REACH : Registration, Evaluation, Authorization and restriction of Chemicals

Below is 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 this initiative. It is the responsibility of the maker or user to register the chemicals that meet the 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 - have they 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.

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.

In addition, 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.