INDEX

INDEX

INDEX
I DEFINITION OF clear to wear..............19
II REFERENCE MANUAL:
SUBSTANCES OF LEGALLY LIMITED USE
Formaldehyde ...23
Arylamines ...........25
Phenols: Pentachlorophenol (PCP) and Tetrachlorophenol (TeCP).....................27
Cadmium ..........28
Lead ......30
Mercury ............32
Chromium..................33
Chromium (VI) ......34
Nickel ....35
Phthalates .36
Polybrominated Flame Retardants...........37
Pesticides .38
Short Chain Chlorinated Paraffins ..........39
Perfluorooctane Sulfonates (PFOS)..............40
Dimethyl Fumarate .......41
Organotin Compounds..........42
Allergenic Dyes.....43
II REFERENCE MANUAL:
SUBSTANCES OF LIMITED USE
Organochlorinated Compounds.....47
Isocyanates....46
III LEGALLY LIMITED PARAMETERS:
pH ......53
Composition Tolerance..................54
Colour Fastness in Water......55
Colour Fastness to Perspiration....56
Colour Fastness on Rubbing.........57
Colour Fastness to Saliva......58
IV OTHER EU REGULATIONS OF MANDATORY COMPLIANCE:
REACH........63

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INDEX

ANNEX I:
SUMMARY TABLE clear to wear...............67
ANNEX II:
List of Controlled Individual Substances................................73
ANNEX III:
Commitment to Comply with the Inditex groups Clear To Wear Product Health Standards...............79

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15

I DEFINITION OF
clear to wear

I DEFINITION OF clear to wear

I DEFINITION OF clear to wear

clear to wear is defined as a product health Standard:
has been developed by Inditex in conformity with the most stringent legislation on product health and safety. In addition to the composition, pH and colour fastness.
regulates those substances whose use is legally limited and which, if present in the product above certain
levels, could be hazardous for human health, such as: Formaldehyde, Arylamines, Phenols (PCP and TeCP),
Cadmium, Lead, Mercury, Chromium, Chromium (VI), Nickel, Phthalates, Polybrominated Flame Retardants,
Pesticides, Short Chain Chlorinated Paraffins, Perfluorooctane Sulfonates (PFOS), Dimethyl Fumarate, Organotin Compounds and Allergenic Dyes,
additionally, clear to wear sets limits to the use of two parameters not contemplated by the legislation in effect: Organochlorinated Compounds and Isocyanates,
finally, clear to wear includes REACH as the EU regulation of mandatory compliance for all Inditex suppliers.

clear to wear is of general and mandatory application for all clothing products, footwear, accessories and/or fabrics supplied to Inditex.

The Supplier is the only party responsible for the compliance of the products supplied to Inditex with clear to

wear.

Finally, and regardless of the commitment accepted by the Supplier to control the parameters regulated in clear
to wear, Inditex will verify its correct implementation at any phase of the manufacturing process of those products
that are manufactured, commercialized and/or distributed by it, by carrying out Routine and Random Sample
analyses on determined Models/Quality at any point of their production cycle.

clear to wear is applied through the following 10 families of products, which are defined according to

article type, degree of contact with the skin and age of the end user:
- Products for users younger than 3 years old (babies)
- Clothing in direct and prolonged contact with the skin.
- Clothing not directly in contact with the skin.
- Parts of footwear in direct and prolonged contact with the skin.
- Parts of footwear not directly in contact with the skin.
- Accessories in direct and prolonged contact with the skin.
- Accessories not directly in contact with the skin.
- Metallic-only accesories.
- Home textiles in direct and prolonged contact with the skin.
- Home textiles not directly in contact with the skin.

This Referece Manual is a free translation from the Spanish Version.

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II REFERENCE
MANUAL:
SUBSTANCES OF
LEGALLY LIMITED
USE.

This Referece Manual is a free translation from the Spanish Version.

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

FORMALDEHYDE (1/2)
1. What is it?
Formaldehyde (CAS No. 50-00-0) is a volatile chemical widely used in the textile and leather industries as: (1) preservative for vegetable and animal raw materials; (2) anti-wrinkling and anti-shrinking agent for cotton products;
(3) dyeing and printing fixative, and (4) leather tanning agent.

2. Where can it be found?

Formaldehyde can be found in many textile and leather products, due to its presence in the composition of a
variety of chemical auxiliaries used in the textile and leather industries, such as:
a) Fixing agents for direct and reactive dyes in cellulose fibers.
b) Anti-wrinkle and anti-shrinking resins used in the finishing processes in cotton products.
c) Resins used in permanent wrinkles in textile articles made of cellulose fibers, mainly in jeans.
d) Heat transfer adhesives used as binders in dye printing.
e) Heat transfer adhesives used in several types of printing processes, such as flock and foil, among others.
f) Reducing agent present in printing by corrosion (rongeant) (Zinc Formaldehyde-Sulfonate)
g) Resins and/or binding agents in some special finishes and/or coatings.
h) Products for tanning and softening of leather.
i) Anti-microbial agents in pastes used in water-based positional printing, and
j) Preservatives for vegetable and animal raw materials.

3. How is it regulated?
Japanese Legislation1: Guide to the Law for the Control of Household Products Containing Harmful Substances, enacted in 1975.
Standard of mandatory use in the Russian Federation2: Textile- Maximum Allowable Concentrations of Free
Formaldehyde, enacted in 1996.
Norwegian Regulation3: Regulations Relating to Restrictions on the Manufacture, Import, Export, Sale and
Use of Chemicals and Other Products Hazardous to Health and the Environment (Product Regulations),
enacted in 2004.
Standard and code of mandatory use in the Peoples Republic of China4: National General Safety Technical
Code for Textile Products GB 18401-2003, enacted in 2005 and National Standard of the P.R.C., Leather
and Fur-Limit of Harmful Matter GB 20400-20065, enacted in 2006.

Limits: No detection (0.05 (A-A0) spectrophotometric absorption- or 16 ppm) for textile products aimed at users younger than 2
years old, and 75 ppm for underwear, sleepwear, gloves and socks.

Limits: No detection for textile products aimed at users younger than 1 year old; 75 ppm for textiles for underwear and bed linen;
300 ppm for textiles for shirts and a like; and 1000 ppm for textiles for coats, pant suits and a like, mainly.

Limits: 30 ppm for textile products aimed at users younger than 2 years old; 100 ppm for textiles that are usually in contact with
the skin, 300 ppm for textiles that are not usually in contact with the skin. Additionally, if the labels indicate that the clothes should
be washed before use, the indicated limits will apply to the items after washing, following the instructions marked by the preservation symbols in the label.

Limits: 20 ppm for textile products aimed at users younger than 2 years old; 75 ppm for textile products in direct contact with the
skin, and 300 ppm for textile products with no direct contact with the skin, mainly for ornamental use.

Limits: 20 ppm for textile products aimed at users younger than 2 years old; 75 ppm for textile products in direct contact with the
skin, and 300 ppm for leather products with no direct contact with the skin, mainly for ornamental use.

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

FORMALDEHYDE (2/2)
Finnish Decree6: Decree on Maximum Amounts of Formaldehyde in Certain Textile Products (210/1988),
enacted in 1988.
Polish Regulation7: ROZPORZ_DZENIE RADY MINISTRW z dnia 19 pa_dziernika 2001 r. w sprawie
bezpiecze_stwa i znakowania produktw w_kienniczych. (Dz. U. z dnia 17 grudnia 2001 r.) (Regulation on
Safety and Textile Marking), enacted in 2001.
Lithuanian Regulation8: Hygiene Norm HN 96:2000 (Hygiene Standards and Regulations), enacted in 2000.

4. How is it analyzed?
Textiles: Japanese Norm: JIS L 1041 1983 and/or ISO/EN Norm 14184.
Leather: Norm ISO/TS 17226: 2008. This Norm offers two methods of analysis: ISO/TS 17226-1:2008 and
ISO/TS 17226-2:2008. Method ISO/TS 17226-2:2008 is not selective, and thus compounds other than Formaldehyde can interfere with the analysis, therefore the method of analysis must be selected carefully.
By using the Standard Operational Procedures9: SOP-A-011 Ed.1 and SOP-A-012 Ed.2.

5. Which are the acceptable limits?

No detection for textile, fur and leather products for children younger than 3 years old.
Maximum 75 ppm for textile, fur and leather products in direct and prolonged contact with the skin, aimed
at customers older than 3 years old (clothing, accessories, footwear, and home textiles mainly)
Maximum 300 ppm for textile, fur and leather products in no direct or prolonged contact with the skin,
aimed at customers older than 3 years old (clothing, accessories, footwear, and home textiles mainly)

6. How can it be avoided?

The presence of Formaldehyde, above the levels indicated in point 5 can be prevented:
a) By obtaining from our suppliers of chemicals the commitment and guarantee that all the products supplied
to be used in the manufacturing process are Formaldehyde-free.10
b) In those cases where its use is unavoidable, by following the instructions for its use provided by the supplier, so as to comply with the minimum requirements established in clear to wear.
c) By washing the clothing items after the printing by corrosion process has been carried out, so as to completely remove any Formaldehyde residue.

Limits: 30 ppm for textile products aimed at users younger than 2 years old, 100 ppm for textiles that are usually in contact with
the skin, and 300 ppm for textile products that are not usually in contact with the skin (including decorative textiles)

Limits: 20 ppm for textile products aimed at users younger than 3 years old; 150 ppm for textile products in direct contact with the
skin; 300 ppm for textile products that are not usually in contact with the skin and 500 ppm for decorative products.

Limits: 20 ppm for textile products aimed at users younger than 2 years old; 75 ppm for textiles that are usually in contact with the
skin and 300 ppm for textile products with no direct contact with the skin.

These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances.

10 Nowadays the producers of chemicals for the textile industry, such as resins, fixing agents and catalysts, have interesting (in price
and properties) alternatives for substituting Formaldehyde containing products.

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

ARYLAMINES (1/2)
1. What are they?
Arylamines are chemical substances, harmful for human health, that can be part of the structure of some dyes
Azo Dyes and which, under certain conditions, can be released from them and absorbed by the human body
through the action of sweat and/or spit.

2. Where can they be found?

Arylamines can be present in colored and printed textile and leather products.
Particularly, there is a high risk of finding Arylamines in dyestuff11, such as: (1) direct dyes for cellulose fibers in
very intense red, bright scarlet and/or black shades; (2) dyes for animal fibers and polyamides in red and bright
scarlet shades, and (3) prints containing the aforementioned shades.

3. How are they regulated?

European Directive12: 76/769/EEC and 2003/3/EC, enacted in 2003.
Spanish Royal Decree13: 1406/1989, of November 10th, which imposes limits for the commercialization
and uses of certain dangerous substances. BOE no. 278 of November 20th, enacted in 2003, and its
latest modification: 1114/2006 of September 29th.
Standard and code of mandatory use in the Peoples Republic of China14: GB 18401-2003 National
General Safety Technical Code for Textile Products, enacted in 2005 and: National Standard of the
P.R.C., Leather and Fur - Limit of Harmful Matter GB 20400-2006, enacted in 2006.
Turkish decree15: Communique on Audit of Certain Textile and Clothing Products (Import: 2009/22),
enacted in 2009.

4. How are they analyzed?

Textiles: Norm UNE-EN 14362-1(2003) for natural fibers and 14362-2 (2003) for synthetic fibers.
Leather: Norm ISO/TS 17234: 2003.
If the presence of aniline and/or 1,4-phenylenediamine has been detected, the corresponding analysis must be
repeated using method LFBG B82.02-9 to confirm the presence of aminoazobenzene.
By the use of the Standard Operational Procedures16: SOP-A-005 Ed.2 and SOP-A-007 Ed.2.

5. Which are the acceptable limits?

Maximum 20 ppm for textile products (clothing, footwear, accessories and home textiles)
Maximum 30 ppm for leather products (clothing, footwear, accessories and home textiles)

11 A list with those dyestuff which can release Arylamines can be found in Annex II. List of controlled individual substances in Forbidden Dyes section (pages 74 and 75)
12 Limits: 30 ppm for textile and leather products in direct and prolonged contact with the skin or products that can be inserted in the
mouth.
13 Limits: 30 ppm ppm for textile and leather products in direct and prolonged contact with the skin or products that can be inserted
in the mouth.
14 Limits: 20 ppm for textile products in general and 30 ppm for leather products in general.
15 It is forbidden to import textile, leather, and ready to wear products manufactured using the substances included as Forbidden
Dyes in Annex II.List of Controlled Individual Substances (pages 74 and 75)
16 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

ARYLAMINES (2/2)
6. How can they be avoided?
The presence of Arylamines, above the levels indicated in point 5, can be avoided by applying the following
preventive measures:
a) By obtaining from our suppliers the commitment that the dyes and pigments they supply will not give
off this type of substances Arylamines17 at any stage of the production process, according to the limits
established in point 5.
b) By using only dyes and/or pigments made by internationally reputed suppliers, who show public commitments and compliance with the most stringent product health laws for all the dyes and pigments they
market.18

17 See Annex II: List of Controlled Individual Substances (pages 73, 74, 75 and 76)
18 Information about this can be obtained from ETAD Ecological Toxicological Association of Dyestuffs (www.etad.com)

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

PHENOLS: PENTACHLOROPHENOL (PCP) AND TETRACHLOROPHENOL (TeCP)

1. What are they?
Phenols PCP (CAS No.: 87-86-5) and TeCP (CAS No.: 25167-83-3) are polychlorinated compounds that act as:
(1) preservatives for vegetable and animal raw materials and (2) insecticides.

2. Where can they be found?

PCP and TeCP can be found in fungicides used for textile and leather products and wood (unprocessed textiles
and/or leather are the items that present a higher risk of containing these substances)

3. How are they regulated?

Swiss Ordinance19: Ordinance on the Reduction of Risks linked to Chemical Products (ORRChim) (Verordnung vom 18. Mai 2005 zur Reduktion von Risiken beim Umgang mit bestimmten besonders gefhrlichen
Stoffen, Zubereitungen und Gegenstnden (Chemikalien-Risikoreduktions-Verordnung, ChemRRV), enacted
in 2005.
Polish Regulation20: ROZPORZ_DZENIE RADY MINISTRW z dnia 19 pa_dziernika 2001 r. w sprawie bezpiecze_stwa i znakowania produktw w_kienniczych. (Dz. U. z dnia 17 grudnia 2001 r.) (Regulation on safety
and textile marking), enacted in 2001.
South Korean Law21: Safety Confirmation Notice (Notice No. 2007-34) Annex 4, enacted in 2007.

4. How are they analized?

Textiles: By Chromatographic Methods and/or German Method 64 LFGB BVL B 82.02.8.
Leather: Norm ISO/TS 17070:2006.
By the use of the Standard Operational Procedures22: SOP-A-009 Ed.1 and SOP-A-010 Ed.2.

5. Which is the acceptable limit?

No detection for all textile and leather/fur products (clothing, accessories, footwear, and home textiles
mainly)

6. How can they be avoided?

The presence of PCP and TeCP, above the levels indicated in point 5, can be avoided by applying the following
preventive measures:
a) By obtaining from our suppliers the commitment that the chemicals they supply: (1) will not contain PCP
nor TeCP, nor their respective salts, (2) that these chemicals will not be transferred to the final product at any
stage of the production process.
b) By avoiding contamination in the leather processing due to the use of drums in which Phenols are used.23

19 Limits: PCP, TeCP, any of their derived salts, and compounds of pentachlorophenoxide and/or tetrachlorophenoxide are forbidden
in textile and leather products.
20 Limits: PCP is forbidden in textile products used in direct and prolonged contact with the skin and/or in products that can be introduced in the mouth.
21 Limits: 0.05 ppm for PCP and TeCP, including their salts, in textile products for babies; 0.5 ppm for PCP and TeCP, including their
salts, in underwear, and 5 ppm PCP and TeCP, including their salts, in bed linen.
22 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.
23 Wood has the tendency to absorb the products used on it and liberate them afterwards.

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

CADMIUM (1/2)
1. What is it?
Cadmium (CAS No.: 7440-43-9) is a heavy metal that is used as: (1) pigment in plastic materials; (2) ultraviolet
stabilizing agent to avoid degradation of plastics; and (3) brightening and antioxidizing agent for metallic accessories.

2. Where can it be found?

Cadmium can be found in a great variety of textile and leather/fur products due to its presence in the composition
of several chemicals used in the textile and leather industries, such as:
a) Stabilizers for plastic materials, such as: Polyvinyl Chloride (PVC), Polyurethane and Polyethylene.
b) Pigments used in dyes, prints and tinctures for plastics (pigments with a higher probability of containing
Cadmium are those of red, orange, yellow or green colors)
c) Cadmium coatings in metallic accessories.

3. How is it regulated?
Swiss Ordinance24: Ordinance on the Reduction of the Risks linked to the Use of Particularly Dangerous
Substances, Preparations and Objects (Ordinance on the Reduction of Risks linked to Chemical Products
(ORRChim)) Draft for consultation of The Swiss Federal Council), enacted in 2005.
Polish Regulation25: ROZPORZ_DZENIE RADY MINISTRW z dnia 19 pa_dziernika 2001 r. w sprawie
bezpiecze_stwa i znakowania produktw w_kienniczych. (Dz. U. z dnia 17 grudnia 2001 r.) (Regulation on
safety and textile marking) and The Ordinance of the Council for Ministers on Safety and Labelling of Textile
Products of 19 October 2001 enacted in 2001.
Swedish Ordinance26: Section 3 of the Ordinance (1998:944) on Prohibitions Etc. in Connection with Handling, Importing and Exporting Chemical Products, enacted in 1998.
Austrian Ordinance27: Ordinance of February 18th, 1994 on Bans and Restrictions of Cadmium and its Compounds, Including White Lead, Federal Law Gazette No 855/1993 enacted in 1992.
Decree of the Netherlands28: Cadmium Decree 1999 (Chemical Substances Act) enacted in 1999.
Danish Statutory Ordinance29: Statutory Order No.1199 of December 23th, 1992 on the Prohibition of Sale,
Import and Manufacture of Cadmium Containing Products, enacted in 1992.

24 Limits: Its use for metals employed in plating is forbidden. 100 ppm for products and accessories made from Cadmium-containing
plastics; 250 ppm for metals that use Zinc as plating; 100 ppm for paints and varnishes and painted or varnished products and
accessories.
25 Limits: Forbidden for products that are in direct and prolonged contact with the skin or that can be introduced in the mouth. 100
ppm for colored plastic products and accessories; 100 ppm for stabilized PVC; 100 ppm in paints (except paints with a high Zinc
content, in which case the limit is 1,000 ppm)
26 Limits: Forbidden for any products that contains Cadmium as a dye, pigment, stabilizer and or galvanizer.
27 Limits: 100 ppm for all products in which Cadmium has been used as pigment and/or stabilizer, among other functions; 100 ppm
for paints (except in those paints with a high Zinc content, in which case the limit is 1,000 ppm), and 250 ppm for metals used in
Cadmium plating.
28 Limits: 100 ppm for any products that contain Cadmium as a dye, pigment, stabilizer and/or galvanizer.
29 Limits: 75 ppm for all products, and their parts, for which Cadmium had been used as surface-treating agent or as a pigment in the
dyeing or stabilization of plastics.

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

CADMIUM (2/2)
4. How is it analyzed?
Textiles, Leather, Plastic and Metals: the Total Cadmium amount is determined following analytical procedures that include microwave digestion with HNO3/H2O2, followed by quantification by Inductively Coupled
Plasma-Mass Spectrometry (ICP-MS)
By the use of the Standard Operational Procedures30: SOP-A-001 Ed.3 and SOP-A-002 Ed.3.

5. Which are the acceptable limits?

Maximum 1 ppm for textile and leather products (clothing, footwear, accessories and home textiles,
mainly)
Maximum 75 ppm for metallic and plastic parts (clothing, footwear, accessories and home textiles, mainly)
Maximum 75 ppm for surface paints and coatings (metallic and plastic parts and accessories in clothing,
footwear, accessories and home textiles, mainly)

6. How can it be avoided?

The presence of Cadmium, above the levels indicated in point 5, can be avoided by:
a) Not using Cadmium as a plastic stabilizer or as a brightening agent for metals.
b) Obtaining from our suppliers of dyes and pigments the commitment and guarantee that the dyes and pigments supplied do not contain Cadmium above the levels indicated in point 5 above.
c) By using only dyes and/or pigments made by internationally reputed suppliers, who show public commitments and compliance with the most stringent product health laws for all those dyes and pigments they
market.31

30 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.
31 Information about this can be obtained from ETAD Ecological Toxicological Association of Dyestuffs (www.etad.com)

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LEAD (1/2)
1. What is it?
Lead (CAS No.: 7439-92-1) is a heavy metal that is used as: (1) metal; (2) alloy for the production of accessories; and (3) pigment.

2. Where can it be found?

Lead can be found in a great variety of textile and leather/fur products, such as: a) accessories and/or parts made
from metals or alloys, and b) some components of a variety of chemicals used in the textile and leather industries, such as: pigments used in paints, prints and plastics, among others (pigments with a higher probability of
containing Lead are those of red, orange, yellow or green colors)

3. How is it regulated?
Swiss Ordinance32: Ordinance on the Reduction of the Risks linked to the Use of Particularly Dangerous
Substances, Preparations and Objects (Ordinance on the Reduction of Risks linked to Chemical Products
(ORRChim) Draft for consultation of The Swiss Federal Council), enacted in 2005.
Danish Statutory Ordinance33: Statutory Order no. 1042 of 1997 (as amended) and Statutory Order no. 1082
of 2007 on Prohibition, Import and Sale of Products Containing Lead, enacted in 2007.
United States Act34: Consumer Product Safety Improvement Act (CPSIA), enacted in 2008.
California Law35: The Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65), enacted in
1986.
Polish Regulation36: The Ordinance of the Council for Ministers on Safety and Labelling of Textile Products
of October 19th 2001 enacted in 2001.

4. How is it analyzed?
Textiles, Leather, Plastic and Metals: the Total Lead amount is determined following analytical procedures that include microwave digestion with HNO3/H2O2, followed by quantification by Inductively Coupled
Plasma-Mass Spectrometry (ICP-MS)
Paints and Surface Coatings: ASTM Method E1645 & E1613.
By the use of the Standard Operational Procedures37: SOP-A-001 Ed.3 and SOP-A-002 Ed.3.

32 Limits: 100 ppm for paints and varnishes and painted or varnished products and accessories, mainly.
33 Limits: Forbidden for any Lead-containing product.
34 Limits: 600 ppm (300 ppm since August 14th 2009 and 100 ppm since August 14th 2011) for Lead in substrates and 600 ppm (90
ppm since August 14th 2009) for Lead in paints and surface coatings.
35 Limits: 30 ppm for Lead in clothing made with PVC (including gloves), Neoprene and/or plastic materials and rainwear; 200 ppm
for Lead in Non-fabric component (zippers, drawstrings, snaps, buttons, among others); 90 ppm for Lead in PVC in personal carrying products (bags, purses, among others), 100 ppm for Lead in any other fabric than PVC in personal carrying products (bags,
purses, among others); 90 ppm for Lead in exterior surface coating in personal carrying products (bags, purses, among others);
90 ppm for Lead in leather in personal carrying products (bags, purses, among others); and 300 ppm for other materials (except
ZIrconia, glass or rhinestone) in personal carrying products (bags, purses, among others)
36 Limits: Forbidden for products that are in direct and prolonged contact with the skin or that can be introduced in the mouth.
37 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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LEAD (2/2)
5. Which are the acceptable limits?
1) Maximum 100 ppm for textile products without direct contact with the skin and aimed at customers older
than 3 years old; metallic and plastic elements (parts, accessories, imitation leather, plastic coatings for fur
and leather and positional prints, mainly)
2) Maximum 90 ppm for all painted materials and those with surface coatings: metals, plastics, wood, raffia,
among other (clothing, footwear, accessories and home textiles, mainly)
3) Maximum 1ppm for all textile and leather products aimed at children younger than 3 years old, and for
textile and leather products in direct and prolonged contact with the skin aimed at customers older than 3
years old (clothing, footwear, accessories and home textiles, mainly)
4) Maximum 30 ppm for clothing made with PVC, Neoprene and other plastic materials.

6. How can it be avoided?

The presence of Lead, above the levels indicated in point 5, can be avoided by:
a) Not using Lead as a base metal or any of its alloys.
b) Obtaining from our suppliers of dyes and pigments the commitment and guarantee that the dyes and pigments supplied do not contain Lead above the levels indicated in point 5 above.
c) By using only dyes and/or pigments made by internationally reputed suppliers, who show public commitments and compliance with the most stringent product health laws for all those dyes and pigments they
market.38

38 Information about this can be obtained from ETAD Ecological Toxicological Association of Dyestuffs (www.etad.com)

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MERCURY.
1. What is it?
Mercury (CAS No.: 7439-97-6) is a heavy metal that can be found in the solid, liquid or gas states (in organic or
inorganic compounds)

2. Where can it be found?

Mercury can be found in textile and leather/fur products in general.
The main causes for the presence of Mercury are:
a) Contamination during the production of sodium hydroxide and/or sodium chloride using the Mercury-cell
process.
b) Contamination during the extrusion of polymers.
c) Its use as a preservative.
d) Contamination from the water used during the processing of textiles and leather.

3. How is it regulated?
Japanese Law39: Law for the Control of Household Products containing Harmful Substances, enacted in
1975.
Polish Ordinance40 Safety and Labelling of Textile Products October 19th 2001, enacted in 2001.
Swiss Ordinance41 Ordinance on Risk Reduction related to Chemical Products (ORRChim) of May 18th 2005
as amended, beyond the EU Restrictions of the Directive 76/769/EEC, 89/101/EC enacted in 2005.

4. How is it analyzed?
Textiles, Leather, Plastic and Metals: the Total Mercury amount is determined following analytical procedures that include microwave digestion with HNO3/H2O2, followed by quantification by Inductively Coupled
Plasma-Mass Spectrometry (ICP-MS)
By the use of the Standard Operational Procedures42: SOP-A-001 Ed.3 and SOP-A-002 Ed.3.

5. Which are the acceptable limits?

No detection for textile, synthetic and leather/fur products (clothing, footwear, accessories and home
textiles, mainly)

6. How can it be avoided?

The presence of Mercury compounds can be avoided by obtaining from our suppliers of dyes and pigments the
commitment and guarantee that the dyes and pigments supplied do not contain Mercury, nor do they transmit it
to the final product, above the levels indicated in point 5 above.

39 Limits: 1 ppm for organic compounds of Mercury for textile products, such as: diapers, aprons, bibs, underwear, stockings, socks
and gloves, mainly.
40 Limits: No detection in textiles in direct and prolonged contact with the skin and/or that can be introduced in the mouth, such as:
underwear, bed linen, towels, hats, diapers, athletic footwear, gloves, bags, purses, wallets, cloth toys, textile parts and accesories
for babies, and carpets, mainly.
41 Limits: No detection in all products.
42 These procedures are owned by Inditex S.A .and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

CHROMIUM
1. What is it?
Chromium (CAS No.: 7440-47-3) is a heavy metal that can be present as pure metal or as Chromium compounds and/or complexes such as salts and dyes.

2. Where can it be found?

Chromium can be found in textile and leather products, due to its presence in the composition of dye stuff and
chemical auxiliaries used in the textile and leather industries, such as:
a) Dye stuff for Wool, Silk and Polyamide (Nylon) textiles especially for dark shades.
b) Dyeing Fixative agents and other dyeing additives for after-treatments in order to improve colour fastness
specially for dark shades.
c) Chromium salts used for tanning of leather ( for limits see Chromium (VI) )

3. How is it regulated?
Chinese Mandatory Standard43: China FZ/T 81014-2008 (Textile Industry Standard of the Peoples Republic
of China ISC 61.020 Y76), enacted in 2008.

4. How is it analyzed?
Textiles: the Total Chromium amount is determined following analytical procedures that include microwave
digestion with HNO3/H2O2, followed by quantification by Inductively Coupled Plasma-Mass Spectrometry
(ICP-MS) and/or GB/T 17593.1 Textiles-Determination of heavy metals Part 1: Atomic Absorption Spectrophotometry.
By the use of the Standard Operational Standards44: SOP-A-001 Ed.3 and SOP-A-002 Ed.3.

5. Which are the acceptable limits?

1.0 ppm for textile products intended for children younger than 3 years old (clothing, footwear, accessories,
home textiles and adornments, mainly)

6. How can it be avoided?

The presence of Chromium, above the levels indicated in point 5, can be avoided by applying the following
preventive measures:
a) For Textiles (except Polyamide, Polyamide blends & worsted wool) by obtaining from our suppliers the
commitment and guarantee that all the products used in the manufacturing process, mainly dyestuff45
and colorant additives, are Chromium-free.
b) For Polyamide, Polyamide blends & worsted wool - most important for dark shades by exhaustive
control of dyestuff concentration after consulting your dyestuff supplier to make sure the dye is bound
strongly enough and not using more Chromium than needed.

43 Limits: 1 ppm for total content of Chromium for textile products.

44 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.
45 Most Chromium containing dyes can be classified in one of the following categories:
I.Metal complex dyes

1:1 metal complex.

2:1 metal complex.
II.Mordant dyes
Metachrome.

After-chrome

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CHROMIUM (VI)
1. What is it?
Chromium (CAS NO.: 7440-43-3) is a heavy metal that, in its (VI) oxidation state, is harmful to humans. Under certain circumstances Chromium (VI) salts can be formed from some chemicals used in leather tanning.

2. Where can it be found?

It can be found in products made of leather, such as: shoes, clothing and accesories.

3. How is it regulated?
German Law46: 30 of the Food and Commodities Law (LMBG) (1/1/96), enacted in 1996.

4. How is it analyzed?
Leather/Fur and Textiles: Norm ISO 17075:2007.
By the use of the Operational Standard Procedures47: SOP-A-013 Ed.2 and SOP-A-014 Ed.2.

5. Which are the acceptable limits?

Maximum 3 ppm for textiles and leather/fur products (garments, shoes, accessories and home textiles in
direct and prolonged contact with the skin)

6. How can it be avoided?

The presence of Chromium (VI), above the levels indicated point 5, can be avoided by:
a) Substituting tanning processes involving Chromium by other Chromium-free tanning processes, that use
different tanning agents, such as: Glutaraldehyde, Phosphonium salts, Aluminum, Zirconium, and/or Titanium (a commonly used process in the tanning sector, technically denominated as wet white tanning)
b) If Chromium is used in the tanning processes, its presence in the final products must be avoided by:
Performing enough washes at the final stage of the tanning procces, in order to avoid high concentrations of Chromium (III) in the final tanned leather.
Avoiding the use of materials with a high oxidizing power, such as: unsaturated fats of fish oil.
Ensuring that the Chromium (III) used in the tanning process comes from a provider that guarantees
a clean tanning process and free of Chromium (VI)
Using neutralizing agents with reducing power.
And, finally, preventing that the pH of the final product be higher than 6,5.

46 Limits: The corresponding authorities advise that Chromium (VI) concentrations higher that 3 ppm must be avoided for those textile and leather products destined to be in direct contact with the skin.
47 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

NICKEL.
1. What is it?
Nickel (CAS NO: 7440-02-0) is a heavy metal that can be used as: (1) a brightening agent for metallic parts, and
(2) an antioxidizing agent.

2. Where can it be found?

Nickel can be present mainly in shiny metallic parts and accesories.

3. How is it regulated?
European Directive48: 76/769/EEC, 94/27/EC and 2004/96/EC, enacted in 1996.
Spanish Royal Decree49: ROYAL DECREE 1406/1989, of November 10th, in which limitations are imposed
to the commercialization and use of certain dangerous substances and mixtures. BOE 278 of November
20th, modified subsequently by Decree 1114/2006 enacted in 2006.
Norwegian Regulation50: The Regulations No. 922 of June 1st 2004, as amended, enacted in 2004.

4. How is it analyzed?
Metals: (1) Norm EN 12472 for accelerated wear and corrosion, and later (2) Norm EN 1811:1999 to evaluate
Nickel release.
By the use of the Standard Operational Procedures51: SOP-A-004 Ed.2 and SOP-A-002 Ed.3.

5. Which are the acceptable limits?

Maximum release 0.5 g/cm2/week for all metallic garments and accesories.

6. How can it be avoided?

The presence of Nickel, above the levels indicated in point 5, can be avoided by obtaining from our suppliers the
commitment and guarantee that all the products they supply are tested in accordance with the method contemplated in point 4 above.

48 Limits: Maximum release 0.5 g/cm2/week for those products in direct and prolonged contact with the skin: (1) buttons, buckles,
rivets, zippers and metallic labels which will be in direct and prolonged contact with the skin; (2) jewels and (3) watches, among
others.
49 Limits: Maximum release 0.5 g/cm2/week for those products in direct and prolonged contact with the skin: (1) buttons, buckles,
rivets, zippers and metallic labels which will be in direct and prolonged contact with the skin; (2) jewels and (3) watches, among
others.
50 Limits: Maximum release 0.5 g/cm2/week for those products in direct and prolonged contact with the skin: (1) buttons, buckles,
rivets, zippers and metallic labels which will be in direct and prolonged contact with the skin; (2) jewels, (3) watches and (4) glasses
and chains for glasses, among others.
51 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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PHTHALATES.
1. What are they?
Phthalates are chemical substances with plastifying properties added mainly to plastics and to PVC to make
them flexible.

2. Where can they be found?

Phthalates can be found in a great variety of textile and leather industry products, such as:
a) Flexible plastics.
b) Positional prints of the plastisol type.
c) Surface coatings.
d) And as demolding agent for plastics.

3. How are they regulated?

European Directive52: 2005/84/CE, enacted in 2005.
Spanish Royal Decree53: ROYAL DECREE 1406/1989, of November 10th, in which limitations are imposed to
the commercialization and use of certain dangerous substances and mixtures. BOE 278 of November 20th,
modified subsequently by Decree 1114/2006 enacted in 2006.
South Korean Law54: Korean Agency for Technology and Standards Issued a Self Regulatory Safety Confirmation Notice (Notice No. 2007-34), enacted in 2007.
Icelandic Regulation55: Regulations on Restriction of the Manufacture, Importation and Distribution of Toys
and Objects Containing Phthalates, enacted in 2000.
Italian Decree56: Decree on Phthalates Adopted on September 30th 1999, enacted in 2003.

4. How are they analyzed?

Textiles, Leather, Plastics: By Chromatographic Methods.
By the use of the Standard Operational Procedure57 SOP-A-016 Ed.2.

5. Which are the acceptable limits?

No detection for all textile, plastic and synthetic products (clothing, Footwear, accessories and home textiles, mainly)

6. How can they be avoided?

The presence of Phthalates, above the levels indicated in point 5, can be avoided by:
a) Substituting solvent based prints (plastisol prints) by water-based prints.
b) Avoiding all possible cross-contamination in the printing lines for those processes using water-based
technologies from those using water-based technologies, in order to do so, products and machinery used
in printing with both technologies must be separated/isolated.
c) Obtaining from our suppliers of chemicals and/or plastic materials the commitment and guarantee that the
products supplied do not contain neither PVC nor Phthalates above the levels indicated in point 5 above.

52 Limits: 1,000 ppm (DEHP, DBP and BBP) for toys and products for children younger than 3 years old, and 1,000 ppm (DINP, DIDP
and DNOP) for toys and products for children younger than 3 years old that can be inserted into the mouth.
53 Limits: 1,000 ppm (DNOP, DEHP, BBP, DBP) in coated textiles, rubber and plastics for babies, mainly.
54 Limits: 500 ppm for products destined for children younger than 3 years old that can be inserted into the mouth (teething aids,
feeding bottles and bath accesories, mainly)
55 Limits: 500 ppm for toys aimed for children younger than 3 years old which, according to their nature or design, can be inserted
into the mouth.
56 See Annex II: List of Individual Controlled Substances (pages 73, 74, 75 and 76)
57 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.
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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

POLYBROMINATED FIRE-RESISTANT COMPOUNDS.

1. What are they?
Polybrominated Fire-Resistant Compounds are chemical substances that are added to textile fibers to act as
flame retardants.

2. Where can they be found?

Polybrominated Fire-Resistant Compounds can be found in home textile products and in garments for special
purposes, such as: Individual Protection Equipment (IPEs) and flame-resistant sleepwear, among others.

3. How are they regulated?

European Directive58: 2003/11/EC that modifies 76/769/EEC, enacted in 2004.
Japanese Law59: Law for the Control of Household Products Containing Harmful Substances, enacted in
1978.
Swedish Ordinance60: KIFS 1998:8, enacted in 1998.

4. How are they analyzed?

Textiles: By Chromatographic Methods.
By the use of the Standard Operational Procedures61: SOP-A-020 Ed.2 and SOP-A-021 Ed.1.

5. Which are the acceptable limits?

No detection of: TRIS, TEPA, PBB and BBPP for all types of textile products (clothing, footwear, accessories and home textiles, mainly)
Maximum 1.000 ppm of: PentaBDE, DecaBDE and OctaDBE, for all types of textile products (clothing, footwear, accessories and home textiles, mainly)

6. How can they be avoided?

The presence of Polybrominated Fire-Resistant Compounds, above the levels indicated in point 5, can be
avoided by:
a) Using only fire-resistant compounds made by internationally reputed suppliers, who show public commitments and compliance with the most stringent product health laws for all those dyes and pigments they
market.
b) Obtaining from our suppliers the commitment and guarantee that the chemicals supplied do not contain
Polybrominated Fire-Resistant Compounds above the levels indicated in point 5 above.

58 Limits: 1.000 ppm (Penta BDE, and OctaDBE) for all products, and forbidden (TRIS, TEPA and PBB) for those products in direct
contact with the skin, such as: underwear and/or bed linen, mainly.
59 Limits: Forbidden (TRIS, TEPA, PBB and BBPP) in textiles for sleepwear, bed linen, curtains and carpets/rugs, mainly.
60 Limits: 1.000 ppm (PentaBDE, OctaDBE and DecaDBE) for all products, and forbidden (TRIS, TEPA and PBB) for those products
in direct contact with the skin, such as: underwear and/or bed linen, mainly.
61 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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PESTICIDES.
1. What are they?
Pesticides are chemical substances usually employed in the textile and leather industries as: (1) insecticides for
wool fibers, (2) insecticides and herbicides for growing vegetable fibers, and (3) preservatives for natural raw
materials.

2. Where can they be found?

Pesticides can be present in: (1) natural fibers of vegetable origin, such as: cotton, flax, and/or linen, (2) natural
fibers of animal origin, such as: wool and silk, and (3) in furs.

3. How are they regulated?

Swiss Ordinance62: Ordinance on Risk Reduction Related to the Use of Certain Particularly Dangerous Substances, Preparations and Articles (Ordinance on Risk Reduction Related to Chemical Products
(ORRChim), enacted in 2001.
Polish Ordinance63: The Ordinance of the Council for Ministers on safety and labelling of textile products of
October 19th 2001 enacted in 2001.
Finnish Decree64: Government Decree on Persistent Organic Substances (735/2002), issued in Helsinki on
August 22nd, 2002. enacted in 2002.
Japanese Law65: Law for the Control of Household Products containing Harmful Substances, enacted in
1975.

4. How are they analyzed?

Textiles and Furs: By Chromatographic Methods.

5. Which are the acceptable limits?

No detection for those Pesticides included in Annex II, for all types of textile and leather/fur products (clothing, footwear, accessories and home textiles, mainly)

6. How can they be avoided?

The presence of the regulated Pesticides can be avoided, among other measures, by obtaining from our suppliers
the commitment and guarantee that all the chemicals that have been used for the growing of vegetable fibers and
for the preservation of animal fibers and leather, do not contain any of the forbidden Pesticides.66

62 Limits: Those Pesticides listed in the ordinance and those containing Mercury are forbidden in textiles and leather/fur products.
63 Limits: The use of Arsenic and Mercury in textile products in direct and prolonged contact with the skin, such as: underwear,
sheets, towels, hats, footwear, textile toys and carpets/rugs, mainly, is forbidden.
64 Limits: Aldrine, DDT (1,1,1 trichlorine-2,2 bis (4-chlorophenyl)ethane), Dieldrine, Endrine, Hexachlorobenzene (HCB), Heptachlorine,
Chlordane, Mirex, Polychlorinated biphenyls and Toxaphene are forbidden in all articles.
65 Limits: 30 ppm for Dieldrin in textile products, such as: diapers, underwear, sleepwear, gloves, socks, stockings, middlewear and
outerwear, hats, caps, sheets and rugs.
66 See Annex II: List of Individual Controlled Substances (pages 73, 74, 75 and 76)

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SHORT-CHAIN CHLORINATED PARAFFINS.

1. What are they?
Short Chain Chlorinated Paraffins (CAS NO. 85535-84-8) are chemical substances mainly used in the leather
industry as a greasing agent for use after the tanning procces and also as flame-resistant and plastifying agents.

2. Where can they be found?

In leather products, such as: footwear, clothes and accessories.
In textiles, rubbers and plastics, as flame-resistant agents.
In surface paints and coatings, as varnishes.

3. How are they regulated?

Swiss Ordinance67: The Ordinance on Risk Reduction related to Chemical Products (ORRChim) of May 18th
2005, enacted in 2005.

4. How are they analyzed?

Leather : By Chromatographic Methods.
By the use of the Standard Operational Procedure68 SOP-A-027 Ed.1

5. Which are the acceptable limits?

Maximum 1000 ppm for textile, leather and plastic products (clothing, footwear, accessories and home
textiles, mainly)

6. How can they be avoided?

The presence of the regulated Short Chain Chlorinated Paraffins can be avoided by, among other measures, obtaining from our suppliers the commitment and guarantee that they have not used these substances as (1) greasing agents for leather, (2) flame-resistant agents for textiles and plastics, and/or (3) plastifying agent for paints.

67 Limits: 1% in paints, varnishes, plastics, rubbers, textiles, leather-processing products and metal-processing products, mainly.
68 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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PERFLUOROOCTANE SULFONATES (PFOS)

1. What are they?
Perfluorooctane Sulfonates (PFOS) (CAS NO.: 2795-39-3) are surfactants used sometimes in the textile and
leather industries to increase resistance of the final products to grease, oil and water.

2. Where can they be found?

PFOS can be present in water-proof textiles and/or stain-proof textiles (hydrofuges and oilfuges), in clothing,
home textiles and footwear, mainly.

3. How are they regulated?

Norwegian Regulation69: The Regulation No. 922 of June 1st 2004 (as amended), enacted in 2007.
European Directive70:Directives 76/769/EEC and 2006/122/EC, enacted in 2008.

4. How are they analyzed?

Textiles, Leather and Similar Materials: By Chromatographic Methods.
By the use of the Standard Operational Procedure71 SOP-A-025 Ed.2.

5. Which are the acceptable limits?

Maximum 1 g/m2 for textile products or other coated materials, such as furs or synthetics (clothing, footwear, accessories and home textiles, mainly)

6. How can they be avoided?

The presence of PFOS can be avoided by, among other measures, obtaining from our suppliers of chemicals
the commitment and guarantee that the products supplied do not contain PFOS and/or that they do not transfer
them to the final products in amounts higher than the levels indicated in point 5 above.

69 Limits: Textile products or other materials containing more than 1 g/m2 of PFOS or related compounds are forbidden.
70 Limits: Textile products or other materials containing more than 1 g/m2 of PFOS or related compounds are forbidden.
70 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

DIMETHYL FUMARATE.
1. What is it?
Dimethyl Fumarate is a chemical substance traditionally used in the agriculture industry and, nowadays, in the
textile industry as well as a biocide to prevent the formation of mold in wood and fur products, during storage
and/or transport in humid climates.

2. Where can it be found?

Dimethyl Fumarate can be found in textiles made from natural fibers and in leather and imitation-leather products.

3. How is it regulated?
French Regulation: NOR: ECEC0828052A, enacted in 2009.
Belgian Ministerial Decree: Belgium Official Journal 12/01/2009, enacted in 2009.
Spanish Royal Decree: BOE of 21/01/2009, enacted in 2009.
European Directive72: 2009/251/CE, enacted in 2009.

4. How is it analyzed?
Textiles, Leather and Plastics: By Chromatographic Methods with detection limits better than 0.1 ppm.

By the use of Standard Operational Procedure73 SOP-A-029 Ed.1.

5. Which are the acceptable limits?

Maximum 0.1 ppm for textile and leather products (clothing, footwear, accessories and home textiles,
mainly)

6. How can it be avoided?

The presence of Dimethyl Fumarate can be avoided by, among other measures, obtaining from our suppliers the
commitment and guarantee that the products supplied do not contain Dimethyl Fumarate and/or that they do not
transfer it to the final products at any stage of the manufacturing process.

72 Limits: Products containig Dimethyl Fumarate cannot be commercialized. The maximum limit to detect the presence of Dimethyl
Fumarate is 0.1 mg/kg of product or part of the product.
73 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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ORGANOTIN COMPOUNDS.
1. What are they?
Organotin Compounds are organic compounds of Tin that are widely used as antifungal and antibacterial agents
in the textile and leather industries. They are also used as stabilizers for plastics and catalysts in polymer synthesis.

2. Where can they be found?

Organotin Compounds can be found in numerous chemicals used in the textile and leather industries, such as:
a) Antibacterials and fungicides in sport clothing and in textiles made from natural and synthetic fibers.
b) Resins and polymers in: prints, coatings and plastic parts.

3. How are they regulated?

Japanese Law74:Law for the Control of Household Products Containing Harmful Substances (1973), enacted in 1980 and The Guide to Law for the Control of Household Products Containing Harmful Substances
(3/1999)
South Korean Law75: Safety Confirmation Notice (No.2007-34) Annex 4, enacted in 2007.

4. How is it analyzed?
Textiles, Leather/Fur and Plastics: By Chromatographic Methods (CG-MS or GC-AED)
By the use of the Standard Operational Procedures76: SOP-A-018 Ed.2 and SOP-A-019 Ed.2.

5. Which are the acceptable limits?

No detection in textile, leather and synthetic products for children younger than 3 years old, and for textile
products, destined for customers older than 3 years old, in direct and prolonged contact with the skin (clothing, footwear, accessories and home textiles, mainly)

6. How can it be avoided?

The presence of Organotin Compounds can be avoided by, among other measures, obtaining from our suppliers
the commitment and guarantee that the products supplied do not contain DBT, TBT nor TPhT and/or that they do
not transfer them to the final products at any stage of the manufacturing process and, additionally, by not using
this type of products as catalysts.

74 Limits: No detection of TBT and TPhT in textiles, such as: diapers, aprons, underwear, gloves and socks, mainly.
75 Limits: 1 ppm of DBT for baby clothing; 0.5 ppm of TBT for baby clothing, and 1 ppm of TBT for underwear and bed linen, mainly.
76 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

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ALLERGENIC DYES.
1. What are they?
Allergenic Dyes are a type of disperse dyes that can induce allergic reactions when are in direct contact with the
skin.

2. Where can they be found?

Allergenic Dyes are mainly used to dye some polyester, acetate and polyamide products, either as dyed and printed products, or in dyed parts, such as buttons.

3. How is it regulated?
German Law77: 30 of the Food and Commodities Law (LMBG) (1/1/96), enacted in 1996.

4. How are they analyzed?

Textiles and Plastics: Norm DIN 54231.

By the use of the Standard Operational Procedure78 SOP-A-017 Ed.2.

5. Which are the acceptable limits?

No detection in textile products for children younger than 3 years old, and in textile products for customers older than 3 years old in direct and prolonged contact with the skin (clothing, footwear, accessories
and home textiles, mainly)

6. How can they be avoided?

The presence of Allergenic Dyes can be avoided by applying the following preventive measures, among others:
a) By obtaining from our suppliers of dyes and pigments the commitment and guarantee that the dyes and
pigments supplied are not, nor do they contain, any of the regulated Allergenic Dyes.79
b) By using only dyes and/or pigments made by internationally reputed suppliers, who show public commitments and compliance with the most stringent product health laws for all those dyes and pigments they
market and or supply at any stage in the manufacturing process.80

77 Limits: the competent authorities forcefully advise that Allergenic Dyes must not be used for dyeing textile products to be used in
direct contact with the skin (detection limit for DIN method 54231: 50ppm) (Allergenic Dyes: Disperse Blue1, Disperse Blue106,
Disperse Blue124, Disperse Blue35, Disperse Orange 3, Disperse Orange 37/76, Disperse Red 1, Disperse Yellow 3)
78 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.
79 See Annex II: List of Individual Controlled Substances (pages 73, 74, 75 and 76)
80 This information can be found at ETAD, Ecological Toxicological Association of Dyestuffs (www.etad.com)

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II REFERENCE MANUAL: SUBSTANCES OF LIMITED USE.

ORGANOCHLORINATED COMPOUNDS.
1. What are they?
Organochlorinated Compounds are chemical substances used in several dyeing processes of polyester
fibers at temperatures lower than 120 degrees centigrade.

2. Where can they be found?

Organochlorinated Compounds can be found in some polyester products and, especially, those mixed with
fibers of animal origin, such as wool.

3. How are they analyzed?

Textiles: By Chromatographic Methods.
By the use of the Standard Operational Procedures81: SOP-A-015 Ed.1 and SOP-A-026 Ed.1.

4. Which are the acceptable limits?

Maximum 1 ppm in textile products for children younger than 3 years old, and in textile products for customers older than 3 years old in direct and prolonged contact with the skin (clothing, footwear, accessories
and home textiles, mainly)

5. How can they be avoided?

The presence of Organochlorinated Compounds can be avoided by, among other measures, obtaining from our
suppliers of chemicals the commitment and guarantee that the products supplied do not contain Organochlorinated Compounds82 and/or that they do not transfer them to the final products in amounts higher than the levels
indicated in point 4 above.

81 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.
82 See Annex II: List of Individual Controlled Substances (pages 73, 74, 75 and 76)

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II REFERENCE MANUAL: SUBSTANCES OF LEGALLY LIMITED USE.

ISOCYANATES.
1. What are they?
Isocyanates are chemical precursors of those polyurethanes used as elastomers (elastic fibers), glues and coatings for furs and textiles (synthetic materials imitating fur/leather)

2. Where can they be found?

Isocyanantes can be found in several products of the textile industry, such as:
a) Polyurethane synthetic materials.
b) Polyurethane coatings, such as imitation leather.
c) Positional prints.

3. How are they analyzed?

Textiles, Leather and Plastics: Norm DIN 55959.
By the use of the Standard Operational Procedure83 SOP-A-028 Ed.1.

4. Which are the acceptable limits?

Maximum 1 ppm for textile products, leather and fake fur/leather materials (clothing, footwear, accessories
and home textiles, mainly)

5. How can they be avoided?

The presence of Isocyanates can be avoided by applying, among others, the following measures:
a) By obtaining from our suppliers of chemicals the commitment and guarantee that the products supplied do
not contain Isocyanates and/or that they do not transfer them to the final products in amounts higher than
the levels indicated in point 5 above.
b) By the complete polymerization of polyurethanes, so as to avoid the presence of Isocyanantes in the final
products.

83 These procedures are owned by Inditex S.A. and have been developed by the University of Santiago de Compostela. They
describe in detail all the handling and quality requirements of the analytical procedure to determine the substance or substances
specified. These procedures are reserved to laboratories accredited by Inditexs Corporate Social Responsibility Department.

This Guideline is a free translation from the Spanish Version.

48

III LEGALLY
LIMITED
PARAMETERS

III LEGALLY LIMITED PARAMETERS

LEGALLY LIMITED PARAMETERS.

pH.
1. What is it?
It is a parameter used to indicate the acidity and/or basicity of any given substance. It ranges from 0 (most
acid) to 14 (most basic) The value for neutral pH is 7.

2. Where can it be found?

In textile products in general.

3. How is it regulated?
Standard of compulsory use in the Peoples Republic of China84: GB National Standard of the Peoples
Republic of China, enacted in 2005.

4. How is it analyzed?
According to the Norms: GB/T 7573:2009 and/or ISO 3071:2005.

5. Which are its limits?

4.0 - 7.5 for textile products for children younger than 3 years old.
4.0 - 7.5 for in textile products for customers older than 3 years old in direct and prolonged contact with the
skin (clothing, footwear, accessories and home textiles, mainly)
4.0 - 9.0 in textile products for customers older than 3 years old without direct and prolonged contact with
the skin (clothing, footwear, accessories and home textiles, mainly)

6. How can acid and basic products be avoided?

By washing the textile with acid/basic washings until neutrality.
By following the recommendations included in pH Guideline & Implementation Toolkit.

84 Limits:

4.0 - 7.5 for textile products for: (1) children younger than 2 years old and (2) customers older than 2 years old, in garmets in direct
contact with the skin.

4.0 - 9.0 for textile products for customers older than 2 years old, in garmets without direct contact with the skin.

This Guideline is a free translation from the Spanish Version.

53

III LEGALLY LIMITED PARAMETERS

COMPOSITION TOLERANCE.
1. What is it?
This is the parameter which quantifies the difference of the composition85 in percentage between the value stated
in the label and the actual one of the garment.

2. Where is it applied?
In textile products in general. Particularly, there is a high risk of non compliance with the tolerance limits in
the following cases: 1) carding processed textiles and 2) textiles which suffered an enzymatic washing.

3. How is it regulated?
European Directive: 2008/121/EC, enacted in 2009.
Spanish Decree: Real Decreto Espaol 928/1987, enacted in 1988 and 396/1990, enacted in 1991.
Standard and code of mandatory use in the Peoples Republic of China: FZ/T 01053-2007, Textiles Identification of Fiber content, enacted in 1998.

4. How is it analyzed?
The different fabrics86 of a garment must be analyzed independently according to the following standards:
For Binary mixture: ISO 1833:2006, CE/96/73 and UNE 40110:1994.
For Tertiary mixture: ISO 5088:1979, CE/73/44 and UNE 40327:1994.

5. Which are its limits?

Single: no tolerance.
Mix: 3%
Exceptions:
a) When a fiber content in a mixture is less or equal to 15%, the tolerance is 30% for this fiber.
b) Articles with justified technical difficulties87: 5% in weight.

6. How can it be avoided?

By obtaining from our suppliers of fabrics and spinning the commitment and guarantee that the products supplied are in accordance with the composition tolerance limits established in point 5.

85 Parameter which expresses the mass of each fibre as a percentage of the total mass of the textile article.
86 Different fabrics are considered as those which present variations in composition, colouring and/or printing.
87 Articles with technical difficulties are those articles obtained from justified specific and/or particular processes that may present
higher composition tolerances: articles that suffered carding, worsted and enzymatic treatments, mainly.

54

This Guideline is a free translation from the Spanish Version.

III LEGALLY LIMITED PARAMETERS

COLOUR FASTNESS IN WATER.

1. What is it?
This is the index which valuates the resistance of the colour of any type of textile to a process of soaking in soft
water and later rest. The Colour Fastness in Water valuates the colour resistance as: 1) colour change- variation on colour intensity- and 2) colour staining staining of a white standard probe -, ranging both index from 1
(worst fastness) to 5 (best fastness)

2. Where it is applied?
It is applied to dyed, pigmented and/or continuous printed textile articles88.

3. How is it regulated?
Standard and code of mandatory use in the Peoples Republic of China89: National General Safety Technical
Code for Textile Products GB 18401-2003, enacted in 2005.

4. How is it analyzed?
The different fabrics90 of a garment must be analyzed independently according to the Norms: GB/T 5713-1997
and/or ISO 105 E01:1994.

5. Which are its limits?

The limits for colour change and colour staining are as follows:
3 - 4 for textile products for children younger than 3 years old.
3 in textile products for customers older than 3 years old (clothing, footwear, accessories and home textiles, mainly)
Exception: 4-5 (staining) for all textile products indicated before with white or pale adjacent to dark parts.
Note: The washing de-pigmented products are out of the scope.

6. How can it be avoided?

The compliance with the limits indicated in point 5 can be avoided by applying the following actions:
a) Correct Dyestuff selection according to the fiber composition from the fabric to dye;
b) Correct application of dyeing processes using the technical data sheet specific for the selected dyestuff;
c) Correct rinse of the fabric;
d) Correct control on dyed and finished products; and,
e) By obtaining from our suppliers of textile and spinning the commitment and guarantee that the products
supplied are in accordance with the minimum Colour Fastness limits.

88 This printing is applied onto the uncut fabric.

89 Limits: index 3-4 for products intended for babies; index 3 for products with direct contact with skin; and index 3 for products
without direct contact with the skin.
90 Different fabrics are considered as those which present variations in composition, colouring and/or printing.

This Guideline is a free translation from the Spanish Version.

55

III LEGALLY LIMITED PARAMETERS

COLOUR FASTNESS TO PERSPIRATION.

1. What is it?
This is the index which valuates the resistance of the colour of any type of textile to acid and basic sweat (human
perspiration) The Colour Fastness to Perspiration valuates the colour resistance as: 1) colour change- variation
on colour intensity- and 2) colour staining staining of a white standard probe -, ranging both index from 1
(worst fastness) to 5 (best fastness)

2. Where it is applied?
It is applied to dyed, pigmented and/or continuous printed textile articles91.

3. How is it regulated?
Standard and code of mandatory use in the Peoples Republic of China92: National General Safety Technical
Code for Textile Products GB 18401-2003, enacted in 2005.

4. How is it analyzed?
The different fabrics93 of a garment must be analyzed independently according to the Norms: GB/T 3922-1995
and/or ISO 105 E04:1994.

5. Which are its limits?

The limits for colour change and colour staining are as follows:
3 - 4 for textile products, with dark shades, for children younger than 3 years old.
4 for textile products, with pale shades, for children younger than 3 years old.
3 in textile products for customers older than 3 years old (clothing, footwear, accessories and home textiles,
mainly)
Exception: 4-5 (staining) for all textile products indicated before with white and pale parts adjacent to
dark parts.
Note: The washing de-pigmented products are out of the scope.

6. How can it be avoided?

The compliance with the limits indicated in point 5 can be avoided by applying the following actions:
a) Correct Dyestuff selection according to the fiber composition from the fabric to dye;
b) Correct application of dyeing processes using the technical data sheet specific for the selected dyestuff;
c) Correct rinse of the fabric;
d) Correct control on dyed and finished products; and,
e) By obtaining from our suppliers of textile and spinning the commitment and guarantee that the products
supplied are in accordance with the minimum Colour Fastness limits.

91 This printing is applied onto the uncut fabric.

92 Limits: index 3-4 for products intended for babies; index 3 for products with direct contact with skin; and index 3 for products
without direct contact with the skin.
93 Different fabrics are considered as those which present variations in composition, colouring and/or printing.

56

This Guideline is a free translation from the Spanish Version.

III LEGALLY LIMITED PARAMETERS

COLOUR FASTNESS TO RUBBING.

1. What is it?
This is the index which valuates the resistance of the colour of any type of textile to the aggression made by continuos rubbing with other fabric (wet and dry fabric) The Colour Fastness to Rubbing valuates the colour resistance as colour staining staining of a white standard probe -, ranging the index from 1 (worst fastness) to 5 (best
fastness)

2. Where is it applied?
It is applied to dyed and/or both continuous printed94 textile articles and to the following localized-printed95
articles : pigments, purpurin and transfers, mainly.

3. How is it regulated?
Standard and code of mandatory use in the Peoples Republic of China96: National General Safety Technical
Code for Textile Products GB 18401-2003, enacted in 2005.

4. How is it analyzed?
The different fabrics97 of a garment must be analyzed independently according to the Norms: GB/T 3920-1997
and/or EN-ISO 105 X12:1993.

5. Which are its limits?

The limits for colour staining are as follows:
4 for textile products for children younger than 3 years old.
3 in textile products for customers older than 3 years old (clothing, footwear, accessories and home textiles,
mainly)
Exception: 2-3 for all textile products with denim effect: jeans.
Note: The washing de-pigmented products are out of the scope.

6. How can it be avoided?

The compliance with the limits indicated in point 5 can be avoided by applying the following actions:
a) Optimum and regular resin polymerization used on pigment prints and special effects like knife coatings
and a like;
b) Vigorous washing of the fabric (dry and wet);
c) The use of non excessive oiling and auxiliary products;
d) Correct control on dyed and finished products; and,
e) By obtaining from our suppliers of textile and spinning the commitment and guarantee that the products
supplied are in accordance with the minimum Colour Fastness limits.

94 This printing is applied onto the uncut fabric.

95 This refers to the typology of printing done in a localized manner on the manufactured garment or on the parts of the fabric cut out
for its subsequent manufacturing.
96 Limits: index 4 for products intended for babies; index 3 for products with direct contact with skin; and index 3 for products without direct contact with the skin.
97 Different fabrics are considered as those which present variations in composition, colouring and/or printing.

This Guideline is a free translation from the Spanish Version.

57

III LEGALLY LIMITED PARAMETERS

COLOUR FASTNESS TO SALIVA.

1. What is it?
This is the index which valuates the resistance of the colour of any type of textile artificial and simulated saliva.
The Colour Fastness to Saliva valuates the colour resistance like: 1) colour change- variation on colour intensity- and 2) colour staining staining of a white standard probe -, ranging both index from 1 (worst fastness) to 5
(best fastness)

2. Where is it applied?
It is applied to dyed and/or continuous printed textile articles98.

3. How is it regulated?
Standard and code of mandatory use in the Peoples Republic of China99: National General Safety Technical
Code for Textile Products GB 18401-2003, enacted in 2005.

4. How is it analyzed?
The different fabrics100 of a garment must be analyzed independently according to Norm: GB/T 18886.

5. Which are its limits?

The limits for colour change and colour staining are as follows:
4 for textile products for children younger than 3 years old.
Note: The washing de-pigmented products are out of the scope.

6. How can it be avoided?

The compliance with the limits indicated in point 5 can be avoided by applying the following actions:
a) Correct Dyestuff selection according to the fiber composition from the fabric to dye;
b) Correct application of dyeing processes using the technical data sheet specific for the selected dyestuff;
c) Correct rinse of the fabric;
d) Vigorous washing and rinse;
e) Correct control on soap and fats residues.
f) The use of non excessive oiling and auxiliary products;
g) Not applying pigments in de-washed products;
h) Correct control on dyed and finished products; and,
i) By obtaining from our suppliers of textile and spinning the commitment and guarantee that the products
supplied are in accordance with the minimum Colour Fastness limits.

98 This printing is applied onto the uncut fabric.

99 Limits: index 4 for products intended for babies.
100 Different fabrics are considered as those which present variations in composition, colouring and/or printing.

58

This Guideline is a free translation from the Spanish Version.

IV OTHER EU
REGULATIONS
OF MANDATORY
COMPLIANCE:
REACH

IV OTHER EU REGULATIONS OF MANDATORY COMPLIANCE: REACH

OTHER EU REGULATIONS OF MANDATORY COMPLIANCE.

REACH.
1. What is it?
REACH is an European Union directive that regulates the Registry, Avaliation, Authorization and Restriction
of Chemicals (Regulation EC 1907/2006 of the European Parliament and Council)

2. Is it of mandatory compliance?
REACH is a mandatory regulation for those suppliers that manufacture, distribute and/or supply ready-to-wear
items, accessories, complements, labels, containers, balings and footwear (hereinafter, Products) for any of
Inditexs formats and that, later, are set aside for sale in any of the European Union member states.
To do so, the mentioned Suppliers should control and manage properly any phase their own and/or subcontracted of the manufacture cycle of the Products with the aim of: (1) detecting and, as a result, avoiding the
presence of Substances of Very High Concern (SVHC)101 in amounts higher than 0,1% of the total weight of
the Products, and (2) justifying the absence of SVHC before any external agency and/or Product Health Team of
Inditex.
If the mentioned SVHCs were detected in amounts higher than the above mentioned limit in the Products before
its import to whichever European Union member states, Suppliers should notify immediately its existence to the
Corporate Social Responsibility Department of Inditex, as well as the corresponding Corrective Action Plan for
its appropriate elimination.

101 REACH defines Substances of Very High Concern (SVHC) as those substances that are carcinogenic, mutagenic or toxic for
human reproduction (CMT 1 and CMT 2) and those persistent, bioaccumulating and toxic (PBT and vPvB) SVHCs have been
published in Annex XVII of REACH for CMT1 and CMT2, and in the web page of the European Chemicals Bureau (http://ecb.jrc.
ec.europa.eu/reach/) for PBT and vPvB.

This Guideline is a free translation from the Spanish Version.

63

ANNEX I:
SUMMARY TABLE
clear to wear

ANNEX I: SUMMARY TABLE clear to wear

ANNEX I: SUMMARY TABLE clear to wear

This Referece Manual is a free translation from the Spanish Version.

67

ANNEX I: SUMMARY TABLE clear to wear

68

This Referece Manual is a free translation from the Spanish Version.

ANNEX I: SUMMARY TABLE clear to wear

This Referece Manual is a free translation from the Spanish Version.

69

ANNEX II:
List of controlled
individual
substances

ANNEX II: List of controlled individual substances

ANNEX II: List of controlled individual substances

This Referece Manual is a free translation from the Spanish Version.

73

ANNEX II: List of controlled individual substances

74

This Referece Manual is a free translation from the Spanish Version.

ANNEX II: List of controlled individual substances

This Referece Manual is a free translation from the Spanish Version.

75

ANNEX II: List of controlled individual substances

76

This Referece Manual is a free translation from the Spanish Version.

ANNEX III:
Commitment to
comply with the
inditex groups
Clear to Wear
Product Health
Standard

COMMITMENT TO COMPLY WITH THE INDITEX GROUPS CLEAR TO WEAR PRODUCT

HEALTH STANDARD.
I hereby confirm that:
1) We have received the Clear to Wear (hereinafter, CTW) product health standard, we have read it and thoroughly understand its implications;
2) We acknowledge that compliance with the CTW is a contractual obligation and undertake, accordingly, to
meet the CTW requirements in all orders involving production, marketing or distribution placed by any of
the formats of the Inditex Group.
3) We undertake to disclose and formally demand CTW implications to the whole of the production line.
4) The Inditex Group:
Reserves the right to check: i) compliance with CTW regarding any good supplied, by any method,
at any time, and/or at any stage of the production, marketing or distribution processes, and ii) the
appropriate disclosure of CTW.
Reserves the right to cancel any order for any good where non compliance with CTW regarding any
test and/or inspection carried out pursuant to the printout has been established.
Reserves the right to return any orders already delivered where non compliance with CTW regarding any test and/or inspection carried out pursuant to the printout has been established.
Reserves the right to cancel or destroy, or to order destruction of the goods subject to the cancelled order, subject to the fact that the cancellation of the relevant order shall entail the non existence
of the obligation to pay any sum whatsoever for the goods failing to comply with CTW.
Holds the Supplier as solely responsible for any and all damages caused by the goods failing to
comply with CTW;
and last,
5) We acknowledge that approval of a sample and any subsequent repetition of goods by the INDITEX
Group do not release us from our liability, for the entire production, marketing and distribution processes.

This Referece Manual is a free translation from the Spanish Version.

79

www.inditex.com

Av. de la Diputacin s/n, 15142 Arteixo. A Corua, Espaa.