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Formaldehyde in Textiles: Limits by Market, and Why Two Labs Disagree

Formaldehyde in textiles by market: 75 mg/kg for EU clothing under REACH entry 72, the entry 77 emission limits that apply from 6 August 2026 and the textiles they reach, Japan, China, Korea, Vietnam, the EAEU, the US, Australia and India; why ISO 14184-1, ISO 14184-2 and Japan's test disagree; and what a finisher keeps on file.

Formaldehyde in textiles: limits by market, and why two labs disagree. EU clothing, skin-contact textiles and footwear: 75 mg/kg after 1 November 2020.

Formaldehyde in textiles is limited in two different quantities. Most rules cap what the fabric contains, in mg/kg: the EU has held clothing placed on the market after 1 November 2020 to 75 mg/kg (jackets, coats and upholstery 300 mg/kg until 1 November 2023) under REACH Annex XVII entry 72. Since 6 August 2026 the EU has also capped what an article releases into the air of a test chamber, in mg/m³, under entry 77, and entry 77 excludes every article that entry 72 covers.

The short version

  • EU clothing, skin-contact textiles and footwear: 75 mg/kg, measured in homogeneous material, for goods placed on the market after 1 November 2020. The 300 mg/kg allowed for jackets, coats and upholstery ended on 1 November 2023.
  • EU, other articles: since 6 August 2026, no more than 0.062 mg/m³ released from furniture and wood-based articles and 0.080 mg/m³ from other articles, in the chamber test of Appendix 14. Road-vehicle interiors follow at 0.062 mg/m³ from 6 August 2027.
  • Japan: for textiles for babies within 24 months of birth, a difference in absorption of not more than 0.05 in the prescribed test, or not more than 16 ppm (16 µg per gram); for underwear, nightclothes, gloves, hosiery and tabi, not more than 75 ppm.
  • China, South Korea and Vietnam: 75 mg/kg for clothing worn against the skin and 300 mg/kg for outer layers or no skin contact, with infant figures of 20, 20 and 30 mg/kg. Korea’s are read from its standards in force; China’s and Vietnam’s are as reported by laboratories and legal summaries; the matrix says which.
  • The United States has no federal limit. Australia publishes guidance figures, not a law. No mandatory limit was found for India.
  • Buyer lists: OEKO-TEX STANDARD 100 sets “n.d.”, 75, 150 and 300 mg/kg for product classes I to IV. ZDHC MRSL V4.0 (October 2026) limits free formaldehyde in the chemicals, not in the fabric: 1,000 mg/kg in formaldehyde-based formulations, 250 mg/kg in the rest.

Formaldehyde in textiles: limits by market

mg/kg, ppm and µg per gram are the same quantity. The last column says how firm each figure is: legal text means read in the rule itself for this page; official table or guidance, read in a government document that is not the rule; draft, read in a government draft, not the text in force; reported, given alike by laboratory or legal summaries while the official text could not be read; unconfirmed, a lead to check, not a figure to work to.

Market Rule Limit Applies from How firm
EU (content) REACH Annex XVII entry 72, added by Regulation (EU) 2018/1513 75 mg/kg in clothing and related accessories, in textiles other than clothing that touch the skin to an extent similar to clothing, and in footwear, for consumers. 300 mg/kg for jackets, coats and upholstery between 1 November 2020 and 1 November 2023 only After 1 November 2020 Legal text. The entry names no test method; the Commission’s explanatory guide to entry 72 lists EN ISO 14184-1:2011, with ISO 17226-1:2008 as a possible alternative
EU (emission) REACH Annex XVII entry 77, added by Regulation (EU) 2023/1464 Released under the test conditions of Appendix 14: 0.062 mg/m³ for furniture and wood-based articles; 0.080 mg/m³ for other articles. Road-vehicle interiors: 0.062 mg/m³ 6 August 2026; vehicles 6 August 2027 Legal text. Excludes articles that entry 72 applies to (next section)
Japan Act No. 112 of 1973 Textile products for babies within 24 months of birth (diapers, diaper covers, bibs, underwear, nightclothes, gloves, hosiery, intermediate wear, outer wear, headwear and bedding): a difference in absorption of not more than 0.05 in the prescribed test, or not more than 16 ppm. Underwear, nightclothes, gloves, hosiery and tabi: not more than 75 ppm, as for adhesives for wigs, artificial eyelashes, false moustaches or beards, and garters 1 October 1975; partly amended 1 April 2016 Legal text: the enforcement regulations’ Appendix Table 1, read in the e-Gov law database; the health ministry’s overview of the criteria of 1 April 2025 gives the same figures in English. What the 2016 amendment changed was not confirmed
China GB 18401-2010 (mandatory), with GB/T 2912.1 as its method Class A (infants) 20 mg/kg; B (direct skin contact) 75; C (no direct skin contact) 300. GB 31701-2015, for children’s products, is reported to use the same classes, method and infant figure 1 August 2011 (issued 14 January 2011); GB 31701-2015 from 1 June 2016 (reported) Legal text for the dates and the method. Reported for the limits: the standard’s own table was not read for this page. No revision of GB 18401 was found for 2023 to 2026, though one cannot be ruled out
South Korea Safety standards for infant textiles and for household textiles Infant textiles (under 36 months) 20 mg/kg; children’s textiles (36 months to 13 years) 75. Household textiles: underwear and mid-layer garments 75, outer wear and bedding 300. Method: KS K ISO 14184-1 Current annexes in force since 7 March 2024 Legal text: the KATS annexes for household, infant and children’s textiles, read in full
Vietnam QCVN 01:2017/BCT (Circular 21/2017/TT-BCT) Products for children under 36 months 30 mg/kg; in direct skin contact 75; not in direct skin contact 300 1 January 2019, postponed from 1 May 2018 by Circular 07/2018/TT-BCT (reported) Reported: three legal and compliance summaries agree; the official gazette refused scripted reads. Amendment 01:2026 (Circular 37/2026/TT-BCT, from 1 July 2026) is described in the one report found as procedural; whether it changes these figures is unconfirmed
Eurasian Economic Union TR CU 017/2011 (light-industry products), cited with TR CU 007/2011 (children’s products) 20 mg/kg for children’s products, 75 in direct skin contact, 300 without, as given by compliance firms 1 July 2012 (reported) Unconfirmed: the regulation’s own appendix was paywalled or empty when fetched. Which of the two regulations sets the children’s figure was not confirmed
United States No federal rule; GAO-10-875 None: the GAO found that “the United States does not legally limit formaldehyde levels in clothing” — Official report of 13 August 2010. No state textile limit was found for this page
Australia ACCC safety guidance, published by Product Safety Australia Not mandatory. “Indicative concentrations (under which there are not current safety concerns)”: 30 mg/kg for infants’ clothing and clothing marked for sensitive skin; 100 for garments which contact the skin; 300 for other garments or fabrics — Guidance. The skin-contact figure is 100 mg/kg, not the 75 sometimes quoted
India None found No figure. IS 14563 (Part 2):2021 is a method of test, identical to ISO 14184-2:2011; it sets no limit — None found for this page, which is not proof there is none. Check the current BIS Quality Control Orders before relying on it

Buyer lists

List Formaldehyde Status
OEKO-TEX STANDARD 100 (restricted substance list, version 03.2026) Class I (baby) “n.d.”; II (in direct contact with skin) 75 mg/kg; III (no direct contact with skin) 150; IV (decoration material) 300. “n.d.” is defined by the “Japanese Law 112” test: an absorbance below 0.05, or 16 mg/kg In force. OEKO-TEX’s notice of 3 March 2026 on the limits changing from 1 June 2026 does not list formaldehyde
ZDHC MRSL (V4.0, October 2026, group 1U) Free formaldehyde 1,000 mg/kg in formaldehyde-based formulations: those used for wrinkle and crease resistance, shrink proofing, dye retention, stain and water repellency and durability, such as fixing and dispersing agents, binders, resins and crosslinkers, and permanent flame-retardant finishing for cotton. 250 mg/kg in all other formulations. Method for textile formulations: HPLC after polymer precipitation and derivatisation with DNPH, or the TEGEWA-based method ZDHC suggests, which each laboratory must validate before use; ISO 27587:2021 for leather formulations, and ISO 27587 to arbitrate a dispute For the chemical formulation, not the fabric. Formulations certified to V3.1, which set no limit, may still be bought until 1 November 2027 and used up until 1 June 2028; after that InCheck shows only V4.0-certified chemicals as conformant. V4.0 certificates are issued from 1 February 2027

Two figures are easy to get wrong: OEKO-TEX’s Class III is 150 mg/kg, not 300, and ZDHC’s 250 mg/kg, new in MRSL V4.0, is for formulations that are not formaldehyde-based: formaldehyde-based ones may hold 1,000, and neither figure is a fabric limit.

REACH entry 77 since 6 August 2026: which textiles it reaches

Entry 77 restricts formaldehyde and formaldehyde-releasing substances in articles by what the article releases. Its list of exclusions includes, as clause (e), “articles for which the restriction laid down in entry 72 applies”. So the two entries do not stack: an article inside entry 72 answers to the 75 mg/kg content limit, not to the emission limit. Entry 72, in turn, reaches only clothing and related accessories, textiles other than clothing that “come into contact with human skin to an extent similar to clothing”, and footwear, and only “for use by consumers”. The text sorts textiles like this:

Textile article placed on the EU market Entry 72: 75 mg/kg in the material Entry 77: release in a test chamber
Clothing and related accessories, for consumers Yes, paragraph 1(a) No: clause (e)
Textiles other than clothing that touch the skin to an extent similar to clothing, for consumers Yes, paragraph 1(b) No: clause (e)
Footwear, for consumers Yes, paragraph 1(c) No: clause (e)
Disposable textiles of the 1(b) kind, “designed to be used only once or for a limited time” No: paragraph 5 Not excluded by clause (e); in scope unless another exclusion applies
Wall-to-wall carpets and textile floor coverings for indoor use, rugs and runners No: paragraph 3(d) Not excluded by clause (e); in scope unless another exclusion applies
Clothing and textiles exclusively for industrial or professional use No: entry 72 covers articles for consumers No, under clause (d), unless formaldehyde released from them “leads to exposure of the general public under foreseeable conditions of use”
Second-hand clothing and textiles No: paragraph 3(c) No: clause (j)
Textile personal protective equipment (Regulation (EU) 2016/425) No: paragraph 4 No: clause (h)
Textile medical devices (Regulation (EU) 2017/745) No: paragraph 4 No: clause (g)

Entry 77’s other exclusions cover articles exclusively for outdoor use, articles whose formaldehyde is exclusively naturally present, biocidal products, food-contact articles, and articles in constructions used outside the building shell and vapour barrier that do not emit into indoor air.

What the text does not settle. Neither legal text names curtains, mattresses or upholstered furniture; entry 72’s temporary derogation named only “upholstery”. The Commission’s explanatory guide to entry 72, guidance rather than law, counts upholstery (“fabric covering chairs, armchairs and sofas”) as covered, and lists curtains and “filling materials in chairs, armchairs and sofas” as not covered; it is silent on mattresses. Entry 77 does not say which textile products count as “furniture” (0.062 mg/m³) rather than “other articles” (0.080 mg/m³), and no Commission list mapping them was found for this page. A home-textile exporter should have the buyer’s answer in writing.

The test. Appendix 14 sets a chamber at 23 ± 0.5 °C and 45 ± 3% relative humidity, one air change an hour, and a loading of 1 m² of test piece per m³ of chamber, a figure that “corresponds to the testing of wood-based panels”; other products may use the loadings of EN 16516 section 4.2.2 where 1 m²/m³ is clearly not realistic. The air is sampled at least twice a day, at least 3 hours apart, until the concentration is steady, for no more than 28 days, and the steady-state value is compared with the limit. Road vehicles are measured in the vehicle interior, to ISO 12219-1 or ISO 12219-10. Neither entry gives a conversion between this mg/m³ figure and a mg/kg content result.

Why two laboratories report different numbers

A formaldehyde result can only be compared with another made by the same method. The ISO 14184 series has three parts, Japan prescribes its own test, and OEKO-TEX combines them. From each method’s published scope:

Method What it measures Lowest figure reported
ISO 14184-1:2011 Free formaldehyde and formaldehyde extracted partly through hydrolysis, by water extraction 16 mg/kg (range 16 to 3,500). Below that, “not detectable”
ISO 14184-2:2011 Formaldehyde released under the conditions of accelerated storage, by vapour absorption 20 mg/kg (range 20 to 3,500). Below that, “not detectable”
ISO 14184-3:2023 Free and hydrolysed formaldehyde by extraction, measured by liquid chromatography, which its scope calls “selective and not sensitive to coloured extracts” Not stated in the published scope
Japan, Act No. 112 The health ministry’s prescribed test. Prefectural testing centres describe it as water extraction with acetylacetone colour development under JIS L 1041 (a secondary source) The baby-product limit is written as a difference in absorption of 0.05, or as 16 ppm
OEKO-TEX STANDARD 100 Samples prepared to “Japanese Law 112 / JIS L 1041 – 2011 (using acetylacetone, method B) and DIN EN ISO 14184-1”, measured “by UV/VIS spectroscopy or LC-FLD” (its testing-methods document) Class I “n.d.”: an absorbance below 0.05, or 16 mg/kg

Read against each other, the scopes give five reasons two reports on one fabric can differ. This is our reading; none of the standards states why results differ.

  • Different fractions. Part 1 catches free formaldehyde plus what hydrolyses in water; Part 2 catches what is released under accelerated storage. They are different quantities. The two rules read here that name a method both name the water-extraction kind: China names GB/T 2912.1 for “free formaldehyde and hydrolyzed formaldehyde (hydro-extraction method)”, and Korea’s standards name KS K ISO 14184-1, its national version of Part 1. A Part 2 result does not answer either.
  • Different floors. “<16” or “not detectable” from Part 1 means below 16 mg/kg; “<20” from Part 2 means below 20. Neither means zero. An “n.d.” on an OEKO-TEX Class I report means below 0.05 absorbance or 16 mg/kg by the Japanese Law 112 test: the same number as Part 1’s floor, from a different test.
  • Different finish to the measurement. Part 3 measures the same fraction as Part 1 but ends in liquid chromatography, “intended to be used for precise quantification”. OEKO-TEX allows a UV/VIS reading after acetylacetone or LC-FLD. On a deep shade or a pigment print, ask which the laboratory used. An instrument maker’s application note (a secondary source) describes a check for colour readings: dimedone binds formaldehyde, so absorbance that disappears after it was formaldehyde, and absorbance that stays was interference.
  • Two ways to state Japan’s line. For baby products the limit is “not more than 0.05 according to a prescribed test or … not more than 16 ppm”. A Japanese report may give a difference in absorption, not mg/kg. Read it against 0.05.
  • Time. A chemical supplier’s comparison (a secondary source) says formaldehyde from DMDHEU resin “can be released during the textile finishing process, storage of the treated fabric, and during consumer use”. Record when each sample was cut and how the goods were stored before comparing two reports.

Before treating either report as wrong, ask both laboratories for the method, its part and edition, the reporting limit and the expanded uncertainty.

Reading one result against two limits

The GAO’s 2010 report notes that “some U.S. retailers have set internal corporate limits on formaldehyde in clothing”. An illustrative case with invented figures: a resin-finished cotton shirt for an EU buyer. The laboratory reports 64 mg/kg by water extraction (ISO 14184-1) with 20% expanded uncertainty, and the buyer’s own limit for the next season is 50 mg/kg. In the restricted substance limit calculator, put the EU’s 75 in the limit field and the buyer’s 50 in the later-limit field:

  • The result runs from 51.2 to 76.8 mg/kg. The number is 11 under 75, but the upper bound is over it, so the result is not conclusively below the EU limit.
  • With a guard band of one expanded uncertainty (12.8 mg/kg), the acceptance limit is 62.2 mg/kg. The result is 1.8 mg/kg past it: on that decision rule the lot is not accepted.
  • Against the buyer’s 50 it is 14 mg/kg over, and even the lower bound, 51.2, is above 50. It fails that figure whatever the uncertainty.
  • To clear 50 on the same rule, the result has to come in at 41.6 mg/kg or less (41.6 plus 20% is 49.92), if the laboratory’s 20% holds at that level.

On a guard-banded rule, a result under the limit is not yet a pass. The guard band is a laboratory convention that none of these rules sets, and a buyer may set its own decision rule; agree it before the order, not after the report. Open the calculator with these figures.

Where formaldehyde comes from in a finishing house

ZDHC’s own list names the sources. MRSL V4.0 (group 1U) says “certain formulations such as easy-care or wrinkle-free resins require the use of formaldehyde in their manufacturing”, gives fixing agents, dispersing agents, binders, resins and crosslinkers the higher 1,000 mg/kg limit, and warns that a conformant formulation “if not applied as per formulators instructions, may give rise to Released-Formaldehyde in the final article”.

Source What the sources say How firm
Crease-resistant, easy-care and non-iron resins ZDHC names “easy-care or wrinkle-free resins” as needing formaldehyde and allows them 1,000 mg/kg of free formaldehyde. A chemical supplier’s comparison calls DMDHEU (dimethylol dihydroxyethylene urea) “a representative formaldehyde-releasing agent” in durable-press finishing ZDHC: primary. DMDHEU: secondary
Release after finishing The same comparison: release continues in storage and use, and the amount depends on “the finishing process parameters and the pH of the environment” Secondary
Fixatives, binders and other auxiliaries ZDHC names fixing agents, dispersing agents and binders among the formulations allowed 1,000 mg/kg. An instrument maker’s application note says formaldehyde “is added to auxiliaries in order to maintain the durability of printing and dyeing and improve the handfeel”. Neither names products ZDHC: primary. Note: secondary

Lower-formaldehyde options

For crease resistance, the alternatives the sources name are polycarboxylic acids: BTCA (1,2,3,4-butanetetracarboxylic acid) and citric acid. They crosslink cellulose through ester bonds and do not release formaldehyde. The trade-offs the same supplier’s comparison reports: DMDHEU gives better wrinkle recovery but a greater loss of fabric strength; citric acid can yellow at high curing temperatures and may need a catalyst such as sodium hypophosphite; BTCA’s safety data sheet warns of serious eye damage. These are secondary sources, not trials: run a trial on your own fabric before changing a recipe. For fixatives and binders, the sources read for this page name no lower-formaldehyde product, so ask each supplier for the formaldehyde content of the formulation.

What a finisher keeps on file

  • Formulation declarations. For every resin, catalyst, fixative, binder and print auxiliary: the supplier’s figure for formaldehyde in the formulation, and the method behind it. Record it as free formaldehyde against ZDHC MRSL V4.0: 1,000 mg/kg for formaldehyde-based formulations, 250 mg/kg for the rest.
  • The recipe and cure for each lot: the product, add-on, catalyst, cure temperature and time, and bath pH, since release depends on process parameters and pH.
  • Test reports per lot that name the method, its part and edition, the reporting limit, the expanded uncertainty and the date the sample was cut.
  • For Japan, the result in the ministry’s prescribed test; for baby products, as a difference in absorption or in ppm. For an OEKO-TEX Class I article, the basis of the “n.d.”.
  • For deep shades and pigment prints, whether the laboratory used ISO 14184-3 or checked a colour reading.
  • For EU home textiles and furniture placed on the market from 6 August 2026, which entry the buyer applies and, under entry 77, a chamber report to Appendix 14 that states the loading factor used.
  • For the United States, the buyer’s own limit and method, since no federal one applies. AATCC TM112, the “sealed jar method”, is described in a secondary source as measuring formaldehyde released under accelerated storage: the same kind of figure as ISO 14184-2, not a water-extraction content.

Questions finishers ask

Does REACH entry 77 apply to garments?

Not to garments that entry 72 covers. Clause (e) excludes “articles for which the restriction laid down in entry 72 applies”, and entry 72 covers clothing, related accessories, clothing-like skin-contact textiles and footwear for consumers. Those stay at 75 mg/kg.

Is ZDHC’s 250 mg/kg in force?

It is in the list now, for the chemical formulation, not the fabric. ZDHC MRSL V4.0, launched on 29 October 2026, sets free formaldehyde at 250 mg/kg for most formulations and 1,000 mg/kg for formaldehyde-based ones, such as crease-resistant resins, fixing agents and binders. Formulators recertify to V4.0 between 1 February and 1 November 2027. Formulations certified to V3.1, which set no limit, may still be bought until 1 November 2027 and used up until 1 June 2028; after that InCheck shows only V4.0-certified chemicals as conformant.

How this page is kept

Last verified: 3 October 2026; the ZDHC figures and entry 72’s date and method on 31 October 2026. Built from the consolidated REACH text of 22 June 2026 (entries 72 and 77, Appendices 12 and 14) and Regulations (EU) 2018/1513 and 2023/1464; the Japanese health ministry’s overview of 1 April 2025; GB 18401-2010’s front matter; Korea’s KATS annexes in force since 7 March 2024; GAO-10-875; the ACCC guidance; the BIS record for IS 14563 (Part 2); the published scopes of ISO 14184-1, -2 and -3; OEKO-TEX’s restricted substance list, 2026 notice and testing-methods document; the Commission’s explanatory guide to entry 72; and ZDHC MRSL V4.0 and V3.1. China’s limits, Vietnam’s and the EAEU’s are reported or unconfirmed, as the matrix marks them, and the finishing chemistry rests on secondary sources, marked where used. The REACH record in this site's regulation register carries the instrument. This page describes what each rule says; it is not legal advice for a particular product or shipment. Corrections are welcome through the contact page.

More on restricted substances: Banned azo dyes: amine limits, dates and tests by market; PFAS in textiles: limits and dates by market.

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