GB18401-2010 "National Basic Safety Technical Specification for Textile Products" (hereinafter referred to as the 10th edition standard) was released on January 14, 2011. This version replaces the current GB18401-2003 (hereinafter referred to as the 03 edition standard) and will be implemented from August 1, 2011. The National Basic Safety Technical Specification for Textile Products is a mandatory national standard, a necessary condition for products to enter the market, and the most basic safety technical requirements proposed to ensure that textile products are harmless to human health. It plays a very important role in textile production, sales, and daily supervision and inspection. Therefore, it is particularly important to correctly understand the standard provisions and clarify their differences from the 03 version of the standard.
1. Main Differences and Interpretation of Articles
Compared with the 03 version, the 10th version of the standard has the following changes, which can be referred to as the strengthened version of GB18401-2003.
1.1 Scope of Application
The 10th edition of the standard stipulates in its scope of application that "this standard applies to textile products for consumption, decoration, and household use produced and sold within the territory of China. Export products may be executed in accordance with the provisions of the contract. Note: The products listed in Appendix A do not fall within the scope of this standard, except as otherwise provided by the state. It can be seen that "household textile products" have been added to the scope of application, and "except for those with other agreements between the supply and demand sides" have been deleted. That is, as long as it is produced and sold within the territory of China, whether it is an agreement between the supply and demand sides or an imported textile product, it must meet the technical requirements of this standard, which is universal and mandatory. Appendix A further clarifies the scope of application of this standard in the catalog of textile products that are not within the scope of this standard, adding "disposable sanitary products", "bags, backpacks, shoes, umbrellas, etc.", "carpets", and changing "decorative hanging fabrics, handicrafts and other decorative small objects" to "fabric handicrafts".
1.2 Definition of textile products for infants and young children
The definition of textile products for infants and young children has been changed from "textile products worn or used by infants and young children aged 24 months and below" in the 03 version standard to "textile products worn or used by infants and young children aged 36 months and below". At the same time, the applicable height in the annotation of Article 5.3 will be changed from "80cm" to "100cm". Compared to the 03 version, the 10th version of the standard has a broader definition of infant and toddler textile products, which is closer to the actual height of infants and toddlers, and also puts forward higher technical requirements for infant and toddler textile products.
1.3 Representation method for product classification and basic safety technical requirements
In Article 4.1 of the 10th edition of the standard, the representation method for product classification has been changed from "A, B, and C codes+textual description" to directly representing the classification method in the form of textual description.
Article 5.2 should be revised as follows: "Textile products for infants and young children should meet Class A requirements, products that come into direct contact with the skin should meet at least the technical requirements of Class B products, and products that do not come into direct contact with the skin should meet at least Class C requirements." The word "at least" has been added. Understanding this change is crucial. The product classification and basic safety technical requirements categories in the 10th edition of the standard are two different concepts. Product classification is a classification of the attributes of textile products based on their ultimate use (Appendix B provides classification examples), while Class A, Class B, and Class C represent technical requirements, and there is no corresponding equivalent relationship between them. However, the 03 version of the standard does not make a clear distinction and is generally understood as a corresponding relationship. As a result, after the implementation of the 10th version of the standard, there have been some confusions in the labeling format of the instructions for use.
1.4 Addition of "4-aminoazobenzene" to carcinogenic aromatic amines
The carcinogenic aromatic amines in Appendix C of the 10th edition of the standard have added "4-aminoazobenzene", and the types of carcinogenic aromatic amines have increased from 23 to 24. Compared to the 03 version, the 10th version of the standard has stricter control over toxic and harmful substances, and also puts forward higher requirements for the capabilities of inspection agencies.
The normative reference document has added GB/T23344, changed GB/T17592.1 to GB/T17592, and added a limit value of ≤ 20mg for decomposable carcinogenic aromatic amines in footnote c of Table 1 /Kg has improved the operability of detecting carcinogenic aromatic amines.
At the same time, specific provisions have been made for the detection of 4-aminoazobenzene in Article 6.8: "Generally, it is first detected according to GB/T17592. When aniline or 1,4-phenylenediamine is detected, it is then detected according to GB /T23344 testing ".
Changes in pH requirements for 1.5
In Table 1 of the 10th edition of the standard, the pH value of Class B products has been relaxed from 4.0~7.5 to 4.0~8.5, which is in line with the actual production situation of China's textile dyeing and finishing industry compared to the requirements of the 03 edition. It fully considers the influence of water quality differences and water resource waste in different regions of China, and to a certain extent reduces the cost of dyeing and finishing washing enterprises.
At the same time, the 10th edition of the standard added "non final products" in footnote a of Table 1, making clearer provisions for products that can be relaxed to 4.0-10.5 for ease of understanding.
1.6 Explanation of color fastness not assessed
Footnote b of Table 1 in the 10th edition of the standard has been changed from "Washing and fading products are not required" to "Non final products, natural colors, and bleached products that require washing and fading processes are not required; traditional hand colored products such as tie dye and wax dye are not required; saliva color fastness is only assessed for children's textile products". At the same time, in Article 5.2, it is added that "curtains and other hanging decorative products are not assessed for their color fastness to sweat stains". This further clarifies that if wash off denim clothing is the final product, color fastness also needs to be assessed.
The 10th edition of the standard has added some situations where color fastness is not assessed, such as hand colored products, natural colors, and bleached products, which better reflect adaptability and pertinence.
In addition, the 10th edition of the standard also made some other changes, such as adjusting some examples in Appendix B, adding Appendix D, and incorporating the content of Note 7.4 into the text.
2 Suggestions
How long is the transition period between the old and new standards? How should the instructions for excessive use be labeled? Is it necessary to indicate the year number in the identification? How to implement the standards during the transition period? At present, there are no specific implementation rules announced. Moreover, different inspection agencies and enterprises have different interpretations of this, which brings some difficulties to enterprises and inspection agencies. Therefore, it is recommended to revise the Implementation Regulations of the Standardization Law of the People's Republic of China as soon as possible or formulate relevant implementation rules for the transition period between new and old standards.
As mentioned earlier, there have been changes in the product classification and representation of basic safety technical requirements in the 10th edition of the standard. However, some of the product standards that have not been updated still use the representation method in the 03 edition of the standard, which has caused difficulties in the labeling of product instructions and the selection of safety technical categories. As per industry standard FZ /T8107-2003 "Single and Clip on Clothing" stipulates in 3.12.7 that "the pH value of finished products is limited to 4.0-7.5 for clothing that comes into direct contact with the skin", and 3.12.8 stipulates that "the pH value of finished products is limited to 4.0-9.0 for clothing that does not come into direct contact with the skin". When clothing complies with GB18401 2010 and FZ/T81007? In 2003, ambiguity arose, leading to different interpretations, such as:
a) If a product is labeled as "GB18401-2010B Class" and "FZ/T81007-2003" in the instructions, and the product classification is not indicated, then the pH value of this product shall be in accordance with FZ /The requirements for T8107-2003 may be 4.0~7.5 or 4.0~9.0. The pH value requirement for GB18401-2010 Class B products is 4.0-8.5. If the pH value test result is 8.0 during supervision and inspection, and strict judgment is made, this product is unqualified; And if the enterprise determines that this product is a textile product that does not come into direct contact with the skin, according to FZ /T8107-2003 specifies a range of 4.0-9.0, combined with the requirements of GB18401-2010 Class B, and the required index should be 4.0-8.5. This product is qualified.
Firstly, labeling "GB18401-2010B Class" is definitely correct, because GB18401? In 2010, there was no requirement to label product classification, and there was no clear definition of product classification. Some clothing products may be textile products that come into direct contact with the skin or textile products that do not come into direct contact with the skin.
b) Another interpretation of similar situations is that it is necessary to label the product classification, that is, to indicate the product category in the label, which can cause trouble in labeling the instructions for use. According to the understanding of the 10th edition of the standard, it is not appropriate to use text for labeling other than "infant and toddler products" for infant and toddler textile products. At present, different inspection agencies have different interpretations of this, which also brings difficulties to textile and clothing enterprises.
In view of the above reasons, I personally suggest that the Standardization Committee and relevant standard setting units provide supplementary explanations on the identification format and selection of judgment indicators after the implementation of GB18401-2010 standard, in order to unify the understanding of this standard by inspection agencies and enterprises. Suggestions can be labeled according to product classification, for example, for infant and toddler textile products: "Basic safety technical requirements: Infant and toddler products"; Textile products that come into direct contact with the skin shall be labeled in the format of "Basic Safety Technical Requirements: Class B" (or Class A); Textile products that do not come into direct contact with the skin can be labeled in the format of "Basic Safety Technical Requirements: Class C" (or Class A or B), or in the format of "Implementation Standard: Product Standard GB18401B Class".
After the implementation of GB18401-2010, when the formaldehyde and pH values specified in the product standards conflict with GB18401-2010 due to changes in expression, they shall be uniformly followed according to GB18401 -Judgment was made in 2010. This not only clarifies the relationship between various standards, facilitates the labeling of product instructions by enterprises, but also avoids quality control by related enterprises such as dyeing and finishing clothing. It is also in line with the original intention of relaxing the pH index when revising GB18401-2010. In addition, when updating product standards in the future, indicators such as formaldehyde, pH value, carcinogenic aromatic amines, and odors can be directly implemented according to the requirements of GB18401 without the need for additional specifications.
3 Conclusion
Compared to the 03 edition, the 10th edition of the National Basic Safety Technical Specification for Textile Products has a wider coverage and stricter control over toxic and harmful substances, fully reflecting the country's emphasis on product quality and safety during the 12th Five Year Plan period. Its implementation will more effectively protect the safety and health of Chinese consumers, guide textile related enterprises to further improve their awareness of quality and environmental protection, advocate low-carbon energy conservation, so as to cope with international trade protection calmly and enhance the competitiveness of Chinese textile and clothing enterprises in the international market. At the same time, standard setting units and supervisory inspection agencies should strengthen the promotion, publicity, and guidance of standards, unify the understanding and application of standards by all parties, and enable new standards to play a better role.
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