REACH restricted substances for apparel buyers
REACH is EU chemicals legislation, not a certification, and no body issues a document declaring a garment or a factory REACH compliant. What it does is restrict certain substances in articles under defined conditions, and separately require information to be passed on about substances of very high concern. Those are two different mechanisms, and confusing them is a common error in apparel sourcing.
Contents
REACH, Regulation (EC) No 1907/2006, is the European Union's framework regulation for the registration, evaluation, authorisation and restriction of chemicals. Most of it concerns substances and mixtures and has little direct bearing on a clothing buyer. Two parts of it matter a great deal, and they work differently from one another.
A garment is an article
REACH defines an article as an object which during production is given a special shape, surface or design that determines its function to a greater degree than does its chemical composition. A t-shirt is an article. So, individually, are the zip, the button, the label and the printed transfer on it, which is why component-level questions arise at all.
This definition is not academic wording. It decides which obligations attach to what you are actually selling, and it is why chemical requirements follow components rather than stopping at the fabric.
Annex XVII: restrictions
Annex XVII is titled restrictions on the manufacture, placing on the market and use of certain dangerous substances, mixtures and articles. It is a numbered list of entries, and each entry is organised in two columns: the designation of the substance, the group of substances or the mixture, and the conditions of restriction.
That second column is the part buyers often skip, and it is where the actual requirement lives. A restriction is rarely a blanket prohibition. It is typically a combination of four things.
- Which substance, or group of substances, is restricted.
- In what, the material, the article type, or the kind of component it applies to.
- Under what use condition, for textiles this is frequently framed around contact with skin, which is why the same substance can be restricted in one product and not in another.
- Above what concentration, expressed against a stated method of determination.
A clear textile example is the restriction on certain azo colourants: it applies to textile and leather articles that may come into direct and prolonged contact with human skin or the oral cavity, and it concerns dyestuffs that can break down under defined conditions to release specified aromatic amines above a stated level. Every element of that sentence is doing work. Change the article type or the contact condition and the applicability changes with it.
Other entries relevant to apparel are scoped to particular components rather than to garments generally, for example restrictions concerned with the release of nickel from items in prolonged contact with skin, which reach metal trims and fastenings rather than fabric, and restrictions on plasticisers that reach flexible plastic components rather than woven cloth. Determining whether a particular component falls inside that kind of scope is a component-specification question, covered in trims and components.
The Candidate List is not the restriction list
This distinction causes much confusion in apparel sourcing, because both lists are informally described as banned chemicals and neither one is quite that.
| Annex XVII restrictions | Candidate List | |
|---|---|---|
| What it does | Restricts or prohibits manufacture, placing on the market or use, under stated conditions | Identifies substances of very high concern under the regulation's criteria |
| Effect on an article | The article may not be placed on the market where it falls within the conditions of the entry | Triggers a duty to communicate information, not a prohibition on sale |
| What a buyer does with it | Establishes whether the entry applies to this material, component and use, and verifies against it | Establishes whether such a substance is present above the threshold, and if so passes the information on |
| How it changes | By amendment to the annex | By periodic updates to the list |
Article 33: the duty to communicate
Where an article contains a Candidate List substance above 0.1% by weight, the supplier of that article must give the recipient sufficient information available to the supplier to allow safe use of the article, including as a minimum the name of the substance. On a consumer's request, the same information must be provided free of charge within 45 days. The list itself is maintained and updated by ECHA at echa.europa.eu, and that is where its current contents should be read.
Two things follow for a clothing programme. The obligation runs down the supply chain, which is why buyers ask their manufacturers about it and manufacturers ask their material suppliers. And it is an information obligation: the presence of such a substance above the threshold does not by itself stop the goods being sold, but failing to communicate it is its own problem. Information notified under this mechanism also feeds the EU database maintained for that purpose, which is a separate topic from the specification work described here.
There is no REACH certificate
No EU body issues a document certifying that a factory or a garment is REACH compliant. When a supplier offers one, what is being offered is either a self-issued statement described in borrowed language, or a laboratory report against a selected set of restrictions being presented as something broader.
What genuinely exists, and what is worth asking for:
- A supplier declaration stating the supplier's position against specified restrictions, for specified materials. Useful, and an attestation rather than a measurement.
- A laboratory test report covering named substances or substance groups, by stated methods, on a defined sample. Analytical, and limited to what it actually covers.
- A compliance statement setting out the supplier's assessment for a defined product. A position, not a regulator's document.
- A product certification such as OEKO-TEX STANDARD 100, which certifies against that scheme's own criteria: a related question, but not the same one. See OEKO-TEX STANDARD 100 explained.
Specifying REACH requirements properly
The instruction make it REACH compliant is not a specification, for the same reason that make it fit well is not a measurement chart. It tells a factory the objective and nothing about the criteria.
What turns it into a workable requirement
- State the destination market or markets, since the applicable law follows where the goods are sold.
- State the product category, and whether it is intended for children, because contact and use conditions differ.
- Name the restrictions or substance groups your programme requires evidence against, rather than the regulation as a whole.
- Say whether your own RSL applies as well, and give its version, it will usually go further than the regulation.
- List the materials and components in scope: fabric, dyes and finishes, prints and coatings, metal trims, plastic components, labels.
- Say what evidence you will accept for each: existing supplier documentation, a declaration, or new testing.
- Say whether Candidate List information is required as part of the submission, and in what form.
- Say when the evidence is needed relative to material booking, sampling and shipment.
How the rest of a technical brief is written is covered in how to write an RFQ, and the general architecture of chemical requirements, including where a buyer RSL and an industry programme sit alongside the law, in RSL and MRSL. What a returned report proves is covered in chemical test reports.
Where REACH sits next to EU labelling
REACH is about what is in the product. EU labelling rules are about what is stated on it: fibre composition, language, durability and who carries the legal responsibility for the goods placed on the market. They are separate obligations that arrive together in practice, and both are covered for the label side in EU apparel labelling compliance.
One shared point is worth making. Both attach to the product being placed on the EU market rather than to the factory that made it, which is why a buyer importing into the EU carries obligations that cannot be transferred to a supplier outside it by contract alone.
Questions this raises
Is there such a thing as a REACH certificate?
No. REACH is EU legislation and no EU body issues a certificate declaring a factory or a garment compliant with it. What exists is supplier declarations, laboratory test reports against specified restrictions, and compliance statements. A supplier offering a REACH certificate is describing something that does not exist.
Does REACH apply to a garment made outside the EU?
The obligations attach to the product being placed on the EU market rather than to where it was manufactured. A garment made anywhere and sold in the EU is within scope, which is why the importer carries obligations that cannot simply be contracted away to a supplier outside the EU.
What is the difference between Annex XVII and the Candidate List?
Annex XVII contains restrictions: an article falling within the conditions of an entry may not be placed on the market. The Candidate List identifies substances of very high concern and triggers a duty to communicate information about their presence above a threshold, rather than a prohibition on selling the article.
Does REACH restrict a substance in all products equally?
No. Restrictions are written with conditions: the substance, the material or article type, the use condition, for textiles often direct and prolonged skin contact, and a concentration determined by a stated method. The same substance can be restricted in one article and not in another.
How should a buyer state a REACH requirement in an enquiry?
Name the destination market and product category, the restrictions or substance groups evidence is required against, whether your own RSL applies and in which version, which materials and components are in scope, what evidence you will accept for each, and when it is needed. Make it REACH compliant on its own is an objective rather than a specification.
Bring the requirement to material selection
Restricted-substance requirements are cheapest to meet while materials are still being chosen. Send the destination market and the restrictions your programme needs evidence against, and we will work through what the material suppliers already hold and where a gap remains.
Discuss a specification