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Since the REACH Regulation entered into force in June 2007, this new legislation has introduced the first EU legal obligation for substances contained in finished products, creating new challenges for the textile & footwear industries.

More than a year after the enforcement, exactly how the new regime will be put into practice by the industry has emerged with a clear direction. The market is directed to focus on Substances of Very High Concern (SVHC). This is in addition to chemical registration, which is less relevant for textile industry because most of the substances contained in textiles are not intended to be released.
For items imported into the EU, textile manufacturers have to notify the European Chemical Agency (ECHA) of any SVHC that is present in the article with a concentration over 0.1% (corresponding to 1000 ppm or mg/kg) per article and if the total annual volume in all products is above 1t/year.
The ECHA published the Candidate List containing 15 SVHC on 28th October 2008 and highly encourages companies to check their potential legal obligations related to the substances in this Candidate List, no matter whether it is the substances on their own, in preparations and in articles. Moreover,
obligation under Article 33 “Duty to communicate information on substances in articles” of REACH regulation states that if the article contains a substance on the Candidate List and its concentration is present above 0.1% (w/w), EU and EEA suppliers of this article must provide sufficient information to their customers and on request to a consumer within 45 days of the receipt of the request.  The information needs to include both the name of substance and the safe usage information.

In parallel with REACH, manufacturers still need to comply with the current Directive 76/769/EEC which includes a list of chemicals, but is not limited to, azo colorants, nickel release, cadmium, etc, that are currently restricted by the European Commission.  On 1 June 2009, Directive 76/769/EEC will be repealed by the REACH regulation. The requirements of those restricted substances may become more stringent up until June 2013.
Article 67 of the REACH regulation states “A substance on its own, in a preparation or in an article, for which Annex XVII contains a restriction shall not be manufactured, placed on the market or used unless it complies with the conditions of that restriction.” As such, manufacturers might experience an increase in testing cost burden, double the time for analytical verification, which ultimately could affect the product shipment to their end customers.
With all this information in hand, brands, retailers and manufacturers with products exported to EU are encouraged to proceed with strategic planning to substantiate their own compliance. Apart from considering the current restricted substance list, adoption of the SVHC candidate list and reviewing product composition should be the prioritized options. With the increasing demand of legal safety measures on textile and footwear, SGS, with experts in our technical competency centre, will keep a finger on the pulse of developments that may impact our customers and help them respond quickly to prepare for legal compliance.

The following table shows the possible applications of the 15 SVHCs in the current Candidate List in the textile and footwear industries, and compares their regulatory requirements with those of restricted substances which are of concern in the EU and US markets.
PBT = persistent, bioaccumulative and toxic substances, vPvB = very persistent and very bioaccumulative substances, C = carcinogenic, M = mutagenic, R = toxic for reproduction, Cat. = Category

Contact Name: Ruth Hon
Tel: 852 2774 7488
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