REACH and SVHC Compliance for Textile Manufacturers (2026)

REACH (Regulation (EC) No 1907/2006) is EU chemicals legislation that places obligations on companies that make, import or use chemicals in the EU. For a textile manufacturer outside the EU, REACH usually does not apply to you directly. The practical question is whether the products you make contain substances that trigger information duties or restrictions for your EU customer. This article is practitioner guidance for factories, not legal advice. Check the current legal text and ask your customer's REACH contact if you are unsure.

The 0.1% Rule: Per Article, Not Per Garment

Under REACH Article 33, a supplier of an article that contains a substance on the SVHC Candidate List above 0.1% weight by weight must give the recipient enough information to use the article safely, and must give a consumer the same information on request. The key question is what the 0.1% is measured against. The Court of Justice of the EU ruled in 2015 (Case C-106/14) that the threshold applies to each article incorporated as a component of a complex product, not only to the finished product as a whole.

In practice, this means a component that is itself an article can trigger the duty even if it is a tiny share of the garment's weight. Fictional example: a metal zip contains a Candidate List substance at 0.3% of the zip's own weight. The zip makes up 1% of the garment's weight, so the substance is about 0.003% of the garment. A calculation against total garment weight shows nothing, yet the 0.1% threshold is exceeded for the zip. Calculating only against the whole garment can therefore understate your exposure. Which components count as separate articles is a legal question covered by ECHA's guidance on substances in articles, so confirm it with your customer or a regulatory specialist.

Many textile buyers also ask for material-level data, for example for fabric, trims, prints and labels, because it makes testing and supplier data easier to manage. That is a sound practice, but the legal unit for Article 33 is the article, not the homogeneous material. Homogeneous material is a concept from other EU laws such as RoHS. Do not assume it sets the REACH threshold.

What the SVHC Candidate List Contains

The Candidate List is maintained by ECHA (the European Chemicals Agency). It is usually updated twice a year. On 4 February 2026 ECHA added n-hexane and bisphenol AF (BPAF) and its salts, raising the list from 251 to 253 entries. I did not find a later 2026 update. Check echa.europa.eu for the current list before you rely on this number.

Restrictions That Matter for Textiles (Annex XVII)

The Candidate List creates information duties. Annex XVII is different: it contains legal restrictions, so a product that breaches one cannot be placed on the EU market. Substances that textile factories most often encounter include:

The PFHxA restriction (Annex XVII Entry 79, Regulation (EU) 2024/2462) matters now. It sets limits of 25 ppb for PFHxA and its salts and 1,000 ppb for PFHxA-related substances. It applies from 10 October 2026 to clothing and related accessories made of textiles, leather, furs and hides, and to footwear for the general public. It applies from 10 October 2027 to other textiles, leather, furs and hides for the general public. Check whether any of your water-repellent or stain-release finishes use fluorinated chemistry. A broader EU proposal to restrict PFAS as a group is under evaluation, so check its current status before relying on it. Entry numbers and limits should be confirmed in the current consolidated Annex XVII.

What Non-EU Manufacturers Need to Do

Direct REACH registration is almost never required for a finished-goods manufacturer outside the EU. Your EU customer, as importer, holds the legal duties. What they need from you is accurate, current substance information so they can meet their Article 33 duties, plus evidence that Annex XVII restrictions are met.

The SCIP database is a separate requirement under the EU Waste Framework Directive, not under REACH. Since 5 January 2021, EU suppliers of articles that contain a Candidate List substance above 0.1% must submit information on those articles to ECHA. The data they submit has to come from the supply chain, so if your factory cannot supply it, your customer cannot complete the notification. Ask your customer exactly which data fields they need.

A practical factory REACH programme keeps: a map of components and materials in each main product type, checked against the current Candidate List; chemical inventory records showing which dyes, auxiliaries and finishes you use; test reports from an ISO/IEC 17025 accredited laboratory for the restricted substance groups your customers ask about; and a process to review your data each time the Candidate List changes. Many buyers expect test reports to be recent, often within 12 months, but that is a customer requirement and not a REACH rule.

Why Your Buyer's RSL Is Not the Same as Your Legal Obligation

REACH sets the legal minimum for the EU market. Many brands operate Restricted Substances Lists (RSLs) that go beyond it. The AFIRM Group RSL is used by many apparel and footwear brands and is updated regularly. ZDHC's MRSL (Manufacturing Restricted Substances List) targets process chemicals used in manufacturing, not only substances in the finished article, which is a different and more demanding layer.

The practical consequence is that a factory can pass a REACH-based test and still fail a brand's RSL requirements. Treat a buyer's RSL as your operating compliance standard, and treat REACH compliance as the floor. If you test only to REACH and present that report to a brand with an RSL, it may not be accepted.

Connecting REACH to the Digital Product Passport

The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) will introduce the Digital Product Passport (DPP). The Commission's ESPR working plan gives an indicative 2027 date for the textiles delegated act, and a delegated act normally applies 18 months after entry into force. These are estimates and not confirmed deadlines. The detailed data requirements for textiles are not final, so do not assume they will match SCIP. A factory that already holds organised substance and material data will find any DPP request easier to answer, and building it now costs little.

REACH compliance checklist for textile factories

• Map the components and materials in your main product types: base fabric, labels, trims, prints, coatings, fasteners and accessories. Note which components are separate articles.
• Check your dyes, auxiliaries and finishes against the current Candidate List at echa.europa.eu. The list updates about twice a year, so a check from 12 months ago may be out of date.
• Check your finishes for PFHxA and related substances now, because the restriction applies to clothing, accessories and footwear for the general public from 10 October 2026.
• Ask each EU customer which test scope, report format and data fields they require. Commission ISO/IEC 17025 accredited test reports for the restricted substance groups they name.
• Calculate Candidate List content for each article or component that could be a separate article, not only against total garment weight.
• If customers use AFIRM, the ZDHC MRSL or their own RSL, obtain the current version and compare it with your test scope.
• Prepare a data package for each EU customer: substance name, CAS number, concentration range, and the article or component it is in.

References

Regulation (EC) No 1907/2006 (REACH), Articles 33 and 59, Annex XVII. Regulation (EU) 2024/2462 (PFHxA restriction, Annex XVII Entry 79). Directive 2008/98/EC (Waste Framework Directive, SCIP). Regulation (EU) 2024/1781 (ESPR). Court of Justice of the EU, Case C-106/14 (Article 33 threshold applies to each article in a complex product), as summarised by Jones Day. SGS SafeGuardS 021/26 on the February 2026 Candidate List update. UL Solutions on Regulation (EU) 2024/2462. Sources consulted on 8 October 2026. Confirm entry numbers, limits and dates in the current legal texts.

Frequently Asked Questions