in reference to textile industry chemicals
imported into Europe.
You may be
aware of the new European initiative
called REACH (Registration, Evaluation,
Authorization and restriction of Chemicals).
This is an initiative that requires each
manufacturer of a chemical substance (reaching
threshold described below) imported into
European Union and a user of that substance to
register with a governing body called ECHA
(European Chemicals Agency,
http://ec.europa.eu/echa/ ). Production
agents and wholesalers may be considered a Downstream
User. For example chemical substances are used
by the dye manufacturer and the fabric mill. So
the dye maker is termed the manufacturer, the
mill is the user. Since wholesalers
and production agents purchase finished
fabric or a garment they
are termed the downstream user
and may not be directly responsible for managing
It is the responsibility of the maker or
user to register the chemicals that meet the
The threshold is 1
tonne imported into Europe on an annual basis.
If you are
shipping to Europe, it is a good idea for you to
check with your suppliers regarding the
chemical substances that
are used in the manufacturing of garments during
the dyeing and finishing
if they meet the threshold - have they been
pre-registered with ECHA.
the 1 tonne threshold does not apply to the
weight of a garment but to the amount of each
chemical substance used in that garment.
step is for the dye maker or chemical substance
maker and the user to pre-register each chemical
covered with the ECHA by December 1st. When a
chemical substance is registered with ECHA the
maker will be issued a reference number.
REACH has an
online tool called the REACH Navigator tool,
will assist entities in determining their
In addition, the ECHA REACH website has
information for Downstream Users and what their
obligations are at
there is a list published by ECHA; Subtances
of Very High Concern (SVHCs). The vendor
must certify that these substances are not
present in the fabric/garment dyes. This could
trigger notification and communication
requirements under REACH if the SVHC amount is
greater than 0.1% w/w.