REACH Regulations - How they apply
to Textile and Leather articles
What is REACH?
It is an EU Regulation,
Regulation (EC) No 1907/2006, of the European Parliament and of the
Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation
and Restriction of Chemicals (REACH)
The European Chemicals Agency (ECHA)
has published numerous guidance documents on this very complex piece of
legislation. You can view these at their website: http://echa.europa.eu/home_en.asp.
What are the objectives of REACH?
REACH places responsibility on all
manufacturers and importers of chemicals to identify and manage the risks
that those substances which they manufacture and market may pose to human
health and to the environment.
What does it actually mean to
clothing manufacturers and retailers?
The key part of REACH that affects
this industry sector is that which relates to substances in articles,
whether those substances are intended to be released and whether they
are substances of very high concern (SVHC).
Definitions of the key words are as
A substance means a chemical
element and its compounds.
Two or more substances mixed together are known as a preparation
e.g. printing inks, dyes.
An article is "an object
which during production is given a special shape, surface or design which
determines its function to a greater degree than does its chemical composition"
Items such as a shirt, a shoe or a handbag are therefore articles, because
their shape and design is what is important, rather than the chemicals
that they are made from or contain.
Substances of very high concern
(SVHC) include those classified as
Carcinogenic, Mutagenic or toxic to Reproduction (CMRs),
Persistent, Bio accumulative & Toxic (PBTs)
Very persistent very bioaccumulative (vPvBs)
So the T-shirt I am selling is an "Article" - what do
I do now?
You need to establish the following
- What chemicals are in your shirt?
- Are any of these chemicals intended
to be released?
- If they are intended for release,
are you using more than 1 tonne of the chemical per year in all of your
- Are any of these chemicals "substances
of very high concern" (SVHC)? If they are, are they present in
the product at levels in excess of 0.1% by weight?
Why do I need to know this?
REACH has some basic rules you must
Substances intentionally released
from Articles must be registered for that specific use if
they are present in those articles in quantities over 1 tonne per producer
or importer per year
Notification of substances of
very high concern in Articles is required if they are present
above a concentration limit of 0.1% by weight and if more than 1 tonne
per year is used in all products.
Even if SVHC does not accumulate up
to the Notification threshold, supplier of articles have to provide recipients
with sufficient information to allow safe use of the article if SVHC is
present and exceeds 0.1% by weight.
If a consumer makes a request on safety
information about SVHC in an article, supplier of the article must provide
such relevant information, free of charge, within 45 days.
How do I decide if something
is "intended to be released"?
Here are some examples to help clarify
1. Machine -washable 100% cotton
men's shirt, dyed brown, with a non-iron finish.
The chemicals to consider in this
product are the dyes used to give colour and the cross-linking resin used
to give the crease-resistant finish.
Although some dyestuff may be lost
when the garment is washed, the ECHA guidelines for substances in articles
regards this as unintentional release, so the chemicals in the dyestuff
used in this product do not need to be registered.
The crease-resistant finish is not
intended for release, so the chemicals in this substance also do not need
to be registered.
2. Black leather jacket, labelled "dry clean only"
Again, dyestuffs lost when the garment
is dry-cleaned would be regarded as unintentional release, so registration
of the dyestuffs is not required.
3. Lavender - fragranced sheets and pillowcases
In this case, the fragrance is intended
to be released. So, the retailer selling the product needs to
- Identify the chemicals that make
up the fragrance.
- Calculate the total amount of these
chemicals in the product
- Calculate if they will use more
than 1 tonne of the substances per year, based on the number of products
they expect to sell
If the usage is less than 1 tonne
p.a., registration is not required.
If they expect to use more than 1 tonne p.a. they must register the chemicals
for that specific use.
4. Denim jeans and pigment-dyed
These products are a matter for debate!
Traditional indigo -dyed denim loses colour when washed; so do pigment
dyed products. It could be argued that this release is not intentional,
just as with other dyed fabrics. However, these products are frequently
sold as "designed to fade" - in other words, their loss of colour
is being used as a marketing feature. In this case, it would be reasonable
to conclude that the loss of dyestuff is intended release.
The safest route would be for the
retailer to register the indigo and pigment dyes; or to buy these products
from suppliers who have already registered the dyestuffs for this end
Anyone in the supply chain can register
a substance - what is important when registering a substance is to ensure
that it has been registered for the specific use that you intend to use
What about substances of very
high concern (SVHCs)?
The list of possible SVHCs is huge,
so it would be impractical to test for all of them in all textile and
Exploring the supply chain for chemicals
being used in products and establishing a list of Restricted Substances
that might reasonably be expected to be found in these products is the
preferred route of many major retailers.
So what might be on a Restricted
Substances List (RSL)?
It should include chemicals already
restricted by EU Directives e.g. azo dyes, nickel, cadmium, etc. It may
also contain other chemicals known to harm humans or the environment.
It must list chemicals that are present not only in textile fabrics and
leather, but also those found in metal and plastic components such as
zips and buttons.
It is very difficult to produce a
"standard" RSL, because each retailer has different supply chains,
sells different products and sells them in different countries. So, although
most RSL's will be largely similar, a RSL really should be tailored for
How does the RSL help me with
substances of very high concern?
Specifying that all the chemicals
in the RSL must be present at levels below 0.1% by weight (1000ppm) will
be in line with the REACH compliance limit for SVHCs. In actual fact,
the majority of chemicals in a RSL will actually have a maximum permitted
limit of much less than 0.1%.
The important thing is to check that
the levels of SVHCs in your products meet your specified limits. You can
do this by requesting test reports from your suppliers, or by carrying
out independent due diligence checks of your own on goods already in store.
Intertek are able to assist you with both testing and in setting up a
due diligence monitoring programme tailored to suit your product range.
Using more than 1 tonne p.a.
For a retailer with a wide range of
products, it is possible that SVHCs are unavoidable in certain products
or packaging materials, and it becomes an important job for the retailer
to accumulate the SVHCs quantities and monitor against the 1 tonne p.a.
This may be an impossible task to
be done on a manual basis. Intertek provides an IT based system tailor-made
for brands and retailers to manage product regulatory requirements including
REACH (registration, SVHC and notification tracking).
For more information about product
safety, you may ask Intertek expert by filling in this enquiry