Two Different Tools: Certification vs. Guideline
Before diving into the comparison, it’s essential to understand what each of these systems is and what they’re not.
- The AFIRM RSL (Restricted Substances List) is a voluntary industry guideline developed by a group of leading apparel and footwear brands. It helps brands communicate chemical restrictions to suppliers. It is not a certification, and it does not involve independent testing or compliance audits.
- The OEKO-TEX® STANDARD 100, on the other hand, is a third-party certification. It includes a restricted substances list, but also a defined testing programme, consistent methodology, and a verification process carried out by accredited institutes — including on-site inspections and regular audits.
In short, AFIRM serves as a helpful reference for internal chemical management within supply chains, guiding brands and suppliers on which substances to monitor. OEKO-TEX®
STANDARD 100, by contrast, is an independently verified certification that demonstrates compliance through accredited testing, auditing, and a globally recognised label.
Common Ground: Shared Values in Chemical Safety
Both OEKO-TEX® STANDARD 100 and the AFIRM RSL Version 10 (2025) aim to minimise exposure to hazardous substances in consumer products. Many substance categories are harmonised across both standards, including:
- Acetophenone & 2-Phenyl-2-Propanol
- Acidic & Alkaline Substances
- Azo-amines & Arylamine Salts
- Brominated & Organophosphorus Substances
- Formaldehyde
- Heavy Metals (Non-Jewellery)
- Pesticides & Herbicides (Agricultural)
- Phthalates
- Polycyclic Aromatic Hydrocarbons (PAHs)
- Quinoline
- UV Absorbers/Stabilisers
This alignment is reassuring — it demonstrates a consensus within the industry on what must be controlled to protect human health and the environment.
Where STANDARD 100 Goes Further
While harmonisation exists, OEKO-TEX® STANDARD 100 frequently takes a more rigorous approach by:
- Testing additional substances within a group: For example, in the case of Bisphenols, OEKO-TEX® also includes BPAF and Vulkanox, which are not addressed by AFIRM.
- Applying stricter limit values: For instance, for Chlorinated Benzenes like 1,2-Dichlorobenzene, OEKO-TEX® sets the threshold at 1 mg/kg, compared to AFIRM’s 10 mg/kg.
- Using more sophisticated testing procedures: OEKO-TEX® employs methods like thermal desorption for VOCs, resulting in a broader and more sensitive analysis.
Categories where OEKO-TEX® goes further include:
- Alkylphenols (APs) & APEOs (including more isomers)
- Bisphenols (e.g., BPAF, Vulkanox)
- Chlorinated Paraffins (SCCP & MCCP)
- Chlorophenols (including mono- and di-chlorinated not listed by AFIRM)
- Chlorinated Benzenes & Toluenes
- Cyclosiloxanes
- Dimethylfumarate
- N-Nitrosamines
- Organotin Compounds
- Ortho-phenylphenol
- PFAS (including additional PFAS beyond legal and AFIRM requirements)
- Solvent & Residuals (including additional analytes like NEP)
This reflects the STANDARD 100 philosophy: proactively test beyond legal minimums to support consumer confidence and industry leadership.
Complex Substances Require Different Approaches
Some substance groups are not harmonised between the two systems, and additional testing may be required to ensure full AFIRM coverage if a product is only certified under STANDARD 100. These differences reflect varying approaches in risk evaluation and test design.
- Dyes: OEKO-TEX® covers nearly all dyes listed by AFIRM, and even when specific ones aren’t tested directly, they are often detected indirectly via AZO testing — a more efficient approach. However, a few dyes listed in AFIRM (e.g. Disperse Red 151) are not directly covered and may require separate testing if specifically requested.
- Heavy Metals (Jewellery): The AFIRM list refers to ASTM toy safety standards (e.g., F2923/F963). OEKO-TEX® STANDARD 100 does not routinely test for heavy metals in jewellery according to these standards, as they are not considered directly relevant for all product types. Instead, a risk-based approach may be applied. Testing can be provided upon request where necessary.
- Monomers: OEKO-TEX® covers styrene and vinyl chloride via VOC emission testing, while AFIRM frames these under monomer restrictions. OEKO-TEX® is currently reviewing options to expand its coverage in this area. For now, additional testing is available on request.
- Ozone-Depleting Substances: These substances are rarely tested due to their global phase-out and limited relevance in modern textile production. While AFIRM includes them in its list, OEKO-TEX® does not routinely test for them, as they are currently not considered relevant within the STANDARD 100 framework.Total Organic Fluorine (TOF): OEKO-TEX®
currently sets the limit at 100 mg/kg, while AFIRM applies a stricter threshold of 50 mg/kg. However, OEKO-TEX® is expected to harmonise this limit as of 01.01.2026. Importantly, the OEKO-TEX® test report clearly indicates the measured values, so customers can easily see whether their result is also compliant with the AFIRM requirement.
The Bottom Line: Complementary Tools, Different Purposes
The AFIRM RSL and OEKO-TEX® STANDARD 100 are not competitors — they are tools for different levels of the value chain. Brands using AFIRM can still benefit from OEKO-TEX® certification to:
- Provide a globally recognised, consumer-facing label that builds trust at the point of sale.
- Ensure independent third-party verification, giving customers, partners, and regulators confidence that safety requirements are being met.
- Secure market access in regions with stricter chemical safety rules, particularly in Europe and Asia.
- Strengthen product marketing and brand reputation with a certification known for safety and transparency.
- Avoid redundant testing by relying on a comprehensive and harmonised test plan, saving both time and cost.
By choosing OEKO-TEX® STANDARD 100, you go beyond guidance — you demonstrate action, transparency, and leadership in product safety and quality.
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