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entitled 'Formaldehyde In Textiles: While Levels in Clothing Generally 
Appear to Be Low, Allergic Contact Dermatitis Is a Health Issue for 
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Report to Congressional Committees: 

United States Government Accountability Office: 
GAO: 

August 2010: 

Formaldehyde In Textiles: 

While Levels in Clothing Generally Appear to Be Low, Allergic Contact 
Dermatitis Is a Health Issue for Some People: 

GAO-10-875: 

GAO Highlights: 

Highlights of GAO-10-875, a report to congressional committees. 

Why GAO Did This Study: 

Formaldehyde-—one of the most widely produced chemicals in the world—-
is used in many products, including disinfectants, pressed-wood, and 
clothing and other textiles. Exposure to this chemical, which has been 
linked to adverse health effects for more than 30 years, typically 
occurs through inhalation and dermal (skin) contact. Formaldehyde can 
be used to enhance wrinkle resistance in some clothing and textiles, 
especially those made of cotton. The Consumer Product Safety 
Commission reviewed formaldehyde in clothing in the 1980s and 
determined that the levels found did not pose a public health concern. 
At that time, most clothing sold in the United States was made here-—
but the market has changed such that most U.S. clothing is now made in 
other countries. This market change has raised anew questions about 
the levels of formaldehyde in clothing. 

In response to a mandate in the Consumer Product Safety Improvement 
Act of 2008, this report provides information on what is known about 
(1) the health risks of exposure to formaldehyde, particularly from 
clothing, and (2) the levels of formaldehyde in clothing sold in the 
United States. GAO analyzed government reviews and the medical 
literature, as well as studies on levels of formaldehyde in clothing, 
and had a sample of 180 textiles—primarily clothing—tested for 
formaldehyde by an accredited laboratory. While illustrative of 
formaldehyde levels that may be found in clothing, the test results 
from GAO’s sample cannot be projected to all clothing sold in the 
United States. This report contains no recommendations. 

What GAO Found: 

The potential health risks associated with formaldehyde vary, 
depending largely on the means of exposure (e.g., inhalation or dermal 
contact), the concentration of the formaldehyde, and the duration of 
exposure. Inhaled formaldehyde may cause such effects as nausea, 
exacerbation of asthma, and cellular changes that may lead to the 
development of tumors. In fact, comprehensive reviews by the 
Department of Health and Human Services, the Environmental Protection 
Agency, and the World Health Organization have found that chronic 
inhalation exposure to formaldehyde may cause cancer. However, the 
health risk of greatest concern associated with formaldehyde in 
clothing—allergic contact dermatitis—stems from dermal exposure. A 
form of eczema, allergic contact dermatitis affects the immune system 
and produces reactions characterized by rashes, blisters, and flaky, 
dry skin that can itch or burn. Another potential health effect from 
dermal exposure to formaldehyde—irritant contact dermatitis—is also a 
form of eczema and has similar symptoms; however, this condition does 
not affect the immune system. Avoiding clothing containing 
formaldehyde is typically effective at preventing allergic and 
irritant contact dermatitis and relieving symptoms, but doing so can 
be difficult as clothing labels do not identify items treated with or 
containing formaldehyde. Washing clothing before it is worn often 
reduces formaldehyde levels but is not always successful. In some 
cases, avoiding or relieving allergic contact dermatitis requires more 
drastic measures, such as taking medications with potentially serious 
side effects. Finally, consumers may also experience dermal exposure 
to formaldehyde by using some cosmetics and skin care products, such 
as shampoos and sunscreens that contain formaldehyde. 

Comprehensive data on formaldehyde levels in clothing sold in the 
United States are not publicly available. While formaldehyde levels in 
clothing are not regulated in the United States, the apparel industry 
reports that 13 countries have laws or regulations that limit 
formaldehyde levels in clothing. Most of the 180 items GAO had tested 
had formaldehyde levels that were below the most stringent of these 
industry-identified regulatory limits. GAO’s test results are similar 
to those of recent studies of formaldehyde levels in clothing by the 
European Union, New Zealand, and Australia—that is, most items were 
found to meet the most stringent limits. Moreover, government studies 
we reviewed showed a decline in the formaldehyde levels in clothing 
since the 1980s, and the levels reported in these studies are 
generally consistent with the decline in levels reported in the 
medical literature. This decline is associated with the development 
and use of low-formaldehyde technologies (resins) in manufacturing 
clothing, which has been encouraged by such factors as the 
identification of formaldehyde as a probable human carcinogen via 
inhalation; the promulgation of federal regulations protecting workers 
from inhalation exposure to formaldehyde; and limits on formaldehyde 
levels that some U.S. retailers have established for clothing they 
sell. 

View [hyperlink, http://www.gao.gov/products/GAO-10-875] or key 
components. For more information, contact John B. Stephenson at (202) 
512-3841 or stephensonj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Formaldehyde Poses Different Health Risks Depending on the Type and 
Extent of Exposure: 

While Comprehensive Data Are Not Available, Recent Studies Suggest 
That Formaldehyde Levels in Clothing Are Generally Low and Have 
Declined over Time: 

Agency Comments and Our Evaluation: 

Appendix I: Government Reviews of the General Health Effects of 
Exposure to Formaldehyde and Medical Literature on the Health Effects 
of Formaldehyde in Textiles: 

Appendix II: Objectives, Scope, and Methodology: 

Appendix III: Voluntary Labeling Programs: 

Appendix IV: Top Ten Exporters of Clothing to the United States in 
2008: 

Appendix V: Results of Formaldehyde Tests for a Sample of Clothing and 
Bed Linens Sold in the United States: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Ten Items Sold in the United States That Exceeded the Most 
Stringent Regulatory Standards for Formaldehyde Identified by the 
American Apparel and Footwear Association: 

Table 2: Levels of Formaldehyde in Clothing and Other Textiles 
Reported in Government Studies, 1984-2010: 

Table 3: Formaldehyde Limits Set by 14 U.S. Retailers for Clothing and 
Bed Linens: 

Table 4: Examples of Voluntary Labeling Programs: 

Table 5: Information on Items Sold in the United States and Tested for 
Formaldehyde Levels, 2010: 

Abbreviations: 

AATCC test: American Association of Textile Chemists and Colorists 112 
test: 

CPSC: Consumer Product Safety Commission: 

DMDHEU: dimethylol dihydroxy ethylene urea: 

EPA: Environmental Protection Agency: 

HHS: Department of Health and Human Services: 

IARC: International Agency for Research on Cancer: 

ISO: International Organization for Standardization: 

Japanese test: Japanese Law 112 test: 

OSHA: Occupational Safety and Health Administration: 

USDA: Department of Agriculture: 

WHO: World Health Organization: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

August 13, 2010: 

The Honorable Jay Rockefeller:
Chairman:
The Honorable Kay Bailey Hutchison:
Ranking Member:
Committee on Commerce, Science and Transportation:
United States Senate: 

The Honorable Henry A. Waxman:
Chairman:
The Honorable Joe Barton:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives: 

Formaldehyde is a colorless, pungent-smelling chemical well known for 
its use as a preservative and disinfectant in laboratories and 
mortuaries but is also widely used in consumer products such as 
pressed-wood products, glues and adhesives, cosmetics, and clothing 
and other textiles. Some clothing--generally garments made of cotton 
and other natural fibers--is treated with resins[Footnote 1] 
containing formaldehyde primarily to enhance wrinkle resistance. 
Formaldehyde is toxic and has been linked to serious adverse health 
effects, including cancer, and some federal agencies have regulations 
that limit human exposure, which occurs primarily through inhalation 
and dermal (skin) contact. Regarding inhalation exposure, the 
Environmental Protection Agency (EPA) regulates formaldehyde emissions 
to the ambient air from both industrial sources and vehicles under the 
Clean Air Act, and the Department of Labor's Occupational Safety and 
Health Administration (OSHA) has standards in place that limit 
employee exposure to formaldehyde emissions in the workplace. 
Regarding dermal exposure to textiles, formaldehyde levels in clothing 
and other textiles that come into contact with the skin are not 
regulated. The Consumer Product Safety Commission (CPSC), which is 
charged with protecting the public from unreasonable risks of serious 
injury or death from consumer products, including clothing, reviewed 
formaldehyde in clothing sold in the United States in the 1980s and 
found that formaldehyde levels were sufficiently low so as not to be a 
public health concern.[Footnote 2] 

At the time of the CPSC review, most textiles sold in the United 
States were also manufactured in the United States. However, the 
market for textiles has changed significantly in recent years, raising 
questions about what the current levels of formaldehyde in clothing 
are. Currently, most clothing sold in the United States is imported 
from other countries, particularly from China, Vietnam, and other 
countries in Asia, as well as from countries in Central America. In 
2008, for example, nearly 35 percent of clothing imported into the 
United States was manufactured in China, up from about 6 percent in 
2000. Moreover, in contrast with the United States, some countries, 
including China, have established legal limits on the levels of 
formaldehyde that clothing may contain. For example, China and Japan 
have similar restrictions on levels of formaldehyde that may be 
contained in infant and other clothing that comes into direct contact 
with the skin. Further, the level of formaldehyde in clothing depends 
largely on the variability in the way the manufacturing process is 
conducted. For example, formaldehyde levels can vary among the same 
type and make of clothing because of, among other things, differences 
in the type of resin used and the ways it is applied. 

Section 234 of the Consumer Product Safety Improvement Act of 2008 
requires GAO to conduct a study on the use of formaldehyde in the 
manufacturing of textiles and apparel.[Footnote 3] This report 
provides information on what is known about (1) the health risks from 
exposure to formaldehyde, particularly from clothing, and (2) the 
levels of formaldehyde found in clothing sold in the United States. To 
determine what is known about the health risks from exposure to 
formaldehyde, we analyzed comprehensive government reviews of the 
health effects of exposure to formaldehyde and conducted a literature 
review of articles in medical, textile, and environmental journals and 
books published from 1980 through April 2010 (see app. I for more 
information on this research).[Footnote 4] To determine what is known 
about the levels of formaldehyde found in clothing sold in the United 
States, we analyzed information about (1) the use of formaldehyde-
containing resins in clothing, (2) formaldehyde levels in clothing 
reported in government studies, and (3) relevant voluntary labeling 
programs, corporate limits, and regulatory limits for formaldehyde 
levels in clothing in the United States and other countries. Because 
of complexities in obtaining English translations of formaldehyde laws 
and regulations in other countries and confirming their application 
within the context of these countries' legal systems, we relied 
primarily on the American Apparel and Footwear Association for 
information on formaldehyde limits set in other countries, including 
the limits identified as the most stringent.[Footnote 5] In addition, 
using an accredited commercial laboratory, we tested a nonprobability 
sample[Footnote 6] of 180 textile items--primarily clothing (165) and 
some bed linens (15)--purchased from selected U.S. retailers in six 
metropolitan areas: Boston, Chicago, Dallas, Los Angeles, Seattle, and 
Washington, D.C. We selected low-or moderately priced items. We 
compared our test results with the most stringent regulatory limits 
for formaldehyde in clothing and other textiles established in other 
countries, as identified by the American Apparel and Footwear 
Association. The results from testing our nonprobability sample are 
illustrative of formaldehyde levels that may be found in some clothing 
and are not projectable to clothing sold in the United States in 
general. Throughout our review, we consulted with CPSC on our 
methodology and to obtain relevant background information stemming 
from the agency's mission to ensure consumer protection. Appendix II 
provides a more detailed description of our scope and methodology. We 
conducted this performance audit from September 2009 to August 2010 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Formaldehyde--one of the most widely produced and used chemicals in 
the world--is a water-soluble gas often used in a water-based solution 
(aqueous form) as a disinfectant or tissue preservative. In terms of 
toxicity, ingestion by an adult of as little as 1 ounce of a solution 
containing 37 percent formaldehyde has been reported to be lethal. 
[Footnote 7] Formaldehyde is also used in other forms, including 
resins, that combine formaldehyde with other compounds. Aqueous 
formaldehyde and products containing formaldehyde tend to emit some 
formaldehyde into the air. Formaldehyde is also produced naturally in 
the environment and is found in low levels in people and most living 
things. In addition, formaldehyde is a by-product of combustion 
processes, such as wood burning and cigarette smoking. When 
formaldehyde is exposed to air, it begins to break down and dissipate. 

The Department of Health and Human Services (HHS) reports that average 
levels of formaldehyde in outdoor air are often less than 0.01 parts 
of formaldehyde per million parts of air, and the average levels in 
indoor air in homes are often less than 0.04 parts per million. 
[Footnote 8] Major sources of formaldehyde in outdoor air are man-
made, such as power plants, manufacturing facilities, incinerators, 
and automobile exhaust. Formaldehyde levels in outdoor air are often 
found to be higher near some industry facilities and in heavily 
populated urban areas. In addition, people exposed to formaldehyde at 
work--such as medical personnel, embalmers, cabinetmakers, and textile 
plant employees--may be exposed to higher levels of formaldehyde. In 
general, the highest levels of airborne formaldehyde are detected 
indoors, where it can be released from various building materials, 
consumer products, and tobacco smoke. 

Because formaldehyde is highly toxic, it is regulated by various 
federal and state agencies to protect human health and the 
environment.[Footnote 9] For example, EPA lists formaldehyde as a 
hazardous air pollutant under the Clean Air Act and as a hazardous 
waste under the Resource Conservation and Recovery Act. Other 
agencies, such as OSHA and the Department of Housing and Urban 
Development, regulate airborne formaldehyde concentrations in the 
workplace and in manufactured homes, and the Food and Drug 
Administration limits the food-related use of formaldehyde to 
packaging components. In addition, California regulates formaldehyde 
emissions from composite wood products to protect human health from 
airborne exposure to formaldehyde.[Footnote 10] According to an 
official from the California Environmental Protection Agency, the 
agency found that emissions from textiles commonly found in the home, 
such as draperies, dissipate quickly, whereas emissions from composite 
wood products are higher and remain relatively constant over time. 

Formaldehyde-containing resins have been used in clothing and other 
textiles since the mid-1920s primarily to impart durable press 
characteristics to fabrics made from natural fibers, especially plant- 
based fibers such as cotton.[Footnote 11] These resins may also 
provide other easy-care benefits, such as shrink resistance and color 
fastness.[Footnote 12] The use of these resins in cotton clothing and 
other textiles became more prevalent in the 1950s and 1960s to compete 
with the increased use of synthetic fabrics, which often provided 
durable press characteristics. Under certain conditions, formaldehyde- 
containing resins may chemically degrade and release (off gas) free 
formaldehyde, including when exposed to high temperature and humidity. 

The level of formaldehyde in clothing identified by testing and the 
level of formaldehyde that may be emitted by that clothing into the 
air will vary under different conditions--especially heat and 
humidity--and the test method used. Formaldehyde release mechanisms 
are numerous and complex, and emissions of formaldehyde from fabrics 
are much lower than the levels found in the fabrics by testing. 
Several analytical tests may be used to identify the levels of 
formaldehyde in clothing and other textiles. Test results are 
generally expressed as micrograms of formaldehyde per gram of fabric--
typically either as microgram per gram or as parts per million. 

The two analytical tests now commonly used in the textile industry to 
identify levels of formaldehyde in clothing and textiles are the 
Japanese Industrial Standard L 1041 test, also known as the Japanese 
Law 112 test (Japanese test), and the American Association of Textile 
Chemists and Colorists 112 test (AATCC test).[Footnote 13] The 
Japanese test was developed to measure the amount of formaldehyde that 
may be released by clothing and other textiles that may come into 
contact with the skin, and the AATCC test was developed to measure the 
amount of formaldehyde that may be released from clothing and other 
textiles during extended storage or hot and humid conditions.[Footnote 
14] Because of different testing specifications, as well as variables 
related to the particular formaldehyde resins used, formaldehyde 
levels measured by the two tests are not comparable, and the results 
from the Japanese test cannot be used to predict what the results 
would be under the AATCC test and vice versa.[Footnote 15] Regarding 
the tests performed on our sample of clothing and bed linens, the 
laboratory tested all of them using the Japanese test and a subset of 
them using the AATCC test. According to the American Apparel and 
Footwear Association, the Japanese test is used to determine whether 
formaldehyde levels in clothing are consistent with levels cited in 
international regulations. In addition, most of the U.S. retailers 
that provided us with information on internal corporate limits use the 
Japanese test or its equivalent. Further, the Japanese test was more 
frequently used in the studies we identified that conducted 
formaldehyde testing in clothing and other textiles. 

The American Apparel and Footwear Association has identified the most 
stringent regulatory limits for formaldehyde in clothing and home 
textiles in other countries for its members that may wish to sell 
their products internationally.[Footnote 16] The most stringent 
formaldehyde limits identified use the Japanese (or equivalent) test 
as a basis for measurement and are: 

* not detectable (defined as less than 20 parts per million) for 
products intended for children younger than 3 years of age, 

* less than 75 parts per million for products that come into direct 
contact with the skin for children who are 3 years of age and older 
and for adults, and: 

* less than 300 parts per million for products that do not come into 
direct contact with the skin--e.g., outerwear--for children who are 3 
years of age and older and for adults. 

Some countries do not limit formaldehyde levels in clothing but 
require disclosure in labels if formaldehyde levels exceed specified 
amounts.[Footnote 17] Further, some countries and private entities 
offer "eco labels" for clothing and other textiles, if their 
formaldehyde levels--as well as levels of other chemicals--are within 
specified ranges. Appendix III provides more information on voluntary 
labeling programs. Finally, while the United States does not legally 
limit formaldehyde levels in clothing, some U.S. retailers have set 
internal corporate limits on formaldehyde in clothing. 

In the mid-1980s, most of the clothing sold in the United States was 
also manufactured in the United States and its territories. However, 
imports of clothing and other textiles from other countries now make 
up a majority of U.S. sales. Although textile industries are dispersed 
throughout the world, China is now the world's largest producer and 
exporter of clothing and textiles. Much of China's growth occurred 
during the 10-year phaseout of textile quotas under the 1995 World 
Trade Organization Agreement on Textiles and Clothing, which was 
completed on January 1, 2005.[Footnote 18] As of 2008, China accounted 
for the largest share of total U.S. clothing imports--34.3 percent, an 
increase from 6.5 percent in 1999. Vietnam and Bangladesh rank second 
and third at 6.7 percent and 6.3 percent, respectively. Appendix IV 
provides additional information on the 10 countries that exported the 
most clothing to the United States in 2008. 

Formaldehyde Poses Different Health Risks Depending on the Type and 
Extent of Exposure: 

Key government reviews on the health effects of exposure to 
formaldehyde, including those conducted by EPA, HHS, and the World 
Health Organization (WHO), have concluded that chronic inhalation 
exposure to formaldehyde may cause cancer. Regarding exposure to 
formaldehyde in clothing, the health risk of greatest concern 
identified in key government reviews and in the medical literature is 
allergic contact dermatitis. 

Key Government Reviews Have Concluded That Chronic Inhalation Exposure 
to Formaldehyde May Cause Cancer: 

The potential health risks from exposure to formaldehyde vary 
depending on the means of exposure (inhalation, dermal, ingestion, or 
eye contact), the concentration of formaldehyde, and the duration of 
exposure, among other factors. Inhaled formaldehyde may cause such 
effects as (1) discomfort or nausea stemming from the chemical's 
pungent odor; (2) irritation of the eyes, nose, and throat; (3) 
exacerbation of asthma; and (4) changes at the cellular level that may 
lead to the development of tumors. In fact, several comprehensive 
government reviews of the health risks of exposure to formaldehyde 
have found that chronic inhalation exposure to formaldehyde may cause 
cancer. 

Concerns about the health risks of exposure to formaldehyde were 
heightened in 1979 when the Chemical Industry Institute of Toxicology 
[Footnote 19] reported that formaldehyde caused nasal cancer in 
laboratory rats. Since then, government and industry entities have 
extensively studied the potential human health risks of inhalation 
exposure to this commonly used chemical. Concerns about formaldehyde 
are based on its cancer-causing potential in humans as well as its 
irritant properties. Research efforts on inhalation exposure have 
focused on indoor air levels of formaldehyde, where concentrations are 
known to be higher, and in particular on exposure in occupational 
settings. These research efforts include long-term epidemiological 
studies conducted on workplace exposure. For example, the largest 
study to date was conducted by the National Cancer Institute, which 
has tracked close to 26,000 workers employed in 10 different 
formaldehyde-producing or -using plants since the 1960s; the latest 
update to this study was published in 2009. Similarly, HHS's National 
Institute for Occupational Safety and Health has studied about 11,000 
textile workers exposed to formaldehyde in the workplace. These 
studies have suggested that formaldehyde exposure is associated with 
nasopharyngeal cancer and possibly with cancers of the hematopoietic 
and lymphatic systems, particularly myeloid leukemia.[Footnote 20] 

Based on these and other studies, at least three government entities-- 
EPA, HHS, and WHO--have conducted comprehensive reviews of the health 
effects of formaldehyde. For example, in 2005, the HHS's National 
Toxicology Program[Footnote 21] concluded that chronically inhaled 
formaldehyde is reasonably anticipated to be a human carcinogen; the 
agency is currently considering upgrading this designation to "known 
to be a human carcinogen."[Footnote 22] Similarly, beginning in 1987, 
EPA classified inhaled formaldehyde as a probable human 
carcinogen[Footnote 23] and in June 2010 released a revised draft 
assessment classifying it as a known human carcinogen.[Footnote 24] 
The draft EPA assessment is undergoing a review by the National 
Academies,[Footnote 25] one of several key steps the agency must take 
prior to finalizing the assessment. In addition, in 2006, WHO's 
International Agency for Research on Cancer (IARC) reclassified 
formaldehyde from "probably carcinogenic to humans," a classification 
based on its 1995 assessment, to "carcinogenic to humans."[Footnote 
26] For the 2006 classification, IARC found sufficient evidence that 
formaldehyde causes nasopharyngeal cancer in humans, limited evidence 
for cancer of the nasal cavity and paranasal sinuses, and strong but 
not sufficient evidence for leukemia. In 2009, IARC's Cancer Monograph 
Working Group determined on the basis of additional epidemiological 
studies that there was sufficient evidence to associate formaldehyde 
exposure with leukemia.[Footnote 27] This finding will be published in 
an upcoming IARC monograph. 

Most studies supporting a link between exposure to formaldehyde and an 
increased risk of cancer studied workers exposed to formaldehyde 
occupationally, rather than people exposed to formaldehyde in consumer 
products, although people may be exposed to formaldehyde in consumer 
goods, such as pressed-wood products and textiles, that may "off gas" 
formaldehyde indoors. While EPA is required to develop regulations 
establishing standards for emissions of formaldehyde from hardwood 
plywood, medium-density fiberboard, and particleboard under July 2010 
amendments to the Toxic Substances Control Act, the comprehensive 
government studies we reviewed do not indicate that formaldehyde 
levels in clothing present an inhalation health risk to consumers. 

The Health Risk of Greatest Concern Associated with Dermal Exposure to 
Formaldehyde in Clothing Is Allergic Contact Dermatitis: 

Regarding exposure to formaldehyde in clothing, CPSC officials said 
that, on the basis of research the agency conducted in the 1980s, 
[Footnote 28] (1) there were no data indicating that formaldehyde in 
clothing and other textiles could penetrate the skin and cause cancer 
and (2) levels of formaldehyde found in clothing did not pose an acute 
or chronic health hazard to consumers. As a result, CPSC concluded 
that a regulatory standard was not needed for levels of formaldehyde 
in clothing and other textiles or for emissions of formaldehyde from 
these items. Further, the United States has no other legal limit on 
the level of formaldehyde that may be found in clothing and other 
textiles. 

Based on our review of the medical literature, the health risk of 
greatest concern associated with formaldehyde in clothing--allergic 
contact dermatitis--stems from dermal exposure.[Footnote 29] A form of 
eczema, allergic contact dermatitis produces reactions characterized 
by rashes, discoloration (particularly redness), swelling, blisters, 
scaling, and flaky dry skin that can itch or burn. These reactions are 
often very painful and can last indefinitely if left untreated. The 
reactions can be exacerbated by heat, humidity, friction, and 
perspiration and are usually worse where clothing fits closely. In 
some cases, repeated scratching of the affected area can lead to 
patches of tough, leathery skin. Allergic contact dermatitis also 
affects the immune system. Another potential health effect from dermal 
exposure to formaldehyde in clothing--irritant contact dermatitis--is 
also a form of eczema and has similar symptoms; however, this 
condition does not affect the immune system. 

Formaldehyde is classified as a "strong sensitizer"--a substance that 
can cause hypersensitivity through recurring or prolonged contact. 
According to the medical literature, people with allergic contact 
dermatitis caused by contact with formaldehyde in clothing have 
generally become hypersensitive to the chemical through previous 
exposure. The test used to determine whether an individual has 
allergic contact dermatitis does not identify the level of 
formaldehyde in clothing that would trigger this condition. Although 
the estimates vary widely, the medical literature suggests that the 
amount of formaldehyde in clothing needed to trigger an allergic 
contact dermatitis reaction in sensitized individuals can be as little 
as 30 parts per million. The amount of formaldehyde in clothing that 
would cause a reaction is an area needing further research, according 
to a 2009 medical journal article by experts on contact dermatitis. 
[Footnote 30] 

Some of the medical literature has estimated the number of people with 
allergic and irritant contact dermatitis caused by dermal exposure to 
formaldehyde. This literature focuses on subpopulations of patients-- 
those with eczema--and therefore the results cannot be generalized to 
the rest of the population. For example, one study reported that 9.2 
percent of patients suspected of having contact dermatitis tested 
positive to a diagnostic skin test--called a patch test--that applied 
a 1 percent formaldehyde solution to the skin to test for any dermal 
reaction. Other studies estimate that between 1.2 percent and 2.3 
percent of people with eczema have dermatitis related to formaldehyde 
in their clothing. Some of the medical literature suggests that 
allergic contact dermatitis may be underreported because medical 
practitioners might not distinguish it from cases of dermatitis with 
other causes, because of differences in how patch testing is conducted 
to determine dermatitis, and because some individuals may attempt to 
treat the condition themselves without seeking medical attention or 
are reluctant to make the number of visits to the doctor necessary to 
make a reliable diagnosis. 

Avoiding clothing containing formaldehyde is typically effective at 
preventing allergic or irritant contact dermatitis and at relieving 
symptoms, but doing so may be difficult because labels for clothing 
sold in the United States generally do not provide information on 
formaldehyde content or on whether the clothing item was treated with 
formaldehyde. One dermatologist with whom we spoke published an 
article that identifies some clothing companies that report using 
little or no formaldehyde in their clothing.[Footnote 31] Also, a 
number of medical articles recommend that patients allergic to 
formaldehyde wash articles of clothing before wearing them to reduce 
the level of formaldehyde to which they may be exposed. The success of 
this technique in limiting exposure to formaldehyde in clothing may 
vary, however. For example, studies conducted by the Department of 
Agriculture (USDA) Agricultural Research Service report that the 
effect of laundering on formaldehyde levels depends on the type of 
resin that is applied to the clothing as well as on other factors, 
such as the alkalinity and hardness of the water and whether bleach is 
used. Other studies report that while formaldehyde levels may decline 
initially after washing, the levels may start increasing again after 
multiple washes. One publication explains that while washing clothing 
does remove some formaldehyde, levels may increase again over time as 
the resin is broken down by, among other things, washing and ironing. 
[Footnote 32] Additionally, certain clothing items, such as hats, are 
generally not washed before being worn. 

In some cases, more drastic measures may be necessary to avoid 
allergic contact dermatitis. Some researchers suggest that some 
patients may need to change occupations or job responsibilities to 
avoid contact with formaldehyde-containing products. If wearing 
clothing with formaldehyde cannot be avoided, some researchers suggest 
wearing synthetic or silk undergarments to act as a barrier between 
the skin and the clothing. When avoidance is not feasible or does not 
sufficiently relieve symptoms for those with allergic contact 
dermatitis, other treatment options include strong oral or topical 
medications, including immunosuppressive agents that may have serious 
side effects. Topical medications should be used with caution because 
some of these medications may actually contain formaldehyde, which 
could potentially perpetuate or worsen the reaction. Finally, we note 
that consumers may also experience dermal exposure to formaldehyde by 
using some cosmetics and skin care products, such as some shampoos and 
sunscreens that contain formaldehyde. 

While Comprehensive Data Are Not Available, Recent Studies Suggest 
That Formaldehyde Levels in Clothing Are Generally Low and Have 
Declined over Time: 

In the absence of U.S. regulation of formaldehyde levels in clothing, 
and associated compliance testing, comprehensive data on the levels of 
formaldehyde in clothing sold in the United States are not publicly 
available.[Footnote 33] Tests conducted by an accredited commercial 
laboratory of 180 items we purchased in stores across the country 
indicate that formaldehyde levels in most of the items are low or not 
detectable. Moreover, these test results indicate that the levels of 
formaldehyde found in most of these items would meet the most 
stringent regulatory standards set by other countries as identified by 
the American Apparel and Footwear Association: not detectable in 
clothing and other items for infants and toddlers younger than 3 years 
of age and less than 75 parts per million for clothing and other items 
that come into direct contact with the skin for adults and for 
children 3 years of age and older.[Footnote 34] However, 10 of the 
items exceeded these limits, with formaldehyde levels ranging from 
75.4 to 206.1 parts per million. As table 1 shows, nine of these items 
exceeded the limits for adults and for children 3 years of age and 
older, and one item--a sheet for a child's crib--exceeded the limit 
for infants and toddlers younger than 3 years of age as well as that 
for adults and for children 3 years of age and older. More than half 
of the items we had tested that exceeded these limits were labeled as 
having fabric performance characteristics related to durable press, 
which may indicate the use of resins that contain formaldehyde and can 
alert consumers who wish to avoid formaldehyde in clothing.[Footnote 
35] Both domestic and imported clothing and bed linens had 
formaldehyde levels that exceeded the limits identified by the apparel 
industry. Appendix V provides more complete information on the items 
we had tested. 

Table 1: Ten Items Sold in the United States That Exceeded the Most 
Stringent Regulatory Standards for Formaldehyde Identified by the 
American Apparel and Footwear Association: 

Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free; 
Country identified on label: China; 
Target customer: Men; 
Formaldehyde level in parts per million[A]: 206.1. 

Item type: Hat; 
Fiber content identified on label: 100% cotton exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[A]: 192.6. 

Item type: Bed linens (pillow cases); 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
Soft finish, easy care; 
Country identified on label: Bahrain; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[A]: 189.6. 

Item type: Khakis; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: No 
iron, permanent crease; 
Country identified on label: India; 
Target customer: Men; 
Formaldehyde level in parts per million[A]: 169.6. 

Item type: Dress shirt; 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[A]: 95.1. 

Item type: Bed linens (pillow cases); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free, easy care, no ironing needed, eco-friendly; 
Country identified on label: USA; 
fabric imported from Pakistan; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[A]: 93.8. 

Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Noniron; 
Country identified on label: Indonesia; 
Target customer: Men; 
Formaldehyde level in parts per million[A]: 92.6. 

Item type: Bed linens (pillow cases); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free performance; 
Country identified on label: Pakistan; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[A]: 89.3. 

Item type: Bed linens (crib sheet); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Preshrunk; 
Country identified on label: Thailand; 
Target customer: Infants/toddlers[B]; 
Formaldehyde level in parts per million[A]: 85.4. 

Item type: U.S. military combat uniform pants; 
Fiber content identified on label: 50% cotton, 50% nylon; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Women; 
Formaldehyde level in parts per million[A]: 75.4. 

Source: GAO analysis of information provided on items' labels or 
packaging and test data from an accredited commercial laboratory. 

[A] These formaldehyde levels were determined using the Japanese test. 

[B] Infants/toddlers refers to children younger than 3 years of age. 

[End of table] 

In 2007, the European Union and New Zealand government conducted 
studies of formaldehyde levels in clothing using methodologies similar 
to ours and also found that most clothing items tested had levels of 
formaldehyde that were low or not detectable.[Footnote 36],[Footnote 
37] Specifically, the European Union found that 212 of 221 items 
tested either had formaldehyde levels below 75 parts per million for 
adults and older children or levels that were not detectable for 
infants. Of the 9 items that exceeded these levels, 5 were either 
dress shirts labeled as "easy care" or T-shirts. Moreover, our 
analysis of the New Zealand government study showed that 96 of 99 
items tested had formaldehyde levels below 75 parts per million; the 3 
exceptions were men's dress or casual pants. A more limited study of 
10 clothing items, conducted in 2007 by the Australian government, 
reported that all 10 items had formaldehyde levels that were not 
detectable.[Footnote 38] These studies, as well as our own test 
results, provide important data on levels of formaldehyde that may be 
found in clothing, but these data cannot be projected to clothing in 
general. 

Regarding the decline in levels of formaldehyde in clothing over time, 
government studies we reviewed have reported decreasing levels since 
the 1960s. While researchers have used various test methods in the 
past, which has limited comparisons of formaldehyde levels in clothing 
over time, the available data on formaldehyde levels in items tested 
show a decline over time. For example, the USDA Agricultural Research 
Service reported that in the early 1960s formaldehyde levels in 
clothing were found to be generally above 3,000 parts per million 
using the AATCC test.[Footnote 39] However, tests conducted in the 
early 1980s by the textile industry showed that formaldehyde levels in 
clothing were generally below 500 parts per million using the AATCC 
test. Further, tests conducted by government entities in Australia, 
Denmark, the European Union, Finland, New Zealand, and the United 
States from 1984 to 2010--more often using the Japanese test--show 
that the percentage of items with formaldehyde levels greater than 100 
parts per million has generally declined (see table 2). For example, 
although in 1985 67 percent of items tested by CPSC[Footnote 40] had 
levels of formaldehyde above 100 parts per million using the Japanese 
test, studies since 2003 have shown that 2 percent or less of the 
items tested using the Japanese test had formaldehyde levels above 100 
parts per million. Similarly, the maximum formaldehyde level 
identified in any item in each study has generally declined. 

Table 2: Levels of Formaldehyde in Clothing and Other Textiles 
Reported in Government Studies, 1984-2010: 

Source: CPSC[B]; 
Year tested: 1984-1985; 
Type of items tested: Clothing and bed linens; 
Number of items tested: 12; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 67%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: 92%; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 736.6; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: 2,897. 

Source: Tampere Regional Institute of Occupational Health, Finland; 
Year tested: 1986-1987; 
Type of items tested: Clothing, home textiles, and cotton fabrics; 
Number of items tested: 20; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 50%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: 90%; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 855; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: 1,680. 

Source: Tampere Regional Institute of Occupational Health, Finland; 
Year tested: 1987-1994; 
Type of items tested: Fabrics, textiles; 
Number of items tested: 144; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 11%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: [C]; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 2,000; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: [C]. 

Source: Finnish Customs Laboratory; 
Year tested: 1988; 
Type of items tested: Imported textiles; 
Number of items tested: 2,719; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 12%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: [C]; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 2,200; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: [C]. 

Source: Finnish Customs Laboratory; 
Year tested: 1989; 
Type of items tested: Imported textiles; 
Number of items tested: 1,922; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 7%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: [C]; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 1,050; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: [C]. 

Source: Finnish Customs Laboratory; 
Year tested: 1990; 
Type of items tested: Imported textiles; 
Number of items tested: 1,547; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 11%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: [C]; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 1,500; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: [C]. 

Source: Finnish Customs Laboratory; 
Year tested: 1991; 
Type of items tested: Imported textiles; 
Number of items tested: 2,173; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 9%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: [C]; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 805; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: [C]. 

Source: Finnish Customs Laboratory; 
Year tested: 1992; 
Type of items tested: Imported textiles; 
Number of items tested: 1,407; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 10%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: [C]; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 1,319; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: [C]. 

Source: Finnish Customs Laboratory; 
Year tested: 1993; 
Type of items tested: Imported textiles; 
Number of items tested: 1,680; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 5%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: [C]; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 643; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: [C]. 

Source: Danish Ministry of Environment and Energy; 
Year tested: 2003[D]; 
Type of items tested: Clothing and home textiles; 
Number of items tested: 10; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 0; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: [C]; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 82; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: [C]. 

Source: New Zealand Ministry of Consumer Affairs; 
Year tested: 2007; 
Type of items tested: Clothing, home textiles, and footwear; 
Number of items tested: 99; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 2%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: [C]; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 250; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: [C]. 

Source: Australian Competition and Consumer Commission; 
Year tested: 2007; 
Type of items tested: Clothing; 
Number of items tested: 10; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 0; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: 0; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: Not detectable; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: Not detectable. 

Source: European Union; 
Year tested: 2007; 
Type of items tested: Clothing and home textiles; 
Number of items tested: 221 items (Japanese test); 
127 items (AATCC test); 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 1%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: 9%; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 162.5; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: 397.3. 

Source: GAO; 
Year tested: 2010; 
Type of items tested: Clothing and bed linens; 
Number of items tested: 180 items (Japanese test); 
21 items (AATCC test); 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: Japanese test[A]: 2%; 
Percentage of items tested with greater than 100 parts per million of 
formaldehyde: AATCC test[A]: 10%; 
Maximum level of formaldehyde identified in any item (parts per 
million): Japanese test[A]: 206.1; 
Maximum level of formaldehyde identified in any item (parts per 
million): AATCC test[A]: 550.7. 

Sources: Government-sponsored or -supported studies and GAO analysis 
of test data from an accredited commercial laboratory. 

[A] Or an equivalent test method. 

[B] CPSC-sponsored study tested a subset (12 items) of its full sample 
using the Japanese and AATCC tests. The entire sample of 180 clothing 
and bed linens was tested using a proprietary method developed by the 
Department of Energy's Oak Ridge National Laboratory, which conducted 
the testing. Based on this test method, 14 percent of the items had 
more than 100 parts per million of formaldehyde, and the maximum 
formaldehyde level identified in an item was 940.2 parts per million. 

[C] Only the Japanese or Japanese-equivalent tests were used in this 
study. 

[D] This is the year the report was published. 

[End of table] 

The levels of formaldehyde found in the these studies are generally 
consistent with information reported since the 1980s in the medical 
literature and trade publications that documents a decline in 
formaldehyde levels in clothing since that time. This decline is 
associated with the development and use of low-formaldehyde resins in 
manufacturing clothing, which has been encouraged by such key factors 
as the following: (1) the identification of formaldehyde as a probable 
human carcinogen via inhalation and the promulgation of regulations by 
OSHA to protect workers, such as those in textile factories, from 
exposure to formaldehyde; (2) legal limits on the levels of 
formaldehyde in clothing and other textiles adopted in other 
countries; (3) limits on formaldehyde levels that some U.S. retailers 
have established for clothing they sell; and (4) the textile 
industry's development of improved resins that provide durable press 
characteristics but release less formaldehyde. 

More specifically, as discussed earlier, formaldehyde was classified 
as a probable human carcinogen in the 1980s based on animal and human 
studies showing that airborne formaldehyde exposure is associated with 
certain types of cancer. In 1987 and 1992, OSHA decreased the 
permissible airborne exposure level of formaldehyde in the workplace. 
The current OSHA regulation, among other things, limits airborne 
exposure to 0.75 parts of formaldehyde per million parts of air. 
[Footnote 41] While this regulation primarily addresses the airborne 
concentration of formaldehyde to which workers--such as those in 
textile factories--may be exposed, several government studies and the 
medical literature have noted that OSHA regulations have encouraged 
lower formaldehyde levels in clothing and other textiles. Information 
provided in a Finnish Regional Institute of Occupational Health study 
illustrates the relationship between the levels of formaldehyde being 
applied to textiles in the workplace and airborne formaldehyde 
emissions in the factory. The Finnish study reported that formaldehyde 
levels in textiles should be under 200 parts per million[Footnote 42] 
to ensure airborne formaldehyde emission levels in factories remain 
below 1 part per million under adverse conditions such as low 
ventilation and high humidity.[Footnote 43] 

Another factor that may have encouraged the use of lower levels of 
formaldehyde in clothing is the adoption in other countries of legal 
limits on formaldehyde in clothing and textiles and on the airborne 
levels of formaldehyde in the workplace. For example, according to 
HHS's National Institute for Occupational Safety and Health, over 20 
countries have established occupational exposure limits to protect 
workers, including those in the textile industry.[Footnote 44] In 
addition, the European Union's European Scientific Committee on 
Occupational Exposure Limits has issued provisional occupational 
exposure limits for formaldehyde. Further, according to the American 
Apparel and Footwear Association, 13 countries regulate the level of 
formaldehyde in clothing.[Footnote 45] Another factor that may limit 
formaldehyde levels in clothing is the use of voluntary labeling 
programs such as the Oeko-Tex® Standard 100 label.[Footnote 46] Such 
labels may be displayed by clothing and other textile items that meet 
certain limits on formaldehyde and other substances. Appendix III 
provides more information on voluntary labeling programs. 

In addition, while there are no legal limits on the levels of 
formaldehyde in clothing in the United States, some U.S. retailers 
have established their own corporate limits on formaldehyde in 
clothing and bed linens. These corporate formaldehyde limits are 
generally considered proprietary, although some may be disclosed upon 
request. We obtained information on corporate limits for formaldehyde 
in clothing established by 14 U.S.-based retailers.[Footnote 47] Many 
of these limits were set within the last 10 years, although one was 
set as early as 1995. In some cases, the limits established by 
retailers apply only to private store brands and not to national 
brands, some of which may establish their own limits. Some of the 14 
retailers told us they review regulations adopted in other countries 
to inform their own corporate limits or to comply with regulations in 
countries where they operate. 

Table 3 shows the corporate limits for formaldehyde in clothing and 
bed linens sold in the United States that we obtained from 14 
retailers. The retailers' limits vary both by age and item category. 
For example, a retailer may have limits for clothing and bed linens 
for infants and toddlers but not for clothing or bed linens for adults. 

Table 3: Formaldehyde Limits Set by 14 U.S. Retailers for Clothing and 
Bed Linens: 

Formaldehyde limits[A,B]: None; 
Number of retailers reporting formaldehyde limits, by category: 
Clothing for infants/toddlers: 0; 
Bed linens for infants/toddlers: 1; 
Clothing for children: 0; 
Bed linens for children: 1; 
Clothing for adults: 3; 
Bed linens for adults: 3. 

Formaldehyde limits[A,B]: less than 250 parts per million; 
Number of retailers reporting formaldehyde limits, by category: 
Clothing for infants/toddlers: 0; 
Bed linens for infants/toddlers: 1; 
Clothing for children: 0; 
Bed linens for children: 1; 
Clothing for adults: 0; 
Bed linens for adults: 1. 

Formaldehyde limits[A,B]: less than 200 parts per million[C]; 
Number of retailers reporting formaldehyde limits, by category: 
Clothing for infants/toddlers: 1; 
Bed linens for infants/toddlers: 1; 
Clothing for children: 1; 
Bed linens for children: 1; 
Clothing for adults: 1; 
Bed linens for adults: 2. 

Formaldehyde limits[A,B]: less than 150 parts per million; 
Clothing for infants/toddlers: 0; 
Bed linens for infants/toddlers: 1; 
Clothing for children: 0; 
Bed linens for children: 1; 
Clothing for adults: 0; 
Bed linens for adults: 1[C]. 

Formaldehyde limits[A,B]: less than 100 parts per million; 
Number of retailers reporting formaldehyde limits, by category: 
Clothing for infants/toddlers: 0; 
Bed linens for infants/toddlers: 0; 
Clothing for children: 1; 
Bed linens for children: 1; 
Clothing for adults: 2; 
Bed linens for adults: 1. 

Formaldehyde limits[A,B]: less than 75 parts per million; 
Number of retailers reporting formaldehyde limits, by category: 
Clothing for infants/toddlers: 2; 
Bed linens for infants/toddlers: 4; 
Clothing for children: 11[D]; 
Bed linens for children: 9[D]; 
Clothing for adults: 8[D]; 
Bed linens for adults: 6[C]. 

Formaldehyde limits[A,B]: less than 20 parts per million; 
Number of retailers reporting formaldehyde limits, by category: 
Clothing for infants/toddlers: 11[C]; 
Bed linens for infants/toddlers: 6[D]; 
Clothing for children: 1; 
Bed linens for children: 0; 
Clothing for adults: 0; 
Bed linens for adults: 0. 

Formaldehyde limits[A,B]: Number of retailers reporting limits; 
Number of retailers reporting formaldehyde limits, by category: 
Clothing for infants/toddlers: 14; 
Bed linens for infants/toddlers: 14; 
Clothing for children: 14; 
Bed linens for children: 14; 
Clothing for adults: 14; 
Bed linens for adults: 14. 

Source: GAO analysis of data from 14 U.S. retailers. 

Notes: Retailers' age designations for infants/toddlers and children 
vary. 

[A] Unless otherwise noted, retailers reported using the Japanese test. 

[B] Formaldehyde limits for clothing are applicable to clothing that 
comes in direct contact with the skin. 

[C] One retailer determines compliance with this limit using the AATCC 
test. 

[D] Two retailers determine compliance with this limit using the AATCC 
test. 

[End of table] 

However, retailers may use their corporate limits more as guidelines 
than as absolute compliance limits. For example, one retailer told us 
that when its test results for formaldehyde content exceed corporate 
limits, the company may conduct additional testing to determine the 
extent of the problem to inform its response. In contrast, this 
retailer told us that if a single sample exceeds a U.S. regulatory 
standard--for example, for lead in clothing--the company rejects the 
entire shipment. Another retailer told us the company complies with 
Japan's formaldehyde limit--the most stringent--when selling products 
in Japan but has established a less stringent limit for clothing sold 
in the United States. 

Finally, another factor that may have contributed to lower levels of 
formaldehyde in clothing, according to government and trade 
publications, is industry actions to address concerns about some 
formaldehyde-containing resins. The older resins, such as urea 
formaldehyde and melamine formaldehyde, impart durable press 
characteristics to clothing but also tend to release more formaldehyde 
during the manufacture, storage, retailing, and use of fabrics and 
clothing than newer resins because they are less chemically stable. In 
addition, the older resins can also stiffen fabric, degrade after 
repeated washing, damage fabrics if chlorine bleach is used, and cause 
the fabrics to emit a noticeable odor. The development and use of 
newer resins in clothing production to impart durable press 
characteristics have addressed some of these issues as well as reduced 
the level of formaldehyde in clothing. These newer resins, also called 
cross-linking agents, became widely used in the 1980s. For example, 
dimethylol dihydroxy ethylene urea (DMDHEU) and its derivatives are 
reported to be the most commonly used resins today. Fabrics finished 
with DMDHEU may release moderate amounts of formaldehyde but can be 
modified to release low to ultra-low levels.[Footnote 48] Newer resins 
that do not contain formaldehyde have also been developed, but they 
are not as widely used because of their higher cost; some may also 
have negative effects on fabrics. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Chairman, CPSC, for review 
and comment. CPSC provided technical comments, which we have 
incorporated, as appropriate. 

We are sending copies of this report to the appropriate congressional 
committees; the Chairman, CPSC; and other interested parties. The 
report is also available at no charge on the GAO Web site at 
[hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or stephensonj@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix VI. 

Signed by: 

John B. Stephenson: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Government Reviews of the General Health Effects of 
Exposure to Formaldehyde and Medical Literature on the Health Effects 
of Formaldehyde in Textiles: 

Following is more detailed information on the sources we used in our 
analysis to determine what is known about the health effects of 
exposure to formaldehyde. 

Aalto-Korte, K., R. Jolanki, and T. Estlander. "Formaldehyde-Negative 
Allergic Contact Dermatitis from Melamine-Formaldehyde Resin." Contact 
Dermatitis, vol. 49, no. 4 (2003). 

Andersen, Klaus E. and Howard I. Maibach. "Multiple Application 
Delayed Onset Contact Urticaria: Possible Relation to Certain Unusual 
Formalin and Textile Reactions?" Contact Dermatitis, vol. 10, no. 4 
(1984). 

Andersen, Klaus E. and Knud Hamann. "Cost Benefit of Patch Testing 
with Textile Finish Resins." Contact Dermatitis, vol. 8, no. 1 (1982). 

Australia Department of Health and Ageing. National Industrial 
Chemicals Notification and Assessment Scheme, Priority Existing 
Chemical Assessment Report No. 28, Formaldehyde. Sydney, Australia, 
2006. 

Belsito, Donald V. "What's New in Contact Dermatitis: Textile 
Dermatitis." American Journal of Contact Dermatitis, vol. 4, no. 4 
(1993). 

Bracamonte, B.G., F.J. Ortiz de Frutos, and L.I. Diez. "Occupational 
Allergic Contact Dermatitis due to Formaldehyde and Textile Finish 
Resins." Contact Dermatitis, vol. 33, no. 2 (1995). 

Carlson, Ryan M., Mary C. Smith, and Susan T. Nedorost. "Diagnosis and 
Treatment of Dermatitis Due to Formaldehyde Resins in Clothing." 
Dermatitis, vol. 15, no. 4 (2004). 

Cockayne, Sarah E., Andrew J.G. McDonagh, and David J. Gawkrodger. 
"Occupational Allergic Contact Dermatitis from Formaldehyde Resin in 
Clothing." Contact Dermatitis, vol. 44, no. 2 (2001). 

Cronin, Etain. Contact Dermatitis, New York City, New York: Churchill 
Livingstone, 1980. 

De Groot, Anton C., et al. "Formaldehyde-Releasers: Relationship to 
Formaldehyde Contact Allergy. Formaldehyde-Releasers in Clothes: 
Durable Press Chemical Finishes. Part 1." Contact Dermatitis, vol. 62, 
no. 5 (2010). 

De Groot, Anton C. and Freddy Gerkens. "Contact Urticaria from a 
Chemical Textile Finish." Contact Dermatitis, vol. 20, no. 1 (1989). 

De Groot, Anton C. and Howard I. Maibach. "Does Allergic Contact 
Dermatitis from Formaldehyde in Clothes Treated with Durable-Press 
Chemical Finishes Exist in the USA?" Contact Dermatitis, vol. 62, no. 
3 (2009). 

Donovan, Jeff and Sandy Skotnicki-Grant. "Allergic Contact Dermatitis 
from Formaldehyde Textile Resins in Surgical Uniforms and Nonwoven 
Textile Masks." Dermatitis, vol. 18, no. 1 (2006). 

Environment Canada and Health Canada, Canadian Environmental 
Protection Act, 1999, Priority Substances List Assessment Report, 
Formaldehyde. Canada, 2001. 

Fowler, Joseph F. "Formaldehyde as a Textile Allergen." In Textiles 
and the Skin (Current Problems in Dermatology), vol. 31, edited by P. 
Elsner, K. Hatch, and W. Wigger-Alberti, 156-165. Basel, Switzerland: 
S. Karger AG, 2003. 

Fowler, Joseph F. Jr., Steven M. Skinner, and Donald V. Belsito. 
"Allergic Contact Dermatitis from Formaldehyde Resins in Permanent 
Press Clothing: An Underdiagnosed Cause of Generalized Dermatitis." 
Journal of the American Academy of Dermatology, vol. 27, no. 6 (1992). 

Geldof, B.A., I.D. Roesyanto, and Th. van Joost. "Clinical Aspects of 
Para-Tertiary-Butylphenolformaldehyde Resin (PTBP-FR) Allergy." 
Contact Dermatitis, vol. 21, no. 5 (1989). 

Hatch, Kathryn L. "Chemicals and Textiles Part II: Dermatological 
Problems Related to Finishes." Textile Research Journal, vol. 54, no. 
11 (1984). 

Hatch, Kathryn L. and Howard I. Maibach. "Textile Chemical Finish 
Dermatitis." Contact Dermatitis, vol. 14, no. 1 (1986). 

Hatch, Kathryn L. and Howard I. Maibach. "Textile Dermatitis: An 
Update." Contact Dermatitis, vol. 32, no. 6 (1995). 

Hatch, Kathryn L. and Howard I. Maibach. "Textile Dye Dermatitis." 
Journal of the American Academy of Dermatology, vol. 32, no. 4 (1995). 

Hegewald, Janice, et al. "Meteorological Conditions and the Diagnosis 
of Occupationally Related Contact Sensitizations." Scandinavian 
Journal of Work, Environment & Health, vol. 34, no. 4 (2008). 

Imbus, Harold R. "Clinical Evaluation of Patients with Complaints 
Related to Formaldehyde Exposure." Journal of Allergy and Clinical 
Immunology, vol. 76, no. 6 (1985). 

Iversen, Olav Hilmar. "Formaldehyde and Skin Carcinogenesis." 
Environment International, vol. 12, no. 5 (1986). 

Lazarov, A. "Textile Dermatitis in Patients with Contact Sensitization 
in Israel: a 4-Year Prospective Study." Journal of the European 
Academy of Dermatology and Venereology, vol. 18, no. 5 (2004). 

Lazarov, A. and M. Cordoba. "Purpuric Contact Dermatitis in Patients 
with Allergic Reaction to Textile Dyes and Resins." Journal of the 
European Academy of Dermatology and Venereology, vol. 14, no. 2 (2000). 

Le Coz, Christophe-J. "Clothing." In Textbook of Contact Dermatitis, 
3rd ed., edited by R.J.G. Rycroft, T. Menne, P.J. Frosch, and Jean- 
Pierre Lepoittevin, 727-749. Berlin, Heidelberg, Germany: Springer, 
2001. 

Maibach, Howard. "Formaldehyde: Effects on Animal and Human Skin." In 
Formaldehyde Toxicity, edited by J.E. Gibson, 166-174. Washington, 
D.C.: Hemisphere, 1983. 

Marks, James G. Jr., et al. "North American Contact Dermatitis Group 
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[End of section] 

Appendix II: Objectives, Scope, and Methodology: 

Section 234 of the Consumer Product Safety Improvement Act of 2008 
requires GAO to conduct a study on the use of formaldehyde in the 
manufacturing of textiles and apparel.[Footnote 49] This report 
provides information on what is known about (1) the health risks from 
exposure to formaldehyde, particularly from clothing, and (2) the 
levels of formaldehyde found in clothing sold in the United States. 
Throughout our review, we consulted with the Consumer Product Safety 
Commission (CPSC) on our methodology and to obtain relevant background 
information stemming from the agency's mission to ensure consumer 
protection. 

To determine what is known about the health effects of exposure to 
formaldehyde, particularly from clothing, we conducted literature 
reviews on both the general health effects of formaldehyde and the 
health effects of exposure to formaldehyde in clothing. For the 
general health effects, we summarized the findings of several 
comprehensive government reviews, including (1) the Health and Human 
Services' (HHS) 2005 National Toxicology Program report on carcinogens 
(currently being updated),[Footnote 50] (2) HHS's Agency for Toxic 
Substances and Disease Registry 1999 toxicological profile for 
formaldehyde,[Footnote 51] (3) the Environmental Protection Agency's 
(EPA) 1991 Integrated Risk Information System formaldehyde 
assessment[Footnote 52] and the 2010 draft update,[Footnote 53] (4) 
the 2006 monograph on formaldehyde prepared by the World Health 
Organization's International Agency for Research on Cancer,[Footnote 
54] and (5) the Organisation for Economic Co-operation and 
Development's 2002 Screening Information Data Set for formaldehyde. 
[Footnote 55] 

To determine the health effects of exposure to formaldehyde in 
clothing, we reviewed and summarized the findings of over 40 relevant 
articles published from 1980 to April 2010 primarily in medical 
journals, but also in textile industry and environmental journals and 
books. We targeted reviews and meta-analyses, rather than individual 
studies, published in English but also included articles presenting 
original research, such as clinical studies. In addition, we 
interviewed and obtained studies from medical professionals, officials 
from the Department of Agriculture (USDA) and CPSC, and 
representatives from industry organizations such as the American 
Apparel and Footwear Association, Cotton Incorporated, and the 
Formaldehyde Council, Inc. 

To determine what is known about the levels of formaldehyde found in 
clothing sold in the United States, we analyzed information on 
formaldehyde-containing resins and formaldehyde levels in clothing 
from government studies, patent applications, and trade publications; 
interviewed officials from government agencies including USDA's 
Agricultural Research Service, industry associations, retailers, 
testing laboratories, and academia, as well the medical profession; 
and contracted with an accredited commercial laboratory to test the 
formaldehyde levels in a nonprobability sample[Footnote 56] of 180 
articles of clothing (165) and bed linens (15). 

For our nonprobability sample, we purchased clothing and bed linens 
from 10 national retailers, two military facilities, and a store 
selling children's scout uniforms. In March 2010, our staff purchased 
items in six major metropolitan areas: Boston, Chicago, Dallas, Los 
Angeles, Seattle, and Washington, D.C. Our sample was approximately 
evenly split by gender and included items worn by adults and children. 
We purchased only items that come into direct contact with the skin; 
we did not buy outerwear such as jackets or coats. We used clothing 
sizes to determine whether clothing was intended for children 3 years 
of age and older. We also considered crib sheets and cloth diapers to 
be intended for use by infants and toddlers. The results from testing 
our nonprobability sample are illustrative of formaldehyde levels that 
may be found in some clothing and are not projectable to clothing sold 
in the United States in general. 

We selected items that were likely to contain formaldehyde, such as 
those made from plant-based fibers, like cotton, that are likely to be 
treated for durable press. Almost all of the items in the sample were 
made from 50 percent or more natural (mostly plant-based) fibers. 
About 76 percent of the items were made from 90 percent or more 
cotton. About a fifth of the items were labeled as being treated for 
durable press, including bed linens and career apparel such as dress 
shirts. We also included some commonly worn items, such as T-shirts 
and jeans, based on a review of Department of Commerce data for 
volumes of clothing and bed linens imported or produced in the United 
States. We selected low-or moderately priced items. Most of the items 
in our sample were imported; however, we also made an effort to ensure 
that about 10 percent of them were American made. 

An accredited commercial laboratory tested the items for formaldehyde. 
The laboratory is accredited by, among others, the American 
Association of Textile Chemists and Colorists and the American 
Association for Laboratory Accreditation.[Footnote 57] To prepare 
items for shipment, we placed each one in its own zippered plastic bag 
shortly after its purchase to avoid cross-contamination from other 
items or packaging materials. Samples received by the laboratory were 
cut, weighed, and kept wrapped in foil inside a plastic bag until the 
formaldehyde test was run. 

The laboratory tested the items using two test methods commonly used 
by the textile industry--the Japanese Industrial Standard L 1041 test, 
also known as the Japanese Law 112 test (Japanese test), and the 
American Association of Textile Chemists and Colorists 112 test (AATCC 
test). Results from the Japanese test and the AATCC test are not 
comparable because, for example, they use different testing 
specifications. The procedure the laboratory used for the Japanese 
test included placing 1 gram of the sample in a stoppered flask with 
100 mL of water and immersing it in a bath of 40°C water for 1 hour. 
The procedure the laboratory used for the AATCC test included 
suspending 1 gram of the sample in a sealed jar above 50 mL of water. 
The jar was kept in an oven at 49°C for 20 hours and then cooled at 
room temperature for 30 minutes. For both tests, an acetyl acetone 
reagent was added as the next step, and the solution was heated at 
40°C for 30 minutes and allowed to cool at room temperature for 30 
minutes. The laboratory ran quality control tests for each batch of 
samples. 

We had each of the 180 items tested using the Japanese test and a 
smaller number using the AATCC test because most of the regulatory and 
corporate formaldehyde limits we identified used the Japanese test or 
its equivalent. According to the American Apparel and Footwear 
Association, this test or its equivalent is used to determine whether 
formaldehyde levels in clothing are consistent with levels cited in 
international formaldehyde regulations, which we used as a basis of 
comparison for our own test results. Also, the Japanese test was more 
frequently used in the government studies we identified that conducted 
formaldehyde testing in clothing and other textiles. In addition, most 
of the U.S. retailers that provided us with information on internal 
corporate limits on formaldehyde in clothing, and the voluntary 
labeling programs we identified, use the Japanese test or its 
equivalent. We tested 21 of the 180 items using both the Japanese test 
and the AATCC test. This latter test is used by some U.S. retailers 
that have established corporate limits on formaldehyde and has been 
used in some studies cited in government reviews, trade publications, 
and the medical literature. The 21 items tested by both methods were 
selected to include a similar mix of clothing and bed linens as the 
overall sample. 

If items contained more than one type of fabric that could potentially 
contain varying levels of formaldehyde, the laboratory tested a 
composite sample that included equal amounts of these fabrics. 
Decorative elements that do not come into direct skin contact, such as 
sequins, were not included as part of the composite. This composite 
approach would tend to result in formaldehyde levels falling between 
the highest and lowest levels in the different fabrics. 

In addition, we contacted U.S.-based, publicly owned retailers to 
determine if they have internal corporate limits for formaldehyde in 
clothing. We contacted 16 retailers and received responses from 14, of 
which 13 had limits. We also found information on the Internet on the 
limits set by one of the two retailers that did not respond. 

To identify regulatory and voluntary labeling programs that may be 
used in other countries as well as relevant studies on the levels of 
formaldehyde in clothing, we contacted government and European Union 
officials and conducted Internet searches. We identified a number of 
countries that have regulatory standards for formaldehyde in textiles 
as well as voluntary labeling programs. Because of complexities in 
obtaining translations of other countries' formaldehyde laws and 
regulations into English and confirming their application within the 
context of these countries' legal systems, we relied primarily on the 
American Apparel and Footwear Association for information on 
formaldehyde limits set in other countries, including the limits 
identified as the most stringent.[Footnote 58] We obtained information 
on international worker safety standards for formaldehyde primarily 
from a report by HHS's National Institute for Occupational Safety and 
Health. 

We conducted this performance audit from September 2009 to August 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix III: Voluntary Labeling Programs: 

Table 4 lists examples of voluntary labeling programs, which are 
primarily used in other countries.[Footnote 59] Clothing and other 
items meeting the specified limits for formaldehyde and other 
substances would typically display a label indicating their 
compliance. The formaldehyde limits in the table are those applicable 
to clothing and other textiles that come into direct contact with the 
skin. 

Table 4: Examples of Voluntary Labeling Programs: 

Governing body: European Union; 
Label name: European Ecolabel; 
Formaldehyde limit for infants/toddlers,[A] in parts per million: 20; 
Formaldehyde limit for children and adults, in parts per million: 30; 
Test method specified (or equivalent): Japanese test. 

Governing body: Good Environmental Choice Australia Ltd; 
Label name: Australian Ecolabel; 
Formaldehyde limit for infants/toddlers,[A] in parts per million: 30; 
Formaldehyde limit for children and adults, in parts per million: 30; 
Test method specified (or equivalent): Japanese or AATCC tests[B]. 

Governing body: International Association for Research and Testing in 
the Field of Textile Ecology; 
Label name: Oeko-Tex® Standard 100; 
Formaldehyde limit for infants/toddlers,[A] in parts per million: Not 
detectable[C]; 
Formaldehyde limit for children and adults, in parts per million: 75; 
Test method specified (or equivalent): Japanese test. 

Governing body: International Working Group on Global Organic Textile 
Standard; 
Label name: Global Organic Textile Standard; 
Formaldehyde limit for infants/toddlers,[A] in parts per million: Any 
level prohibited; 
Formaldehyde limit for children and adults, in parts per million: Any 
level prohibited; 
Test method specified (or equivalent): Not specified. 

Governing body: New Zealand Ecolabelling Trust; 
Label name: Environmental Choice New Zealand; 
Formaldehyde limit for infants/toddlers,[A] in parts per million: 30; 
Formaldehyde limit for children and adults, in parts per million: 30; 
Test method specified (or equivalent): Japanese test. 

Source: GAO analysis of voluntary labeling programs. 

[A] The transition from limits applicable to infants/toddlers to those 
for children and adults, where applicable, is 3 years of age. 

[B] Or certified according to the most recent Oeko-Tex® Standard 100. 

[C] Formaldehyde limit listed as "not detectable" is 16 parts per 
million. 

[End of table] 

[End of section] 

Appendix IV: Top Ten Exporters of Clothing to the United States in 
2008: 

Country: China; 
Percentage of total U.S. imports[A]: 34.3%. 

Country: Vietnam; 
Percentage of total U.S. imports[A]: 6.7%. 

Country: Bangladesh; 
Percentage of total U.S. imports[A]: 6.3%. 

Country: Honduras; 
Percentage of total U.S. imports[A]: 5.9%. 

Country: Indonesia; 
Percentage of total U.S. imports[A]: 4.8%. 

Country: Mexico; 
Percentage of total U.S. imports[A]: 4.6%. 

Country: Cambodia; 
Percentage of total U.S. imports[A]: 3.9%. 

Country: India; 
Percentage of total U.S. imports[A]: 3.9%. 

Country: El Salvador; 
Percentage of total U.S. imports[A]: 3.7%. 

Country: Pakistan; 
Percentage of total U.S. imports[A]: 3.1%. 

Source: GAO analysis of the Department of Commerce Office for Textiles 
and Apparel data. 

Notes: Data include all apparel imports under notional category 1. 

[A] By square meter equivalents. 

[End of table] 

[End of section] 

Appendix V: Results of Formaldehyde Tests for a Sample of Clothing and 
Bed Linens Sold in the United States: 

Table 5 shows the results of tests we had performed on 180 items--165 
articles of clothing and 15 bed linen items. 

Table 5: Information on Items Sold in the United States and Tested for 
Formaldehyde Levels, 2010: 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free; 
Country identified on label: China; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 206.1; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: Hat; 
Fiber content identified on label: 100% cotton exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 192.6; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: Bed linens (pillow cases); 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
Soft finish, easy care; 
Country identified on label: Bahrain; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 189.6; 
Formaldehyde level in parts per million[B]: AATCC test: 550.7. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: Khakis; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: No 
iron, permanent crease; 
Country identified on label: India; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 169.6; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: Dress shirt; 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 95.1; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: Bed linens (pillow cases); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free, easy care, no ironing needed, eco-friendly; 
Country identified on label: USA of fabric imported from Pakistan; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 93.8; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Noniron; 
Country identified on label: Indonesia; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 92.6; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: Bed linens (pillow cases); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free performance; 
Country identified on label: Pakistan; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 89.3; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: Bed linens (crib sheet); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Preshrunk; 
Country identified on label: Thailand; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: 85.4; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Exceeds; 
Item type: U.S. military combat uniform pants; 
Fiber content identified on label: 50% cotton, 50% nylon; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: 75.4; 
Formaldehyde level in parts per million[B]: AATCC test: 205.5. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (pillow cases); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 72.4; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: U.S. military combat uniform pants; 
Fiber content identified on label: 50% cotton, 50% nylon; 
Fabric performance characteristic identified on label or packaging: 
Insect repellent; 
Country identified on label: USA; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 71.0; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Noniron, stain resistant; 
Country identified on label: Indonesia; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 63.0; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: U.S. military combat uniform shirt; 
Fiber content identified on label: 50% cotton, 50% nylon; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: 57.8; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: No 
iron, permanent crease; 
Country identified on label: Vietnam; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 54.3; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Hat; 
Fiber content identified on label: 79% cotton, 19% polyester, 2% other; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: 50.1; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (pillow cases); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free, bleach friendly; 
Country identified on label: India; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 47.9; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free, easy care; 
Country identified on label: Dominican Republic; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 45.9; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Minimal shrinkage, fade and pill resistant, nonroll collar; 
Country identified on label: Pakistan; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 45.5; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: 42.5; 
Formaldehyde level in parts per million[B]: AATCC test: 32.7. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 100% worsted wool (polyester 
lining); 
Fabric performance characteristic identified on label or packaging: 
Wrinkle and stain resistant; 
Country identified on label: Mexico; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 41.7; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Noniron, stain resistant; 
Country identified on label: Honduras; 
Target customer: Men; 
[Empty]; 
Formaldehyde level in parts per million[B]: Japanese test: 38.0; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Easy iron; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 37.2; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (sham); 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Pakistan; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 35.9; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle resist; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 32.7; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Jeans; 
Fiber content identified on label: 98% cotton, 2% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: 24.0; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Stain resistant, wrinkle free; 
Country identified on label: Assembled in Nicaragua; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 23.7; 
Formaldehyde level in parts per million[B]: AATCC test: 43.2. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Blouse; 
Fiber content identified on label: 69% cotton, 27% nylon, 4% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: 23.5; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
Easy care, wrinkle resist; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 22.5; 
Formaldehyde level in parts per million[B]: AATCC test: 33.1. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Hat; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: 22.5; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: No 
iron, wrinkle free, easy care; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 22.4; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Scout skirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: 21.6; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Sweatpants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Honduras; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: 21.0; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 97% cotton, 3% elastane; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: India; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: 20.5; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: U.S. military dress uniform shirt; 
Fiber content identified on label: 65% polyester, 35% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: 20.3; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Pajamas; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Thailand; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: 24.1. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free, stain repellent; 
Country identified on label: Vietnam; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: 21.8. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 90% cotton, 10% cashmere; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA of imported fabric; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: 21.1. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Underwear; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: India; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: 14.0. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (crib sheet); 
Fiber content identified on label: 100% cotton sateen; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: 13.8. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Shrink resistant, wrinkle resistant, stain repellant, soil release; 
Country identified on label: Vietnam; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: 11.1. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress; 
Fiber content identified on label: 54% cotton, 45% polyester, 1% 
metallic. Lining: 65% polyester, 35% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: 11.0. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (crib sheet); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Easy care; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Cargo pants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Kenya; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Cargo pants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Indonesia; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Cloth diapers; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Extra absorbent and quick drying; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Cloth diapers; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Extra absorbent and quick drying; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Hat; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Hat; 
Fiber content identified on label: 100% cotton exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Jeans; 
Fiber content identified on label: 100% cotton exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Indonesia; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Jeans; 
Fiber content identified on label: 99% cotton, 1% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Pajamas; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Pajamas; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Pajamas; 
Fiber content identified on label: 100% cotton exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Romper; 
Fiber content identified on label: 100% combed cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Romper; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Romper; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Romper; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Set (dress and leggings); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: Not detectable. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Set (romper, pants, and bib); 
Fiber content identified on label: 100% cotton/80% cotton, 20% 
polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Set (top and bottom); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Set (top and bottom); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Thailand; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Set (top and bottom); 
Fiber content identified on label: Shell: 100% cotton exclusive of 
decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Set (tops and bottom); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Socks; 
Fiber content identified on label: 82% cotton, 15% nylon, 2% spandex, 
1% rubber; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Sweatpants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Sweatpants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: El Salvador; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Guatemala; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Guatemala; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Thailand; 
Target customer: Infants/toddlers[D]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (pillow cases); 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Pakistan; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Cargo pants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 55% linen, 45% rayon; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Jeans; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Pajamas; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 100% organic cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: India; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Lesotho; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Scout pants; 
Fiber content identified on label: 67% cotton, 33% polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Scout shirt; 
Fiber content identified on label: 67% cotton, 33% polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Sweatpants (shorts); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Vietnam; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Honduras; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Honduras; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Underwear; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Boys 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: Not detectable. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (pillow cases); 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Pakistan; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Blouse; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bra; 
Fiber content identified on label: 95% cotton, 5% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bra; 
Fiber content identified on label: 95% cotton, 5% spandex, inner cup: 
100% polyester (padded); 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Vietnam; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress; 
Fiber content identified on label: 100% cotton. Mesh--100% polyester, 
exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 97% cotton, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Jeans; 
Fiber content identified on label: 56% ramie, 25% cotton, 18% 
polyester, 1% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: Not detectable. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 100% cotton exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Vietnam; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Scout shirt; 
Fiber content identified on label: 65% polyester, 35% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Mexico of USA Parts; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 95% cotton, 5% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Underwear; 
Fiber content identified on label: 95% cotton, 5% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Girls 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (fitted sheet); 
Fiber content identified on label: 100% cotton exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (flat sheet); 
Fiber content identified on label: 60% pima cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
Easy care; 
Country identified on label: China; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (pillow cases); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Adults or children 3 years of age and older; 
[Empty]; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bed linens (pillow cases); 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
Easy care, wrinkle resistant; 
Country identified on label: China; 
Target customer: Adults or children 3 years of age and older; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Cargo pants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Egypt; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 100% wool; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Vietnam; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
Easy care; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: Shell: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Easy iron; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Easy care; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 55% cotton, 45% polyester; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle free; 
Country identified on label: Vietnam; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 60% cotton, 40% polyester exclusive 
of decoration; 
Fabric performance characteristic identified on label or packaging: 
Easy care; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Hat; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Moisture management; 
Country identified on label: China; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Hat; 
Fiber content identified on label: 100% cotton exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Hat; 
Fiber content identified on label: 97% cotton, 3% P.U. spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: Not detectable. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Jeans; 
Fiber content identified on label: 100% Cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: India; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Jeans; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Mexico; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Jeans; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Mexico; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 100% combed cotton; 
Fabric performance characteristic identified on label or packaging: 
Wrinkle resistant; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 100% combed cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: No 
iron, wrinkle free, permanent crease, polished finish; 
Country identified on label: Vietnam; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Shrink resistant, wrinkle resistant, stain repellant, soil release; 
Country identified on label: Vietnam; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Pajama pants; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Cambodia; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: India; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 100% cotton exclusive of decoration; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: India; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 60% cotton, 40% polyester; 
Fabric performance characteristic identified on label or packaging: 
Easy care; 
Country identified on label: Indonesia; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 65% cotton, 35% polyester; 
Fabric performance characteristic identified on label or packaging: 
Easy care, wrinkle resistant, super soft touch; 
Country identified on label: China; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Socks; 
Fiber content identified on label: 84% cotton, 15% nylon, 1% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Sweatpants (shorts); 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Honduras; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Mexico; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Pakistan; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: U.S. military combat uniform shirt; 
Fiber content identified on label: 50% cotton, 50% nylon; 
Fabric performance characteristic identified on label or packaging: 
Insect repellent; 
Country identified on label: USA; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: U.S. military dress uniform shirt; 
Fiber content identified on label: 75% polyester, 25% wool; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Underwear; 
Fiber content identified on label: 100% combed cotton; 
Fabric performance characteristic identified on label or packaging: 
Antimicrobial, pre-shrunk; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Underwear; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Underwear; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Honduras; 
Target customer: Men; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Blouse; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Indonesia; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: Not detectable. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Blouse; 
Fiber content identified on label: 65% cotton, 35% silk; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Blouse; 
Fiber content identified on label: 68% cotton, 28% nylon, 4% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bra; 
Fiber content identified on label: 95% cotton, 5% lycra; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Bra; 
Fiber content identified on label: Body/cup: 80% nylon, 20% lycra. 
Back lining: 84% polyester, 16% lycra; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: Not detectable. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Cargo pants; 
Fiber content identified on label: 97% cotton, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Cargo pants; 
Fiber content identified on label: 98% cotton, 2% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Indonesia; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 54% linen, 44% cotton, 2% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Vietnam; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 97% cotton, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Vietnam; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 97% wool, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress pants; 
Fiber content identified on label: 98% cotton, 2% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Sri Lanka; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 60% cotton, 37% polyester, 3% 
spandex; 
Fabric performance characteristic identified on label or packaging: 
Easy care; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 96% cotton, 4% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 96% cotton, 4% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: Not detectable. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 97% cotton, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 97% cotton, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress shirt; 
Fiber content identified on label: 97% cotton, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Indonesia; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress skirt; 
Fiber content identified on label: 71% polyester, 26% rayon, 3% 
spandex; 
Fabric performance characteristic identified on label or packaging: 
Washable stretch, minimum care required; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Dress skirt; 
Fiber content identified on label: 97% cotton, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Sri Lanka; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: Not detectable. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Jeans; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 96% cotton, 4% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Indonesia; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 97% cotton, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Vietnam; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 97% cotton, 3% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 98% cotton, 2% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Khakis; 
Fiber content identified on label: 98% cotton, 2% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Vietnam; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 100% organic cotton; 
Fabric performance characteristic identified on label or packaging: 
Soft hand, shrink resistant; 
Country identified on label: Vietnam; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Polo shirt; 
Fiber content identified on label: 95% pima cotton, 5% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Vietnam; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Socks; 
Fiber content identified on label: 76% cotton, 21% nylon, 3% lycra; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Pakistan; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Socks; 
Fiber content identified on label: 77% cotton, 18% polyester, 3% 
natural latex rubber, 1% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: USA; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Sweatpants; 
Fiber content identified on label: 85% cotton, 15% polyester; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Cambodia; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Sweatpants; 
Fiber content identified on label: 90% cotton, 10% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Assembled in Guatemala; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: Not detectable. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
Pre-shrunk; 
Country identified on label: Honduras; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: T-shirt; 
Fiber content identified on label: 100% cotton; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Thailand; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Underwear; 
Fiber content identified on label: 92% cotton, 8% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: China; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Comparison to most stringent regulatory standards for formaldehyde[A]: 
Meets; 
Item type: Underwear; 
Fiber content identified on label: 95% cotton, 5% spandex; 
Fabric performance characteristic identified on label or packaging: 
None identified; 
Country identified on label: Bangladesh; 
Target customer: Women; 
Formaldehyde level in parts per million[B]: Japanese test: Not 
detectable; 
Formaldehyde level in parts per million[B]: AATCC test: [C]. 

Source: GAO analysis of information provided on items' labels or 
packaging and test data from an accredited commercial laboratory. 

[A] As compared with the most stringent regulatory standards for 
formaldehyde identified by the American Apparel and Footwear 
Association, Restricted Substance List, Release 6, 2010. 

[B] Formaldehyde levels listed as "not detectable" are below 20 parts 
per million for the Japanese test and 10 parts per million for the 
AATCC test. 

[C] This item was tested only by the Japanese test. 

[D] Infants/toddlers refers to children younger than 3 years of age. 

[End of table] 

[End of section] 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

John B. Stephenson, (202) 512-3841 or stephensonj@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Christine Fishkin, Assistant 
Director; Gezahegne Bekele; Mark Braza; Antoinette Capaccio; Keya 
Chateauneuf; Nancy Crothers; Lorraine Ettaro; Melissa King; Nathan A. 
Morris; and Ruth Solomon made key contributions to this report. 

[End of section] 

Footnotes: 

[1] In this report, the term "resin" encompasses both the older resin 
technologies that may release high levels of formaldehyde and the more 
recent cross-linking agents that may release little to no formaldehyde. 

[2] Formaldehyde is one of five substances CPSC has identified as a 
strong sensitizer--a substance that can cause hypersensitivity through 
recurring contact--under the Federal Hazardous Substances Act. 
Therefore, formaldehyde and any products containing 1 percent of 
formaldehyde or more (10,000 parts per million) are required to bear a 
warning label. The 1 percent refers to the concentration of 
formaldehyde in solutions and products, not in the air. This reporting 
level for formaldehyde far exceeds amounts likely to be found in 
clothing. 

[3] Pub. L. No. 110-314, § 234 (2008). 

[4] Most of the relevant articles identified from our literature 
review were from medical journals or addressed medical issues, and in 
this report, we use the term "medical literature" to refer to the 
articles. 

[5] American Apparel and Footwear Association, Restricted Substance 
List, Release 6 (2010). 

[6] A nonprobability sample is a sample in which some items in the 
population have no chance, or an unknown chance, of being selected. 
Results from nonprobability samples cannot be used to make inferences 
about a population. 

[7] Medical Management Guidelines for Formaldehyde (Atlanta: U.S. 
Department of Health and Human Services, Agency for Toxic Substances 
and Disease Registry, Feb. 7, 2008), [hyperlink, 
http://www.atsdr.cdc.gov/mhmi/mmg111.html] (accessed Aug. 5, 2009). 

[8] U.S. Department of Health and Human Services, Public Health 
Service, National Toxicology Program, Report on Carcinogens, 
Background Document for Formaldehyde (Research Triangle Park, North 
Carolina, 2010). 

[9] In this report, we use the terms "toxic" and "highly toxic" as 
they are used by EPA's Toxics Release Inventory Program and HHS's 
Agency for Toxic Substances and Disease Registry, respectively. 

[10] EPA initiated an advanced notice of a proposed rulemaking in 
December 2008 indicating that the agency intends to investigate 
whether and what type of federal regulation or other action might be 
appropriate to protect against the risks posed by formaldehyde emitted 
from composite and pressed-wood products. Furthermore, on July 7, 
2010, the Formaldehyde Standards for Composite Wood Act was signed 
into federal law. The new law amends the Toxic Substances Control Act 
to establish standards for emissions of formaldehyde from hardwood 
plywood, medium-density fiberboard, and particleboard. EPA must 
promulgate regulations to implement the standards by January 2013. 

[11] In this report, "durable press" is used to encompass terms such 
as wrinkle resistant, wrinkle free, noniron, no iron, and easy care. 
The durable press fabric characteristic applies to items treated to 
retain their shape and pressed appearance after many uses, washing, 
and tumble drying. All-synthetic fabrics, such as 100 percent 
polyester, are inherently durable press and do not need to be treated. 

[12] Formaldehyde may also be used in binders for prints, in various 
coatings such as fire retardant chemicals, and for other purposes. 

[13] The International Organization for Standardization (ISO) has 
equivalent tests: ISO 14184-1 Textiles--Determination of Formaldehyde--
Part 1: Free and Hydrolyzed Formaldehyde (Water Extraction Method), 
which is equivalent to the Japanese test; and ISO 14184-2 Textiles-- 
Determination of Formaldehyde--Part 2: Released Formaldehyde (Vapour 
Absorption Method), which is equivalent to the AATCC test. 

[14] Formaldehyde Release from Fabric, Determination of: Sealed Jar 
Method, AATCC Test Method 112-2008. 

[15] In general, the AATCC test results in higher formaldehyde levels 
than the Japanese test--except at low formaldehyde levels, such as 30 
parts per million or less--although the difference between the 
formaldehyde levels measured by the two tests depends, in part, on the 
type of fabric and resin used. 

[16] In the Restricted Substance List, the American Apparel and 
Footwear Association, a national trade association, provides 
information about the regulatory limits for various substances in 
countries in which its members may operate. The Restricted Substance 
List identifies Austria, China, Finland, France, Germany, Japan, 
Lithuania, the Netherlands, New Zealand, Norway, Poland, Russia, and 
South Korea as countries that regulate formaldehyde in apparel, home 
textiles, and footwear products. 

[17] Information on countries that require disclosure was compiled by 
the Hong Kong Standards and Testing Centre, a laboratory that provides 
formaldehyde testing services according to international standards and 
regulations. 

[18] Various international agreements (or quotas) capping textile and 
apparel imports into the United States were put in place, in part, to 
attempt to curb the trend toward offshore production, which many U.S. 
manufacturers were using in order to control costs. The World Trade 
Organization agreement was put in place to lift these quotas. 

[19] This organization is now called the Hamner Institutes for Health 
Sciences. 

[20] The hematopoietic and lymphatic systems are, among other things, 
involved in the production of blood and in the immune system function. 

[21] U.S. Department of Health and Human Services, Public Health 
Service, National Toxicology Program, Report on Carcinogens, 11th 
Edition (Research Triangle Park, North Carolina, 2005). 

[22] 74 Fed. Reg. 67883 (Dec. 21, 2009). 

[23] EPA, Office of Pesticides and Toxic Substances, Assessment of 
Health Risks to Garment Workers and Certain Home Residents From 
Exposure to Formaldehyde (Washington, D.C., 1987); and Integrated Risk 
Information System, Formaldehyde (CASRN 50-00-0) (Washington, D.C.: 
EPA), [hyperlink, http://www.epa.gov/ncea/iris/subst/0419.htm] 
(downloaded Dec. 9, 2009). 

[24] EPA, IRIS Toxicological Review of Formaldehyde--Inhalation 
Assessment (External Review Draft) (Washington, D.C., June 2010). 

[25] The National Academies comprises four organizations: the National 
Academy of Sciences, the National Academy of Engineering, the 
Institute of Medicine, and the National Research Council. 

[26] World Health Organization, International Agency for Research on 
Cancer, IARC Monographs on the Evaluation of Carcinogenic Risks to 
Humans, Volume 88, Formaldehyde, 2-Butoxyethanol and 1-tert- 
Butoxypropan-2-ol (Lyon, France, 2006). 

[27] Robert Baan et al. "A Review of Human Carcinogens--Part F: 
Chemical Agents and Related Occupations," The Lancet Oncology, vol. 
10, issue 12 (2009). 

[28] Department of Energy, Oak Ridge National Laboratory, Formaldehyde 
Release From Durable-Press Apparel Textiles, Final Project Report to 
the U.S. Consumer Product Safety Commission (Oak Ridge, Tennessee, 
1985). 

[29] Dermal exposure occurs when skin comes in contact with free 
formaldehyde in textiles. Formaldehyde in clothing may be either bound 
or free, and it is the skin contact with free formaldehyde that is 
associated with the negative health effects. Free formaldehyde occurs 
when there is an incomplete binding process between the formaldehyde- 
based resin and the clothing fibers or when the resin decomposes. 
Unless otherwise noted in this report, references to the health 
effects associated with formaldehyde in clothing or textiles refer to 
free formaldehyde. 

[30] Anton C. De Groot and Howard I. Maibach, "Does Allergic Contact 
Dermatitis from Formaldehyde in Clothes Treated with Durable-Press 
Chemical Finishes Exist in the USA?" Contact Dermatitis, vol. 62, no. 
3 (2009). 

[31] Ryan M. Carlson, Mary C. Smith, and Susan T. Nedorost, "Diagnosis 
and Treatment of Dermatitis Due to Formaldehyde Resins in Clothing," 
Dermatitis, vol. 15, no. 4 (2004). 

[32] Etain Cronin, Contact Dermatitis (New York City: Churchill 
Livingstone, 1980). 

[33] While a national regulation of formaldehyde in clothing would not 
necessarily produce comprehensive data on levels in clothing, such 
data are unlikely to be compiled without a requirement to do so. 

[34] We considered all items in our sample to come into direct contact 
with the skin, although some textile industry standards consider bed 
linens for older children and adults to be subject to the formaldehyde 
limits applicable to items that do not come into direct contact with 
the skin. 

[35] We are using "durable press" to include terms such as wrinkle 
resistant, wrinkle free, noniron, no iron, and easy care. 

[36] European Commission Directorate General Joint Research Centre, 
Physical and Chemical Exposure Unit, Chemical Release from Textiles, 
European Survey on the Release of Formaldehyde from Textiles (Ispra, 
Italy, 2007). 

[37] Evaluation of Alleged Unacceptable Formaldehyde Levels in 
Clothing (Wellington, New Zealand: New Zealand Ministry of Consumer 
Affairs, Oct. 17, 2007), [hyperlink, 
http://www.consumeraffairs.govt.nz/legislation-policy/policy-reports-
and-papers/reports] (accessed Oct. 22, 2009). The New Zealand 
government also received information from four retailers that tested 
203 items. One item, a preproduction fabric, was found to be above the 
acceptable level, which was defined by New Zealand to be 100 parts per 
million. 

[38] No Formaldehyde Found in Clothing, Australian Competition and 
Consumer Commission, (October 17, 2007), [hyperlink, 
http://www.accc.gov.au/content/index.phtml?itemId=801314] (accessed 
Aug. 5, 2009). 

[39] B.A. Kottes Andrews, "Wrinkle Resistant Cotton and Formaldehyde 
Release," Colourage Annual (1995). 

[40] Formaldehyde Release from Durable-Press Apparel Textiles, Final 
Project Report to the U.S. Consumer Product Safety Commission (1985). 

[41] The current OSHA regulation, among other things, limits airborne 
exposure to 0.75 parts of formaldehyde per million parts of air over 
an 8-hour workday; sets a short-term exposure limit of 2 parts of 
formaldehyde per million parts of air; and includes a hazard 
communication requirement pertaining to formaldehyde gas, all mixtures 
or solutions composed of greater than 0.1 percent formaldehyde 
(equivalent to 1,000 parts per million), and materials capable of 
releasing formaldehyde into the air, under reasonably foreseeable 
conditions of use, at concentrations reaching or exceeding 0.1 parts 
per million. The National Institute for Occupational Safety and Health 
has established nonenforceable guidelines for formaldehyde exposure 
and recommends an occupational exposure limit over an 8-hour workday 
of 0.016 parts per million and a 15-minute ceiling of 0.1 parts per 
million in the air. 

[42] This formaldehyde level in textiles is based on the Japanese test. 

[43] Eero Priha, "Are Textile Formaldehyde Regulations Reasonable? 
Experiences from the Finnish Textile and Clothing Industries," 
Regulatory Toxicology and Pharmacology, 22, 243-249 (1995). 

[44] Department of Health and Human Services, National Institute for 
Occupational Safety and Health, The Registry of Toxic Effects of 
Chemical Substances, No. LP8925000, CAS No. 50-00-0 (Washington, D.C., 
2009). 

[45] The countries the American Apparel and Footwear Association 
identifies as having regulatory standards for formaldehyde in clothing 
and other textiles are Austria, China, Finland, France, Germany, 
Japan, Lithuania, the Netherlands, New Zealand, Norway, Poland, 
Russia, and South Korea. 

[46] The Austrian Textile Research Institute and the German Research 
Institute Hohenstein jointly developed the Oeko-Tex® Standard 100 in 
1992. The International Oeko-Tex® Association, which includes 14 
textile research and test institutes in Europe and Japan, is 
responsible for the independent tests for harmful substances according 
to Oeko-Tex® Standard 100. 

[47] We requested information on corporate limits on formaldehyde in 
clothing and other textiles, if any, from 16 publicly traded U.S.-
based clothing retailers. One of the 14 retailers responding reported 
that it had not established formaldehyde limits. For one of the two 
retailers that did not respond, we were able to obtain, from its Web 
site, information about the corporate limits it has established. 

[48] According to medical literature, moderate amounts of formaldehyde 
are defined as between 1,000 and 100 parts per million, while low and 
ultra-low levels are below 100 parts per million, based on the AATCC 
test. 

[49] Pub. L. No. 110-314, § 234 (2008). 

[50] U.S. Department of Health and Human Services, National Toxicology 
Program, Report on Carcinogens, 11th Edition (Research Triangle Park, 
North Carolina, 2005). 

[51] U.S. Department of Health and Human Services, Public Health 
Service, Agency for Toxic Substances and Disease Registry, 
Toxicological Profile for Formaldehyde (Atlanta, Georgia, 1999). 

[52] Integrated Risk Information System, Formaldehyde (CASRN 50-00-0) 
(Washington, D.C.: EPA), [hyperlink, 
http://www.epa.gov/ncea/iris/subst/0419.htm] (downloaded Dec. 9, 2009). 

[53] U.S. Environmental Protection Agency, External Review Draft: 
Toxicological Review of Formaldehyde--Inhalation Assessment, in 
Support of Summary Information on the Integrated Risk Information 
System, Volume I of IV (Washington, D.C., June 2010). 

[54] World Health Organization, International Agency for Research on 
Cancer, IARC Monographs on the Evaluation of Carcinogenic Risks to 
Humans, Volume 88, Formaldehyde, 2-Butoxyethanol and 1-tert- 
Butoxypropan-2-ol (Lyon, France, 2006). 

[55] Organisation for Economic Co-operation and Development, SIDS 
Initial Assessment Report for 14th SIAM, Formaldehyde (CAS No. 50-00-
0) (Paris, France, 2002). 

[56] A nonprobability sample is a sample in which some items in the 
population have no chance, or an unknown chance, of being selected. 
Results from nonprobability samples cannot be used to make inferences 
about a population. 

[57] The American Association for Laboratory Accreditation bases its 
accreditation on the International Organization for Standardization 
(ISO) 17025:2005, General requirements for the competence of testing 
and calibration laboratories. 

[58] American Apparel and Footwear Association, Restricted Substance 
List, Release 6 (2010). 

[59] We have identified a few U.S.-based retailers that comply with 
some voluntary programs, but they do not generally sell individual 
items that are labeled to indicate compliance. 

[End of section] 

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