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Substances of concern in garments

Chemical duties that already apply under REACH, and the wider substance disclosure the passport is expected to add.

Regulation (EU) 2024/1781, Article 2(27); Regulation (EC) No 1907/2006, Article 33 and Annex XVII

REACH duties apply now; SCIP notification since January 2021. Passport disclosure follows the delegated act, expected in 2027.

Two sets of rules meet here. REACH already restricts specific substances in garments and makes a brand answer for substances of very high concern in what it sells. ESPR adds a wider definition, substances of concern, which the textile passport is expected to disclose once the delegated act is adopted, expected in 2027.

What already applies under REACH

  • Annex XVII restrictions limit or ban named substances in textiles, certain azo dyes, nonylphenol ethoxylates, several phthalates and cadmium among them. They apply to the garment itself, whoever made it.
  • Article 33: a supplier of an article containing a candidate-list substance of very high concern above 0.1 percent by weight must tell business customers, and consumers on request, within 45 days.
  • SCIP: since January 2021, such articles must also be notified to the European Chemicals Agency's database before they are placed on the EU market, so that recyclers can find the information later.
  • The candidate list grows, usually twice a year, so a composition that was fine last season may need a new check.

What ESPR calls a substance of concern

  • A candidate-list substance of very high concern under REACH.
  • A substance classified in one of the hazard classes ESPR lists, such as carcinogenic, mutagenic, toxic to reproduction, an endocrine disruptor, or persistent and bioaccumulative.
  • A persistent organic pollutant under the POPs Regulation.
  • A substance that makes the product harder to reuse or recycle. This fourth group is new: a water-repellent finish, a bonded laminate or an antimicrobial treatment can count even when it is not toxic.

The study behind the textile act (JRC, May 2026) proposes that the passport states whether a garment contains substances of concern, and that where they sit and in what concentration is available to recyclers and authorities rather than to everyone. That is a disclosure of what is present, a different question from the restricted-substance list most brands manage today: a list says what was not found, the passport says what is there.

Where brands get caught

  • Treating a supplier test report against a restricted-substance list as the whole answer. Coatings, prints and trims carry most of the substances the fourth group catches.
  • Missing SCIP notifications. The duty has applied for years and market surveillance checks it, not only recyclers.
  • Assuming a sourcing country applies the same limits. Several substance groups are restricted in the EU and nowhere else in the chain.

What to prepare this season

  • Ask suppliers for positive chemical declarations per component, not only a pass against a list.
  • Record finishes, coatings, prints and trims separately from the fabric; that is where the disclosure will point.
  • Keep certificates from recognised schemes next to the styles they cover, with their validity dates.

One record

What the Seamdex record already carries

  • Substance statements per product on the Compliance tab: candidate-list substances above the threshold, the REACH authorisation and restriction lists, the POPs Regulation and the packaging substance rules, plus a free-text statement, all shown on the passport.
  • Treatments, coatings, finishes and prints recorded per layer from the vetted lists, with certificates attached to the fibres and components they cover.
  • A recyclability score whose criteria include the coatings and blends the fourth group is about.

Built around the data set the Commission's researchers have proposed, updated as the delegated act lands. Not a compliance claim: no one can make one before the act exists.

FAQ

Questions on this rule

For the REACH restrictions, a list and testing against it are the usual proof. For the passport, the expected disclosure is what the garment contains, so suppliers will need to declare finishes and coatings positively.

No. It defines what must be disclosed and what the ecodesign requirements may later address. A finish that hinders recycling is not banned by the definition, it is named.

A brand placing an article with a candidate-list substance above 0.1 percent on the EU market is a supplier of that article and has had to notify it since January 2021.

Regulatory dates last reviewed October 2026. Future dates are expectations, not law. This guide describes the rules; it is not legal advice.

Structure the data before the rules land.

One garment record, published the same day, at one price.

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