REACH Proposed Restriction on Substances in Textiles & Clothing

REACH Proposed Restriction on Substances in Textiles & Clothing

The European Commission is looking for input on a new proposal to restrict certain carcinogenic, mutagenic or toxic for reproduction (CMR) substances in textiles and clothing under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation. 

The Commission published the consultation on October 22nd, 2015. The deadline for response is January 22, 2016.

The Proposal

Under REACH Article 68 (section 2), the Commission intends to target specific categories of consumer articles with the purpose of restricting CMR substances (Categories 1A and 1B). According to its consultation briefing, the Commission chose textiles and clothing as its first test-case because of the high likelihood of a prolonged, or multiple short-term, exposure of consumers to CMR substances in those articles.

The Commission asked the European Chemicals Agency to compile a list of CMR substances that could potentially be present in textile and clothing articles. Based on that list, the Commission tabled 291 substances split into three categories:

  • Classified dyes and carcinogenic amines
  • Petroleum and coal stream substances
  • Other substances

The restriction would aim to cover articles that consist of at least 80 percent of textile fibres by weight, or that contain a part that consists of at least 80 percent of textile fibres by weight. This includes raw, unfinished, semi-finished and finished goods, whether or not coated or laminated, including articles such as footwear, accessories, clothing, interior textiles, fibres, yarn, fabrics and knitted panels.

Examples include but are not limited to:

  • Underwear
  • Nightwear
  • Swimwear
  • Footwear
  • Hangings and curtains
  • Carpets
  • Pillowcases and bed linens

Articles excluded from the possible restriction are:

  • Footwear, clothing or their parts and accessories made of real leather
  • Footwear, clothing or their parts and accessories made of natural furs or hides
  • Toys

Through this consultation, the Commission is looking for input on the concentration, function and available alternatives to these CMR substances and the socio-economic impact of the implementation of restrictions.

 

What Does this Mean for You?

Not every substance on the list of 291 will be present in your products but even if only 10 percent are, you must be prepared to work with suppliers and eliminate them. If you don’t know what substances are in your products, make sure you establish a process to find that information internally and assess the impact of these possible restrictions on your products. However, because this proposal is still in the consultation phase, there are currently no legal ramifications to be cognisant of.

If you are a manufacturer or any other company involved with the textiles industry (and not exclusively dealing in leather and natural furs or hides) then you are impacted by this proposal. While any citizen or organization is welcome to contribute, it is especially important those most impacted provide input. Contact your industry organization and ensure they are aware of this development. Ask about their plans to submit a completed questionnaire as part of the consultation, before January 22, 2016. If you are not part of an organization, look to complete a questionnaire yourself or with other industry colleagues.

Access the consultation here.

 

Looking Ahead

After two additional restricted substances were added to the SVHC Candidate List in June and seven new substances were proposed for the Listing in August, the constant flux in restricted substance regulations requires organizations to be agile in their compliance program planning. Investing in a platform solution will allow you to respond nimbly when changes are initiated.

 

If you have questions about how this proposed restriction could affect your program, or how to better plan for change, contact one of our regulatory experts at info@assentcompliance.com.

We would love to hear about your challenges and opinions on which substances may make it through the consultation. Please add your thoughts in the comments below to join the discussion.

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