The German Consumer Goods Act

TRUE and FALSE

Facts concerning the ban on the use of certain azo dyes according to the German Consumer Goods Act (Bedarfsgegenständeverordnung)

The 2nd amendment to the Consumer Goods Act was passed by of certain azo dyes in consumer goods that come into repeated contact with the skin.

In July 1995 the 4th amendment to this Act was passed in which certain dates for the introduction of the Act were extended.

The scope of the Act was also extended to include certain azo pigments.

In February 1996 the German Department of Health published a method of testing for the prohibited substances in textiles in their Federal Gazette.

An equivalent method for leather has been available in draft from the German Standards Association since April 1996.

The final version will be available early in 1997.

A 5th amendment was approved in November 1996 and should be published in April 1997. lt:

·                  extends the sell-by date for goods already in the shops

·                  sets the analytical detection limit in the consumer good at

·                  30 mg/kg

·                  includes only those pigments which test positive in analytical testing

·                  defines more clearly which groups of consumer goods are affected by this law: clothing (including shoes), bedding, towels, wigs, jewelry, back-packs, baby articles and feminine hygiene products

Azo dyes are the world´s most commonly used dyes, and their use in textile and leather dyeing are only two of many applications.

Many food dyes are also members of the azo dye class.

The German ban affects only a very small number of the azo dyes manufactured today.

Modern dyes and their application are today optimized to reduce the chance of absorption into the body and subsequently breaking down into the corresponding aromatic amines.

The German Act protects the consumer from any potential danger by forbidding those few azo dyes, which could cleave in vivo to release amines known to have some evidence of carcinogenicity.

The German Consumer Goods Act does not cite any specific azo dyes but lists the 20 amines which should not be detected after splitting up of the dye molecule at the azo groups.

These amines are either known carcinogens or are suspected of human carcinogenic potential.

The large number of azo dyes and preparations containing azo dyes that are available make it impossible to prepare a list of banned dyes and keep it up to date.

Lists such as those based on Color Index numbers are also unsatisfactory as they are incomplete and because the composition of dyes can vary depending on the manufacturer.

In future the German authorities will be testing to see whether consumer goods comply with the new Act.

As the dye itself is not a consumer good it will not be tested. The consumer protection requirement is that each article, when analyzed, should not contain any of the 20 listed amines after the dye molecule has been broken down.

For leather the official method is described in the DIN 53316 analytical procedure. According to the method, use of forbidden azo dyes is confirmed if one of the listed amines is found with a concentration in excess of 30 mg/kg (= 30 ppm  = 0.003%).

Special rules apply for the amines 2-naphthylamine and 4-aminodiphenyl, as due to the possibility of false positives, testing cannot confirm their presence unequivocally.

Supplementary information, such as the chemical structure of the dye, is necessary for confirmation.

There are still some dye manufacturers who manufacture and sell azo dyes based on benzamine and its analogues.

As a result the consumer is exposed to unnecessary risk.

Members of the ETAD organization of dye and pigment manufacturers have taken a strong line by supporting the manufacture of dyes that are not based on the 20 listed amines.

We're glad to provide a written confirmation that leather which is dyed for Franz Hoffmann- Feinleder complies with the German Consumer Good Act.