Restricted substances in textiles: REACH and buyer lists
Most textile buyers now ask for chemical compliance as well as quality. Here is what REACH covers, how buyer restricted substance lists work and what is usually tested.
A textile order is judged on more than colour, weight and fastness. Brands and retailers selling into Europe and other regulated markets need to show that their products do not contain restricted chemicals above set limits. For a buyer, it helps to understand the framework, so that requests to a mill are precise and test reports can be read with confidence.
REACH in outline
REACH is the European Union's chemicals regulation (Regulation (EC) No 1907/2006). Most of it concerns companies that manufacture or import chemical substances, but two parts apply directly to finished textile articles:
- Annex XVII restrictions: a list of substances that may not be present in certain articles above specified limits. Several entries concern textiles, for example the restriction on azo dyes that can release certain carcinogenic aromatic amines, the restriction on nonylphenol ethoxylates in washable textiles, and an entry covering a group of substances classified as carcinogenic, mutagenic or toxic for reproduction in clothing and textiles that come into contact with the skin.
- The Candidate List of substances of very high concern (SVHC): if an article contains a listed substance above 0.1% by weight, the supplier must give recipients enough information to use the article safely, and consumers can ask for the same information.
REACH is updated regularly as new substances are added to the Candidate List and new restrictions are adopted, so compliance is an ongoing check rather than a one-time certificate.
Buyer restricted substance lists
Many brands go further than the law. They publish a restricted substance list (RSL) that sets limits for chemicals in finished products, often combining requirements from several markets and adding substances of concern that are not yet regulated. Industry lists such as the AFIRM RSL are widely used as a common reference.
A second kind of list controls what goes into the process rather than what remains in the product. A manufacturing restricted substance list (MRSL), such as the ZDHC MRSL, sets limits on chemicals in the dyes, auxiliaries and finishes used at the mill, on the basis that preventing a substance from entering the process is better than testing for it at the end.
Product label schemes such as OEKO-TEX STANDARD 100 test finished textiles against their own criteria, which differ by product class, with the strictest limits for baby articles.
What is commonly tested on cotton
For woven, dyed and printed cotton the usual test parameters include:
| Parameter | Why it is relevant |
|---|---|
| Arylamines from azo dyes | Some azo colourants can split into restricted amines |
| Formaldehyde | Can come from resin finishes and some binders or fixing agents |
| pH | Residual acid or alkali from processing can irritate skin |
| Extractable heavy metals | Traces from some dyes, pigments and auxiliaries |
| Alkylphenols and their ethoxylates (APEO/NPE) | Historically used in detergents and auxiliaries |
| Phthalates | Relevant mainly to plastisol prints and coatings |
| PFAS | Relevant to water and oil repellent finishes, under growing restriction |
| Chlorinated phenols, organotins | Biocides and preservatives in some chemicals |
Not every parameter applies to every product. An untreated cotton with no repellent finish, for example, has no reason to contain PFAS, but a buyer may still ask for a test as part of a standard package.
Food contact is separate
Textiles used in direct contact with food, such as muslin and cheesecloth for kitchens and dairies, are covered by food contact rules, which have their own tests (such as migration testing) separate from REACH and apparel RSLs. A fabric that complies with an RSL is not automatically suitable for food contact, and the reverse is also true.
Working with a mill on compliance
Practical steps that make compliance smoother:
- Share your RSL, or the list you follow, at the enquiry stage, not after bulk production.
- Say which product class and market the fabric is for, since limits differ.
- Agree which tests will be done, by whom, and at what stage: on the development sample, on the first bulk lot, or periodically.
- Mention any finish that raises specific parameters, such as easy-care resins or pigment binders.
Print chemistry can also affect the test package, so it helps to discuss requirements alongside the choice between reactive and pigment printing. To discuss the requirements for your product, contact us.
