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Keep reading...On 23 September 1999, the Mars Climate Orbiter probe, which cost around 125 million dollars, disintegrated in the Martian atmosphere. No malfunction, no calculation error: one team of engineers was working in metric units, the other in imperial units. The numbers were correct. It was the reference list used to interpret them that was wrong.
Space probes aren’t lost in electroplating workshops. But the mechanism behind the error is identical: taking the ‘grammar’ of one process and applying it to a process that ‘speaks’ a different language. This is what has been happening for years in the metal accessories supply chain, which has been asked to reduce or eliminate substances on the basis of lists written for textiles, leather and plastics. Serious, well-constructed lists. Except they were designed for something else.
A LIST THAT DIDN’T EXIST
MRSL stands for Manufacturing Restricted Substance List: the list of substances subject to restrictions in manufacturing processes. The version published today within the ZDHC framework — the Zero Discharge of Hazardous Chemicals programme, which aims for zero discharge of hazardous chemicals into the environment — covers textiles, leather and plastics. Metal accessories have never been taken into account.
Ester Falletta, technical director of the Physis Consortium, uses two precise terms to describe what has happened in the vacuum left by that omission: distortions and misrepresentations. Demands were nevertheless made of suppliers, because brands could not afford to wait for a list that nobody was actually drawing up. And so a buckle, a zip or a clamp ended up being measured against a standard designed for other products.
WHO IS ACTUALLY QUALIFIED TO DRAW IT UP?
The real question is who is qualified to draw up such a list. Not a single manufacturer, who knows only their own ring well. Not a brand, which views the supply chain from the outside and from above.
Physis is the first consortium established to represent the entire metal accessory production chain: from metal refining to manufacturing plants, from software to supporting technological solutions, from base materials to semi-finished products, right through to surface treatments such as electroplating and varnishing. This structure has made it possible to bring together, around a single table, technicians overseeing different stages of production, supplemented by an international network of experts.
In 2025, the project to develop the MRSL for metal accessories officially began, with the Physis Consortium acting as lead organisation, in tandem with ZDHC.
ELECTROPLATING, CHAPTER ONE
By the end of 2025, the working group had finalised the first list: substances subject to restriction in electroplating processes applied to metal accessories.
This list comprises three main categories: metallic, organic and inorganic substances.
The document was submitted to the MRSL Council, which established a Technical Expert Group (TEG) comprising international experts in formulation, industrial plants and processes, sustainability, and brand representatives. The TEG, chaired by Ester Falletta, is finalising its review of the document, with final validation by the MRSL Council – the body responsible for its independent technical review – scheduled for October 2026.
NOT A LIST OF PROHIBITIONS
A list of restricted substances is instinctively seen as a ‘no entry’ sign, and therefore as a cost, a complication, a problem. But the situation should be viewed quite differently: the publication of the MRSL will not be an end in itself, but a starting point.
The logic follows that of progressive reduction plans, which accompany the use of a substance right through to its phase-out. And the list will be reviewed periodically, as technology within the supply chain advances. This is based on a criterion that rarely features in sustainability documents: alongside environmental protection and health and safety, the industrial and economic sustainability of the measures being proposed is also taken into account. In other words: no reduction that a real supply chain is unable to sustain.
Not a static list of obligations, therefore, but a programme that moves in step with research and, in some respects, drives it forward.
For years, the metal fittings sector has been asked to prove its environmental credentials using someone else’s yardstick. Now it is developing its own assessment system. A major step forward.
