REACH
The European chemical control framework that regulates the registration, evaluation, authorisation and restriction of chemicals. Regulation (EC) 1907/2006 managed by the European Chemicals Agency (ECHA).
Context
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the European chemical control framework. It requires manufacturers and importers to register the chemical substances they place on the EU market and restricts or bans the use of dangerous substances.
Regulatory origin
Regulation (EC) 1907/2006 of the European Parliament and of the Council of 18 December 2006, published in OJEU L 396 on 30 Dec 2006. Amended regularly. Managed by the European Chemicals Agency (ECHA · Helsinki).
The 4 mechanisms of REACH
Registration · mandatory registration of substances above 1 tonne/year.
Evaluation · ECHA evaluation of registrations and priority substances.
Authorisation · prior authorisation to use Annex XIV substances (sunset date · the most dangerous substances).
Restriction · direct Annex XVII restrictions on the manufacture, placing on the market or use of dangerous substances.
Application to the textile sector
In textiles, REACH affects brands that import articles containing chemical substances (dyes, flame retardants, wetting agents, DWR treatments). Annex XVII contains over 70 restriction entries, several applicable to textiles (entry 27 nickel, entry 43 azo dyes, entry 72 CMR in textiles).
Timeline
REACH adopted
Regulation (EC) 1907/2006 published in OJEU L 396.
Entry into force
Progressive application by tonnage bands.
End of pre-registration
Close of the pre-registration period for existing substances.
Annex XVII updated
New restrictions are added via amending regulations (e.g. Reg. (EU) 2018/1513 entry 72 CMR textiles).
Applied case
A textile brand that imports textile dyes from China for its own dyeing line assesses its REACH compliance.
Collects the Safety Data Sheets (SDS) of the 12 imported dyes · verifies that they are registered under REACH (ECHA registration number).
Cross-checks the composition of each dye against the SVHC Candidate List · 2 dyes contain DBP phthalate at a concentration above 0.1 per cent weight/weight.
Substitution plan: identifies 2 alternative SVHC-free dyes with equivalent dyeing results · progressive transition over 12 months.
Common mistakes
REACH does not apply only to chemical manufacturers.
It also applies to importers and intermediate users (downstream users). A textile brand that imports chemically treated fabric is a downstream user with its own documentary obligations.
REACH is not met with an SDS signed by the supplier.
The Safety Data Sheet is documentary input. Compliance requires acting on the information: SCIP, authorisation if applicable, and upstream traceability.
A substance not listed in SVHC does not mean free use.
Annex XVII of REACH restricts specific uses. A substance may not be in SVHC and still be prohibited in a specific textile use (e.g. certain azo dyes).
REACH does not exempt you from specific obligations such as Forced Labour.
It is a chemical framework, not a labour one. Human rights due diligence lives in the CSDDD and in the Forced Labour Regulation.
Frequently asked questions
What is REACH?
Regulation (EC) 1907/2006 Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), published in OJEU L 396 (30.12.2006). In accordance with Article 1: to ensure a high level of protection of human health and the environment, as well as the free movement of substances on the internal market. The general framework for the control of chemical substances and mixtures in the EU.
Who does REACH apply to?
To any manufacturer, importer, distributor or downstream user of chemical substances or mixtures on the EU market above 1 t/year. For textiles it applies indirectly to the WHOLE chain: dyes, wetting agents, flame retardants, DWR finishes, metal accessories. The Article 33 obligation (SVHC communication in articles) directly affects final brands.
How is REACH complied with?
Through 4 key processes: (i) Registration of substances >=1 t/year (Title II), (ii) Evaluation by ECHA and national authorities (Title VI), (iii) Authorisation for Annex XIV substances (Title VII), (iv) Restriction for specific conditions of use (Annex XVII, Title VIII). For textiles: operational focus on Annex XVII (entries 27/43/46/47/50/61/72) and Article 33 (SVHC in articles).
What is the difference between REACH Annex XIV and Annex XVII?
Annex XIV (Authorisation) prohibits the use of the substance unless prior authorisation is obtained (an onerous process ~250,000 EUR). Annex XVII (Restrictions) directly prohibits manufacture/placing on the market/use for specific conditions — without the possibility of individual authorisation. Annex XVII is direct and operational; Annex XIV is administrative and selective.
What is REACH Article 33 and how does it affect textiles?
Article 33 requires the supplier of an article containing an SVHC at a concentration >0.1 per cent weight/weight to communicate to the B2B customer (on receipt of the article) or to the consumer (within 45 days of a request). It is the most critical operational REACH obligation for textile brands that import finished articles from Asia.
What is the difference between REACH and CLP?
REACH (Reg. 1907/2006) is the general framework for chemical control: registration, evaluation, authorisation, restriction. CLP (Reg. 1272/2008) is the implementation of the GHS system for the classification + labelling + packaging of dangerous substances and mixtures. REACH is the "what to control"; CLP is the "how to classify and label". They coexist and complement each other.
Fuentes oficiales
- European Parliament and Council · OJEU18 dic 2006 (consolidado vigente)Standard in force
- European Chemicals Agency2024Official information
- European Chemicals Agency2024Regulatory list
