APEO/ AP Investigation

Summary Report
December 2011

Introduction
BACKGROUND
In September 2011, Greenpeace released the report Dirty Laundry II: Hung out to dry. They drew out 6 samples from different
H&M stores globally and tested them for toxic substances; Nonylphenol Ethoxylates (NPE).
NPEs are commonly used a detergents in textiles production. When broken down to Nonylphenol, it becomes a toxin that has
persistent and hormone disrupting properties.
Since 4 out of 6 samples were tested positive for NPE, we proceeded with an investigation to find the source of contamination.
Case

Thumbnail

Information from Greenpeace

Polo T Shirt

Purchased in China
Made in China
19 ppm

Bird Shirt

Purchased in Netherlands
Made in Bangladesh
21 ppm

Shirt

Purchased in Switzerland
Made in Bangladesh
3.1 ppm

Snoopy

Purchased in Russia
Made in Bangladesh
5 ppm

It is important to note that all 4 cases comply with our current

RSL.
Restricted substance
Limit
Alkylphenol Ethoxylates / Alkylphenols (APEO/AP)
Nonylphenol Ethoxylates (NPE)
100 ppm
Octylphenol Ethoxylates (OPE)
100 ppm
Nonylphenol (NP)
Not detected
Octylphenol (OP)
Not detected

Introduction
WHAT ARE NPEs?
NPEs/ OPEs are included in the group of non-ionic
surfactants called alkylphenolethoxylates (APEOs).
NPEs and OPEs can degrade to NP and OP
respectively.

SAMPLES TESTED BY GREENPEACE

APEOs CAN BE USED IN FOR EXAMPLE:

Detergents
Sourcing agents
Wetting agents
Softeners
Emulsifier/ dispersing agents
Impregnating agents
Degreasing agents for leather
Finishing
De-gumming for silk production
Dyes and pigment preparations

Error: Country of
manufacture is
Bangladesh

Methodology
Pre-assessment

Assessment

Evaluation

PRE-ASSESSMENT
Documentation
We requested the suppliers and their processing units who produced the 4 garment styles to fill
out 2 documents. We also requested for them to submit their processing recipes.
1.
Self Assessment
2.
Chemical Inventory
3.
Processing Recipes
We used this information to better prepare for our next step which is to assess the production line.
Test the same garment styles Greenpeace tested
During pre-assessment, we also retrieved the same garments where possible, and tested them.
As all garments are constructed with different parts and components, we tested different sections
of the garment (e.g. body, sleeve, collar) and components to understand the concentration of
APEO at different parts of the garment.

TEST LAB
Bureau Veritas (BV)

DETECTION LIMITS
The detection limits are not the usual
parameters used in current H&M
testing. They were developed
especially for this investigation by BV
to test samples at much lower
frequencies.

ASSESSMENT
We then tried to identify the possible sources of APEO. The depth of the investigation differed case
by case. The difference highly depended upon how each garment was produced. However, for
each case, we prioritized testing at the tier closest to us first- our suppliers. Then, depending upon
the test results, we made decisions as to how to proceed further in the investigation- whether to
select more samples from the same tier, or go further down the supply chain to search for the
source of APEO contamination.

Detection limit for fabric:

OP/NP: 1ppm
OPEO/ NPEO: 1ppm

EVALUATION
After analysing all information gathered from the pre-assessment stage and the assessment stage,
we made evaluations and have drawn some next steps for action.

Detection limit for water:

OP/NP: 1ppb
OPEO/ NPEO: 10ppb

Detection limit for chemicals:

OP/NP: 1ppm
OPEO/ NPEO: 1ppm

Methodology
TESTING PRIORITY
1st Priority

2nd Priory

LIMITATIONS
Production
Units

Washing
Unit

Printing
Unit

Fabric
Mill

Internal Wet
Processing

WHAT ARE WE TESTING?

Incoming water

All incoming
water sources
e.g. River/
Ground water

Wastewater
Factory Treatment
Plant

Wastewater
Discharge &
Sludge

Based on recipe:
Select Relevant chemicals with potential APEO content based
Other chemicals onsite:
Select other chemicals on site that potential of APEO content

Wastewater
quality test
Sludge Quality
test

The biggest limitation foreseen for this

investigation was the period difference
between the time when the products
were produced, and when this
investigation began. Having had the
products been produced approximately
one year prior, we expected for some
evidence to be loss, no longer traceable
or containing different properties (e.g.
incoming water and wastewater are
unlikely going be the exact same/ near
same quality as the quality used and
discharged one year ago).

Results
Number of positive results across all 4 investigations (in Bangladesh and China):
Incoming water

Chemical Products

Wastewater Discharge

Sludge

Number of positive
results

2 out of 10
(20%)

12 out of 35
(34%)

1 out of 14
(0.07%)

2 out of 7
(30%)

Result range for positive

results

1.4ppb to 65 ppb

1 ppm to 3470 ppm

See below table.

69.9 ppb

1.51 ppb 28.7 ppb

Number of positive results across all 4 investigations (in Bangladesh and China):
#
1
2
3
4
5
6
7
8
9
10
11
12

Tested positive
Softener
Softener
Softener
Binder
Binder
Formulated Pigment
Formulated Pigment
Formulated Pigment
Wetting Agent
Sequestering agent
Soaping agent
Anti-Back staining

Result
NPE 3470 ppm; NP 14.3 ppm
NPEO: 4.0 ppm OPEO: 2.0 ppm
NPEO: 4.0 ppm OPEO: 3.2 ppm
NPEO: 12.5 ppm
NPEO: 4 ppm OPEO: 4 ppm
NPEO: 322 ppm OPEO: 2780 ppm
NPEO: 1.8 ppm OPEO: 1.05 ppm
NPEO: 5.05ppm
NPEO: 4.6 ppm OPEO: 2.6 ppm
NPEO: 4.8 ppm OPEO: 2.6 ppm
NPEO: 4.6 ppm OPEO: 2.0 ppm
OPEO 1ppm

All chemicals tested except 1 (#1) comply with EU regulations (EC No. 1907/2006)

Results- Polo Shirt, Produced in China

Greenpeace Result: 19 ppm

MATERIAL TESTS

WATER & CHEMICAL TESTS AT PROCESSING UNITS

External
Washing

Finishing

Yarn Dyeing

Incoming Water

NP: 1.4g/l

ND

ND

Result
Finished Product

Greige Yarn

Body

NPE 3.57ppm;
OPE 1.62ppm;
NP 2.02 ppm

Silicon Oil: NPE

3470 ppm1; NP
14.3 ppm

ND

NPE 3.24ppm

Chemical
Products used

ND

White part of
collar
Blue stripe on
collar

NPE 16.69ppm;
NP 1.74 ppm

Wastewater
Discharge

ND

ND

NPE 69.9 g/l

Sludge

ND

NP: 28.7 g/l

Yarn

NPE 1.34 ppm;

NP 1.88 ppm

NPE 14.9 g/l;

NP 1.51 g/l

1. Silicon oil was found onsite, however, it was not being

used, nor was there evidence showing that it was in use.

Results- Shirt, produced in Bangladesh

Greenpeace Result: 3.1 ppm

MATERIAL TESTS

WATER & CHEMICAL TESTS AT PROCESSING UNITS

Washing

Dyeing

Incoming
Water

ND

ND

Chemical
Products used

Anti-back staining:
OPEO 1ppm

Wetting Agent
Sequestering Agent
Soaping Agent
Softener
Softener

Wastewater
Discharge

ND

ND

Sludge

ND

ND

Result
Finished Product

NPEO: 4.0ppm
OPEO: 2.0 ppm

NPEO: 4.6 ppm

NPEO: 4.8 ppm
NPEO: 4.6 ppm
NPEO: 4.0 ppm
NPEO: 4.0 ppm

OPEO: 2.6 ppm

OPEO: 2.6 ppm
OPEO: 2.0 ppm
OPEO: 2.0 ppm
OPEO: 3.2 ppm

Results- Bird Shirt, produced in Bangladesh

Greenpeace Result: 21 ppm
MATERIAL TESTS
Result
Finished Product
from Factory 1

Finished Product
from Factory 2

Lt Green print with

white fabric
Green print with
white fabric
Black print with
white fabric
Yellow print with
white fabric
Gold foil print with
white fabric
Pink print with
white fabric
White shell fabric
Lt Green print with
white fabric
Green print with
white fabric
Black print with
white fabric
Yellow print with
white fabric
Gold foil print with
white fabric
Pink print with
white fabric
White shell fabric

NPEO: 10 ppm
OPEO: 1.6 ppm
NPEO: 8.0 ppm
OPEO: 6.0 ppm
NPEO: 8.0 ppm
OPEO: 4.2 ppm
NPEO: 6.0 ppm
NPEO: 4.0 ppm
OPEO: 2.0 ppm

WATER & CHEMICAL TESTS AT PROCESSING UNITS

Printing Unit 1

Printing Unit 2

Incoming
Water

Not detected

Not detected

Chemical
Products used

Sapamine
Optical
Brightener
agent
Optical
Brightener
agent
Softener

Not detected
Not detected

Detergent
Binder

Not detected
NPEO: 12.5
ppm
Not detected
Not detected
NPEO: 322
ppm OPEO:
2780 ppm
Not detected

NPEO: 6.0 ppm

NPEO: 2.0 ppm
NPEO: 4.0 ppm
OPEO: 4.0 ppm
NPEO: 4.0 ppm
OPEO: 4.0 ppm
NPEO: 2.0 ppm
OPEO: 2.0 ppm
NPEO: 1.8 ppm
OPEO: 1.2 ppm
NPEO: 3.0 ppm
OPEO: 1.0 ppm
NPEO: 16 ppm
OPEO: 8.0 ppm
NPEO: 3.0 ppm
OPEO: 1.6 ppm

Foil glue
Fixing agent
Green Pigment

Black Pigment
Wastewater
Discharge

Not detected

Not detected

Binder WST
Binder

Pink pigment

Not detected

Not detected

Not detected
NPEO: 4 ppm
OPEO: 4 ppm
NPEO:
5.05ppm

Results- Snoopy T- Shirt, produced in Bangladesh

Greenpeace Result: 5 ppm

MATERIAL TESTS

WATER & CHEMICAL TESTS AT PROCESSING UNITS

Result

Finished Product

Black print with

grey fabric

NPEO: 8.0 ppm

OPEO 1.2 ppm

White print with

grey fabric
Grey fabric (body)

NPEO: 4.0 ppm

OPEO 1.2 ppm
NPEO: 10 ppm
OPEO 2.0 ppm

Dyeing

Printing

Incoming
Water

ND

NPEO: 65 ppb

Chemical
Products
used

Stabilizer
Wetting
agent
Stabilizer

Not detected
Not detected

Clear effect

Not detected

Orient Paste

White Paste

Black Pigment
Wastewater
Discharge

ND

ND

Sludge

ND

ND

Not detected
Not detected
Not detected
NPEO: 1.8 ppm
OPEO: 1.05 ppm

Results- Source of APEO overview

Greenpeace
Results

19ppm

21ppm

3.1ppm

5ppm

Sample

H&M Results

Highest content NPE from

collar strip (blue)

Incoming water at 1.4ppb

High possibility of
contamination from
Silicon oil found in
washing unit at NPE 3470
ppm (but no evidence or
indication that it is in use)

Highest APEO
concentrations
found in areas of
print

2 out of 3
formulated
pigments were
tested positive

We believe the
main APEO source
is from the binders
(also found in
formulated
pigments)

APEO was found in

shell fabric when
tested as a finished
garment

APEO found in a
mix range of
auxiliaries used,
ranging in
concentrations
from 4.0 ppm to 4.6
ppm

Key Findings:
1.
2.

APEO has been detected across the production chain at different tiers by different sources.
Main sources: Softeners, Binders and formulated pigments.

1.8 ppm was found

in the black
pigment

Assumption is that
the body fabric is
already
contaminated
before entering
production (as
there was no
washing or dyeing
in our production
scope therefore
could not add
contamination)

APEO found in incoming ground

water at 65 ppb

Next Step
This APEO investigation has provided us a snapshot towards the sources of APEO contaminations. Results have
indicated that there is no intentional of APEO in our products, and that in most cases, the detected levels are at
background levels.
BARRIERS
The definition of Zero. Right now, background concentrations of hazardous chemicals can be detected, for
example, in the incoming water of factories. Currently, our chemical supplier's ability to ensure of APEO free
means not intentionally used.
Coverage beyond Tier 1 and 2 suppliers.
Right now, our direct business partners are what we call Tier 1 suppliers. We need to configure how we deal
with suppliers beyond our direct influence.
NEXT STEPS
As all contamination sources comes primarily from chemicals, we will work and communicate with some major
chemical suppliers to see what is possible in terms their ability to supply Zero APEO products.
Overall, the industry needs to work in a collaborative way; Cover efforts with our business partners no matter
direct or indirect. This includes the involvement of our suppliers (1st and 2nd tier suppliers), chemical suppliers,
service providers (e.g. BV), and the government.
BEYOND APEO
In line with our zero discharge of hazardous chemicals by 2020 commitment, we will in the next 18 months
expand beyond this study, and make investigations on the presence of other hazardous chemicals in our supply
chain. Until then, we are able to grasp a better picture towards how to plan and scale up, and reduce negative
environmental impact across our supply chain.

Publication details

Contact Details
Media Relations
mediarelations@hm.com