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Labor für chemische und physikalische Prüfungen an Textilien, Leder und Bedarfsgegenständen Laboratory for chemical and physical testing on textiles, phone : ++49 (0) 40- 300 33 73-1527 / fax -1821
Hansecontrol • Wandsbeker Str. 13c-f • D-22179 Hamburg Manager of Lab for Chemistry and Textile Physics Phone: Dear Sir/Madame, Two new changes to European legislation have become relevant for the OTTO Group. 1. the classification of the blue dye in the silica gel drying agent packet as
“substance of very high concern” and
2. a legal ban on the substance dimethyl fumarate effective as of 1 May, which is
often added to the silica gel packet as a biocide.

In order to avoid moulds, one or more SILICA GEL packet(s) is/are often included with shoes and
other products. In the course of current tests of this drying agent, the substance dimethyl
fumarate, which represents a health hazard, was found. As a biocide, is serves to also prevent
moulds in the product.
The primary substance itself, the drying agent silica gel, causes no problems of any kind.
Today, a considerable part of the silica gel bag is impregnated with hazardous substances:
1. Blue Colour Indicator
When used as a drying agent (e. g. in shoe boxes), silica gel does not need a colour
indicator (blue or orange dye). The widely used blue colour indicator cobalt dichloride
was, due to its carcinogenic potential, classified as a substance of very high concern
(SVHC) in the new European REACh Directive.
In February, a registration process according to REACh was initiated.
German discounters have already responded to this with a ban.
2. Biocide, Dimethyl fumarate
Tests of silica gel packets in December of 2008 and January/February 2009 have shown
that a considerable number of silica gel packets used for leather products, particularly for
shoes, have been treated with the substance dimethyl fumarate as a preventative
measure for killing moulds.
Dimethyl fumarate is a severe contact allergen, which, even at low concentrations,
results in severe allergic reactions right up to burn-like injuries when it comes into contact
with the skin.
As of May 1st 2009, the EU has ruled to ban this substance across Europe.
This concerns all products, also those already on the market. It must be ensured that all
products with a dimethyl fumarate concentration of more than 0.1 mg/kg are taken off the
market.
It is unusual that the EU is so quick to ban a substance, but this has occurred due to severe
allergic reactions in consumers triggered through contact with this chemical.
Labor für chemische und physikalische Prüfungen an Textilien, Leder und Bedarfsgegenständen Laboratory for chemical and physical testing on textiles, phone : ++49 (0) 40- 300 33 73-1527 / fax -1821
Hansecontrol • Wandsbeker Str. 13c-f • D-22179 Hamburg
Hansecontrol recommends immediately banning the use of both substances

dimethyl fumarate (biocide, CAS-No. 624-49-7) and
Cobalt dichloride (blue humidity indicator in silica gel, CAS No. 7646-79-9)

as of now and to promptly inform the suppliers affected by this.
Hansecontrol also recommends, particularly with respect to dimethyl fumarate that will be
subject to a legal ban in the near future, conducting controls in the scope of random
sampling of incoming goods and those already received.
The results serve to assess the current situation and to prepare suitable measures for
implementing the new legal requirements.
This generally concerns all product groups, particularly all types of leather products (shoes,
clothing, accessories, and furniture).
The prices for such tests amount to
1. Cobalt dichloride € 50.00 2. Dimethyl fumarate € 90.00

Source: ftp://mail2.tuttibambini.co.uk/tuttibk/Users%20Data/Export1/customer%20datebase/OTTO/DMF_OTTO_25032009_GB.pdf