing, which lists per-metal concentration limit values and reporting limits for thirteen metals — antimony, arsenic, lead, cadmium, chromium (total), hexavalent chromium, cobalt, copper, nickel, mercury, zinc, manganese, and silver — in industrial textile- and leather-production discharge, and adds the requirement that the same metals be tested in sludge in addition to wastewater (as was the case in edition 01.2022). The remainder of the 2024 update concerns SVHC additions (diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide, bis(4-chlorophenyl) sulphone, 1,4-dioxane), PFAS scope changes (per- and polyfluoroalkyl substances grouped under PFCA-related and PFHxS-related sums, plus the replacement of extractable organic fluorine with total fluorine as the operative PFAS-ban metric), and minor adjustments for phenol, SCCP/MCCP, and glutaraldehyde — none of which concern heavy metals.

Key numbers

STeP Annex 3 Group 11 — wastewater limit values for heavy metals (p. 3–4)

The notice publishes the following per-metal wastewater concentration limit values and reporting limits for the OEKO-TEX® STeP certification. The MRSL (Manufacturing Restricted Substances List) column indicates whether the substance is included in the restricted list either unconditionally (X) or conditionally on the production process ((X)¹).

  • Antimony (Sb) — CAS 7440-36-0 et al. — MRSL: X — wastewater limit 100 µg/L, reporting limit 1 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Arsenic (As) — CAS 7440-38-2 et al. — MRSL: X — wastewater limit 50 µg/L, reporting limit 1 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Lead (Pb) — CAS 7439-92-1 et al. — MRSL: X — wastewater limit 100 µg/L, reporting limit 1 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Cadmium (Cd) — CAS 7440-43-9 et al. — MRSL: X — wastewater limit 100 µg/L, reporting limit 0.1 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Chromium total chromium (Cr) — CAS 7440-47-3 et al. — MRSL: (X)¹ — wastewater limit 200 µg/L, reporting limit 1 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Hexavalent chromium (Cr(VI)) — CAS 18540-29-9 et al. — MRSL: X — wastewater limit 50 µg/L, reporting limit 1 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Cobalt (Co) — CAS 7440-48-4 et al. — MRSL: (X)¹ — wastewater limit 50 µg/L, reporting limit 1 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Copper (Cu) — CAS 7440-50-8 et al. — MRSL: (X)¹ — wastewater limit 1,000 µg/L, reporting limit 1 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Nickel (Ni) — CAS 7440-02-0 et al. — MRSL: (X)¹ — wastewater limit 200 µg/L, reporting limit 1 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Mercury (Hg) — CAS 7439-97-6 et al. — MRSL: X — wastewater limit 10 µg/L, reporting limit 0.05 µg/L; sludge: testing required, reporting limit 0.2 mg/kg.
  • Zinc (Zn) — CAS 7440-66-6 et al. — MRSL: (X)¹ — wastewater limit 5,000 µg/L, reporting limit 5 µg/L; sludge: testing required, reporting limit 2 mg/kg.
  • Manganese (Mn) — CAS 7439-96-5 et al. — MRSL: (X)¹ — no wastewater limit value published (entry ”–”), reporting limit 1 µg/L; no sludge limit value (entry ”–”), reporting limit 2 mg/kg.
  • Silver (Ag) — CAS 7440-22-4 et al. — MRSL: X — wastewater limit 100 µg/L, reporting limit 1 µg/L; sludge: testing required, reporting limit 2 mg/kg.

The notice also states (p. 4) that “in addition to the testing of group 1, 7 and 12, also group ‘11. heavy metals and their compounds’ shall be tested in sludge (as it was in edition 01.2022)” — i.e., sludge testing for the Group 11 heavy metals is reinstated for the 2024 cycle.

Non-heavy-metal 2024 changes (recorded for context; not HMI-actionable)

The notice also publishes the following 2024 changes that do not concern heavy metals; recorded here for completeness because the document’s HMI relevance is bounded by what it does and does not change in the heavy-metals scope:

  • New SVHC additions to STANDARD 100, LEATHER STANDARD, ORGANIC COTTON, and ECO PASSPORT (p. 1): diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide (CAS 75980-60-8) at 1,000 mg/kg across all four labels; bis(4-chlorophenyl) sulphone (CAS 80-07-9) at 1,000 mg/kg across all four labels; 1,4-dioxane (CAS 123-91-1) at 10 mg/kg in STANDARD 100, LEATHER STANDARD, and ORGANIC COTTON and 100 mg/kg in ECO PASSPORT.
  • PFAS changes (p. 2): PFCA related substances sum limit of 260 µg/kg across all four labels; perfluorohexanesulfonic acid (PFHxS) related substances and salts sum limit of 25 µg/kg across all four labels. From 01.01.2024, total fluorine (TF) replaces the prior extractable organic fluorine (EOF) limit value for “a more effective ban of intentional use of PFAS”; the TF limit is set at 100 mg/kg for all product classes, with personal protective equipment (PPE) granted an exception to the total-fluorine content limit.
  • Other 2024 changes (p. 2): phenol limit value of 100 mg/kg added for all LEATHER STANDARD product classes; SCCP & MCCP sum limit value decreased to 50 mg/kg for all LEATHER STANDARD product classes; glutaraldehyde limit value removed from STANDARD 100 “as it was not relevant for samples tested under the STANDARD 100.”

Methods (brief)

The document is a customer-information notice publishing the OEKO-TEX Association’s revised test criteria for its certification labels. No primary analytical work is reported. The notice does not describe analytical instrumentation, sample preparation, digestion methods, reference materials, or quality-control procedures for the metals it lists; those operational details live in the underlying STANDARD 100, LEATHER STANDARD, ORGANIC COTTON, ECO PASSPORT, and STeP standards documents and in the OEKO-TEX test institutes’ internal procedures, which this customer notice points to but does not reproduce. The CAS-number assignments include the “et al.” qualifier on each entry, indicating that the limit values apply to the named element and its compounds collectively rather than to a single named species; this is consistent with how OEKO-TEX expresses elemental content/release limits across its certification labels. Speciation is reported separately only for chromium, where Cr (total) and Cr(VI) (hexavalent) carry distinct wastewater limit values (200 µg/L and 50 µg/L respectively). Mercury is reported as total Hg in wastewater without methylmercury speciation, consistent with industrial-wastewater regulatory practice. The notice is silent on arsenic speciation; the As(7440-38-2) entry covers arsenic and its compounds without distinguishing inorganic versus total or organic species.

Implications

  • Regulatory/industry-standard context (textile- and leather-derived children’s articles). OEKO-TEX certification is one of the principal industry-ecolabel standards covering textile and leather production; ECHA’s 2023 CMR-childcare-articles investigation report (echa2023-cmr-childcare-articles) lists OEKO-TEX alongside EU Ecolabel for textiles and shoes for children, GOTS, Blue Angel, Bluesign, and Nordic Swan as ecolabel-class standards consulted in deriving its proposed REACH Article 68(2) restriction scope. For HMI children’s-product categories that are textile- or leather-based (infant clothing, blankets and sleep sacks, bibs, fabric-contact products), this notice records the OEKO-TEX Association’s 2024 standard position on heavy metals in industrial wastewater and sludge from the production processes that produce those materials. The OEKO-TEX limits are not consumer-product contamination limits and do not substitute for the EU Toy Safety Directive (TSD), the REACH childcare-articles restriction process, the German Product Safety Act, or any government regulation; they are the certification-body limit values that audited textile and leather mills agree to meet to retain OEKO-TEX-certified status.

  • STeP wastewater/sludge metals scope (HMI-relevant). The STeP Annex 3 Group 11 list publishes per-metal wastewater concentration limit values for thirteen metals in textile/leather-production discharge and requires the same metals be tested in sludge. Of these thirteen, eight overlap the HMI ten-analyte vocabulary directly — Pb, Cd, total As (no speciation), Sb, total Cr, Cr(VI), Ni, and total Hg — while Co, Cu, Zn, Mn, and Ag fall outside the HMI Cochrane ten but inside the broader environmental-metals scope. The wastewater limit values are expressed in µg/L (production-effluent concentration), not in finished-product µg/kg, and so do not feed ingredient contamination_profile data. They are recorded here as a regulatory-context anchor for any future HMI work on the upstream supply-chain platform (textile mill, leather tannery, dye house) that produces children’s textile articles.

  • App. Not directly relevant to consumer-facing ingredient or product contamination data, because the notice publishes wastewater and sludge limits for industrial textile production, not finished-product contamination values. Relevant to a future supply-chain transparency surface that maps which industry-ecolabel certifications a textile-based children’s product carries and what each certification’s heavy-metals limit framework covers.

  • Courses. Suitable for a regulatory-context module covering the distinction between government regulations (TSD, REACH, CPSC), industry ecolabels (OEKO-TEX, GOTS, Blue Angel), and brand-private certifications. The 2024 update is also a worked example of the annual standard-setting cycle a certification body runs: new SVHCs are added when CAS-number-identified substances of concern accumulate, scope changes are made when the operative test metric is found insufficient (EOF replaced by total fluorine for PFAS), and limit values are removed when not relevant to the substrate class (glutaraldehyde withdrawn from STANDARD 100). Useful to brand-QA and regulatory-affairs audiences as a reference point for which heavy metals industry-standard certifications actually test for in textile/leather production discharge.

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