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REACH for the textile industry

REACH is short for Registration, Evaluation, Authorization and Restriction of Chemicals.

Regulation (EC) No 1907/2006 - REACH - wants to guarantee the safe use of chemical substances and preparations throughout the entire industrial production chain and therefore imposes not only obligations on the producers and importers of chemicals concerning the gathering and distribution of information on the characteristics of the substance, but also on the downstream users, such as textile manufacturers. After all, each downstream user has to assure the proper safe use of chemicals and see to it that the necessary information is sent to the chain, also about substances contained in articles.

Obligations for producers and importers of chemical substances

In a nutshell

The supplier guarantees that the articles he produces in or imports into the European Economic Area are in conformity with:

    • The Regulation on Registration, Evaluation, Authorisation and Restriction of Chemicals (EC 1907/2006 - REACH)
    • The obligation to communicate: suppliers of articles which contain a substance of very high concern (SVHC) in a concentration above 0.1% (weight by weight) have to provide enough information to allow the safe use of the article to the recipients of the article. see http://echa.europa.eu/candidate-list-table
    • The annex XVII of REACH related to substances that may only be used in a restricted manner and of which the restrictions are specified in the REACH regulation

Most REACH obligations apply to the producers and importers of chemical substances, as such or in preparations. They first have to register the substance and to apply for its authorisation if need be. The obligation to register came into force on June 1st, 2008. However since it is impossible to draw and process all files at once, a postponement is foreseen for pre-registered substances until December 1st, 2010, June 1st, 2013 and June 1st,2018 in function of the amount and hazardous properties of the chemical substance.

On chemical substances and preparations

The REACH communication tool on chemical substances and preparations is the safety data sheet. Another part is added to the SDS, i.e. the exposure scenario reproducing the risk management measures for identified uses. This exposure scenario will be deducted from the chemical safety report that is drafted upstream the chain for the registration file and will gradually become available after registration of the substance.

Obligations of the producers of articles

REACH is a European community regulation that directly applies in all member states of the European Union.
If you are an EU based company then it is your responsibility to ensure any textile products, including chemicals used in their manufacture, whether they have been produced outside or within the EU, have been evaluated to ensure they are REACH compliant.
If you are a textile company based outside of the European Union then you are obliged to inform your buyers, which are EU based, on the status of SVHC within products/chemicals that are supplied to them.
By not supplying this information to your buyers you will be at a serious disadvantage to your competitors and this could potentially lead to your EU customers sourcing products from a REACH compliant supplier.

Registration of substances intended to be released from an article

Each producer or importer of an article from which chemical substances are intended to be released (e.g. perfume molecules in t-shirts or curtains) has to register this chemical substance if it exceeds 1 ton per year (art. 7.1). If this chemical substance has already been registered by the producer upstream in the (European) supply chain, you don’t have to do it again.

Communication on chemical substances in articles

Each downstream user has to inform its customers according to article 33 of REACH if the article contains a substance of very high concern listed in the candidate list for registration in Annex XIV of REACH, in a concentration of more than 0.1% (w/w). This information has to mention the name of the substance as well as the dangers, the conditions of safe use and the appropriate risk management measures for its entire life cycle, including waste phase, of the article.
The candidate list will be updated twice a year with substances of very high concern as determined by the member states. The most recent candidate list is published on the ECHA website. The publication of a so-called substance of very high concern on the list, immediatiely involves the obligation to communicate. Consumers must be informed on their demand and this within a period of 45 days following their request. Example: PVC coatings with phthalates in concentrations of more than 1% or fire retardant HBCD in more than 0.1% in FR curtains.
REACH does not ask you to communicate the entire chemical composition of your textile product, nor to hand over all safety data sheets of the used chemicals products to your client!

Supplying textile products in conformity with the imposed restrictions

On June 1st, 2009, the existing directives concerning the limitations on marketing chemical substances as such, in preparation or in articles have been inserted into annex XVII of REACH. This means that the supplied textile products have to comply with the applicable restrictions, such as the immeasurable presence of azo-dyestuffs that can split into carcinogenic aromatic amines.

Controlled use of chemical substances

The textile industry uses a lot of chemical substances. As a downstream user, you are obliged to evaluate and apply risk reducing measures before using the chemical substances. You will receive this information by means of the safety data sheet of your supplier. If you do not agree with the risk management measures or conditions of use you have to inform the European Chemical Agency (ECHA) about it within 6 months upon reception of the product with safety data sheet and comply yourself within a period of 12 months. You can do so by mentioning your use to the supplier or to carry out a proper chemical safety analysis. There are a number of reasons why you do not have to draw up a proper chemical safety report (art. 37.4). Also when using substances falling under the authorisation obligation (substances listed in annex XIV) you will have to inform ECHA hereof.

Mentioning your use of the chemical substance to the supplier in order to turn it into an identified use

Each industrial user of chemical substances has the right (not the obligation) to inform his direct supplier about the use of the product in order to turn it into an identified use. The advantage is that by doing so it will be added to the registration file of the producer of the substance at the top of the chain and that you will receive the corresponding risk management measures through the safety data sheet.

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