Azo Requirement on Imported Apparel and Textile Products

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Consumer goods which contain listed aromatic amines originating from azo dyes are currently prohibited from manufacture and sale in many countries in the global marketplace. India was the first Asian country to launch a chemical regulation in 1997 to ban specific azo dyes from being used in apparel and textile products.
India has published legislation prohibiting the handling of a total of 112 azo- and benzidine-based dyes. In 1993, the Government of India prohibited the handling of 42 benzidine-based dyes. The Ministry of Environment and Forests further prohibited the handling of an additional 70 azo dyes in 1997. According to the Indian import policy, import of textiles and textile articles is permitted subject to the condition that they do not contain any of the hazardous dyes (azo dyes) whose handling, production, carriage or use is prohibited in India under the provisions of the Environment (Protection) Act, 1986. This amendment was made to the Indian legislation by the Notification No. 03 (RE-2001)/1997-2002 dated on 31 March 2001.
Under the Notification of Ministry of Commerce No. 03 (RE-2001), a pre-shipment certification is required declaring that the shipment is free of azo dyes. The pre-shipment certification must be from a textile testing laboratory accredited to the National Accreditation Agency of the country of origin, certifying that the products do not contain any of the prohibited dyes. It is required for all imported textile products, that testing must be done for every consignment on every model and color in order to ensure compliance to the azo requirement.
The amendment of the regulation by Public Notice No. 12 (RE-2001), clarified that if imported consignments carry a pre-shipment inspection certificate issued by a textile testing laboratory accredited by a National Accreditation Agency of the country of origin, is not required that testing be done during customs clearance. Otherwise, testing and certification will be required before importation is allowed.
Textile Products Imported with Pre-shipment Inspection Certificate
  • Imported textile products with a pre-shipment inspection certificate can expedite custom clearance
  • If testing is required at the port of loading, samples must be collected by a third party inspector.
  • Mandatory testing parameters are fibre composition and azo dyes
  • Testing can be carried out by a textile testing laboratory from the country of origin.  The laboratory must be accredited to ISO 17025 by a national accreditation agency and the accreditation agency logo must be on the testing report
  • Testing reports with “pass” result should be given to the inspection team for pre-shipment inspection certificate issuance
Textile Products Imported without Pre-shipment Inspection Certificate
  • For textile products imported into India without any testing, importers are required to reserve 25% of their shipment for random testing by India Customs
  • Testing will be done by an India laboratory which is approved by the Ministry of Textiles
  • Mandatory testing parameters are fibre composition and azo dyes
  • Shipment will be released after a “pass” result is obtained
Although the Ministry of Environment and Forests has prohibited the handling of 112 dyes in textile products which are capable of releasing any of the harmful amines, it is currently checking on the list of banned amines that will be released from certain of the azo dyes during the reductive cleavage. The list of banned amines is the same as those regulated under EU Regulation (EC) No. 1907/2006 (REACH) Annex XVII.
Name
CAS No.
Name
CAS No.
4-Aminodiphenyl
92-67-1
3,3'-Dimethylbenzidine
119-93-7
Benzidine
92-87-5
3,3'-Dimethyl-4,4'diaminodiphenylmethane
838-88-0
4-Chloro-o-toluidine
95-69-2
p-Cresidine
120-71-8
2-Naphthylamine
91-59-8
4,4'-Methylene-bis-(2-chloroaniline)
101-14-4
o-Aminoazotoluene
97-56-3
4,4'-Oxydianiline
101-80-4
2-Amino-4-nitrotoluene
99-55-8
4,4'-Thiodianiline
139-65-1
4-Chloroaniline
106-47-8
2-Aminotoluene
95-53-4
2,4-Diaminoanisole
615-05-4
2,4-Diaminotoluene
95-80-7
4,4'-Diaminodiphenylmethane
101-77-9
2,4,5-Trimethylaniline
137-17-7
3,3'-Dichlorobenzidine
91-94-1
2-Methoxyaniline
90-04-0
3,3'-Dimethoxybenzidine
119-90-4
4-Aminoazobenzene
60-09-3

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