REACH: Registration, Evaluation, Authorization and Restriction of Chemicals
Textile industry chemicals imported into Europe — a summary for the apparel and textile trade.
Please Read First
We are NOT experts or an authority on this subject. Please consult with the appropriate agencies for correct and current information on this subject. This is time sensitive information. Rules and regulations often change. Utilize the information on this page at your own risk. The information on this page was posted November 2008. It is important that you consult directly with the REACH website for the most up to date and correct information. Do NOT rely on the information listed on this page as your only research. This page is only to be used as an initial summary to learn some of the issues as per our understanding in Nov. 2009.
Below is in reference to textile industry chemicals imported into Europe. You may be aware of the European initiative called REACH (Registration, Evaluation, Authorization and restriction of Chemicals). This is an initiative that requires each manufacturer of a chemical substance (reaching the threshold described below) imported into the European Union and a user of that substance to register with a governing body called ECHA (European Chemicals Agency, http://ec.europa.eu/echa/).
Related Industry Topics
Who Has to Register
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 this initiative. It is the responsibility of the maker or user to register the chemicals that meet the threshold.
The 1 Tonne Threshold
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 process, and if they meet the threshold, whether they have been pre-registered with ECHA. Please note 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.
Pre-Registration and Reference Numbers
The first 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, http://reach.jrc.it/navigator_en.htm, that will assist entities in determining their responsibility. In addition, the ECHA REACH website has information for Downstream Users and what their obligations are at http://reach.jrc.it/downstream_users_en.htm.
Substances of Very High Concern
In addition, there is a list published by ECHA: Substances of Very High Concern (SVHCs). The vendor must certify that these substances are not present in the fabric and garment dyes. This could trigger notification and communication requirements under REACH if the SVHC amount is greater than 0.1% w/w.
References & Further Reading
Common Questions
What is REACH?
REACH is a European initiative: Registration, Evaluation, Authorization and restriction of Chemicals. It requires each manufacturer of a chemical substance imported into the European Union, and a user of that substance, to register with a governing body called ECHA, the European Chemicals Agency, when the substance reaches the threshold described on this page.
What is the REACH registration threshold?
The threshold is 1 tonne imported into Europe on an annual basis. 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.
What is a downstream user under REACH?
Production agents and wholesalers may be considered a Downstream 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 this initiative. It is the responsibility of the maker or user to register the chemicals that meet the threshold.