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ZDHC (Zero Discharge of Hazardous Chemicals) published its new Chemical Watchlist for the textile, leather, apparel and footwear sectors in February 2026. It has been generating some concerns in the industry since that time. According to usbcertification.com, the list contains1,673 substances of concern, which were identified following the screening of approximately 5,000 substances. It was designed as an informational tool, in addition to ZDHC’s Manufacturing Restricted Substances List (MRSL).
The Chemical Watchlist was developed in alignment with the EU’s Corporate Sustainability Reporting Directive (CSRD) and Ecodesign for Sustainable Products Regulation (ESPR). CSRD and ESRS require companies to disclose the use and emissions of hazardous substances, including Substances of Concern (SoC). The ESPR introduces mandatory use of a Digital Product Passport, which must include chemical composition data, including SoCs.
The list is positioned as a voluntary, expert-led reference tool to support brands, suppliers, chemical formulators, and other stakeholders across the textile and footwear value chain in identifying and reporting substances of concern and substances of very high concern (SVHC). The Chemical Watchlist does not replace the ZDHC MRSL and does not introduce new compliance requirements, restrictions or testing mandates.
The impact of the Chemical Watchlist extends beyond current reporting cycles. ZDHC states that the list will be kept current through a transparent updating process, evolving in parallel with developments in science, regulation and industry practice. The long-term ambition is to integrate the list within the Roadmap to Zero Programme and enable structured reporting and performance tracking through ZDHC platforms.
This approach is viewed as a strategic step toward transforming chemical transparency from a compliance obligation into a shared, data-driven management practice across the industry.