What does the REACH regulation require of a textile buyer?
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is an EU regulation that operates in stages, placing obligations on the party manufacturing or importing a chemical. In the language of the regulation, textile products are treated as "articles"; that is, the fabric itself is not an object of chemical registration, but the substances within the fabric are subject to restrictions. For the buyer, this means ensuring that residual chemicals arising from the dyeing, printing and finishing processes of the fabric they purchase remain below the legal thresholds.
Two mechanisms are decisive in practice. The first is the Annex XVII restrictions: concrete concentration limits are defined for substances such as certain azo dyestuffs, nickel release, nonylphenol ethoxylates (NPE) and certain phthalates. The second is the SVHC candidate list: substances of very high concern are updated periodically, and when an article contains SVHCs exceeding 0.1% by weight, a notification obligation throughout the supply chain and registration in the SCIP database arise. This list is not fixed; the industry norm is to reference "the SVHC list in force on the date of shipment" in contracts.
The critical point for the buyer is this: REACH compliance is not a document, it is a result. A supplier's declaration of being "REACH compliant" is not sufficient evidence on its own; it must be assessed together with the supporting test reports, chemical inventory and dyeing process records.
What does OEKO-TEX STANDARD 100 test, and how does it differ from REACH?
OEKO-TEX STANDARD 100 tests every component of a textile product, from its yarn to its accessories, against a broad list of harmful substances: banned azo dyestuffs, formaldehyde, extractable heavy metals, pesticides, chlorinated phenols, phthalates and more. Testing is carried out across four product classes according to the degree of skin contact; the strictest limits apply to baby products (Class I) and the most lenient to decoration products that do not touch the skin (Class IV).
Establishing the relationship between REACH and OEKO-TEX correctly is important. REACH is the legal precondition for placing a product on the EU market; non-compliance directly results in legal sanctions. Although OEKO-TEX is a voluntary programme, in practice most European brands make it a purchasing requirement, because it offers a single document backed by independent third-party testing. OEKO-TEX updates generally tighten their limits early, anticipating new REACH/SVHC restrictions; therefore a valid OEKO-TEX certificate is a strong but, on its own, insufficient indicator of REACH compliance.
| Dimension | REACH / SVHC | OEKO-TEX STANDARD 100 |
|---|---|---|
| Legal nature | Mandatory EU regulation | Voluntary product certificate |
| What it governs | Restricted substance in article + SVHC notification | Harmful substance limits in the finished product |
| Scope | All articles entering the EU market | Certified product/batch, on a component basis |
| Testing requirement | Not explicit; the compliance result matters | Mandatory testing in an accredited laboratory |
| Limit strictness | Legal threshold (Annex XVII, 0.1% SVHC) | Stricter than REACH for most substances |
| Updating | SVHC list expands periodically | Annual limit revision, anticipates REACH |
How do ZDHC and MRSL connect to this picture?
A fabric passing REACH and OEKO-TEX tests gives indirect information about the chemical management of the process, but does not show the full picture. The MRSL (Manufacturing Restricted Substances List) produced by the ZDHC (Zero Discharge of Hazardous Chemicals) programme reverses the logic: instead of looking at the residue in the finished product, it restricts the chemical formulations entering the production workshop themselves. When a dye, auxiliary chemical or printing paste complies with the MRSL, it means the banned substance has never been involved in the process at all.
This distinction is powerful from an auditing perspective, because RSL (product limit) tests are sampling-based and may not catch every batch; the MRSL, however, eliminates the risk at the input gate. The ZDHC ecosystem also defines parameters for wastewater discharge (heavy metals, AOX, pH) and connects with water management targets such as ZLD. In practice, an advanced commission dye/finishing facility manages its chemical inventory with MRSL-compliant products verified on platforms such as the ZDHC Gateway. For the detail of this topic, you can refer to our ZDHC compliance guide.
To summarise the three layers in a single sentence: MRSL manages the input, ZDHC manages the discharge waste; REACH sets the legal threshold; OEKO-TEX independently verifies the finished product. When a buyer sees these four together, they have proven that chemical risk is addressed at every point of the supply chain.
How do the framework, scope and evidence document match up?
The table below matches the three frameworks along the axes of scope and concrete evidence document. This matching can form the backbone of your supplier selection checklist.
| Framework | Scope (what it assures) | Expected evidence / document |
|---|---|---|
| REACH Annex XVII | Restricted substances in the article below threshold | Restricted substance test report + declaration of conformity |
| REACH SVHC / SCIP | SVHC above 0.1% has been notified | SVHC screening result, SCIP registration if required |
| OEKO-TEX STANDARD 100 | Harmful substance test on the finished product passed | Valid certificate no. + product class + date |
| ZDHC MRSL | Production chemicals compliant at source | MRSL-compliant chemical inventory / Gateway record |
| ZDHC Wastewater | Wastewater discharge within parameters | Accredited wastewater test report |
Document currency and traceability
The existence of the document is not enough; it must be current and traceable. OEKO-TEX certificates have a validity period and their number can be verified online; an expired certificate is not evidence. SVHC screening reports must be assessed together with the SVHC list version they refer to, because as the list expands, an earlier report does not cover newly added substances. For this reason, the buyer must match the evidence documents to the shipment/batch number and request periodic refreshing.
For the broader regulatory context, our sustainability and regulation guide addresses how the frameworks (ESPR/DPP, CBAM, EPR) intersect with one another; the chemical compliance layer in this article is one part of that picture.
What do these three layers mean for the buyer?
From a risk management perspective, the three layers close three different points of failure. Not relying on REACH means the risk of the goods being stopped at EU customs and recalled. Not requesting OEKO-TEX means not having the product's skin-contact safety verified by an independent party. Skipping ZDHC/MRSL means losing the only mechanism that guarantees the harmful chemical never enters production at all. A mature B2B purchasing process stipulates these three separately and does not assume one substitutes for another.
A single-coordinator structure provides an advantage at this point: when in-house knitting and the contracted dyeing, printing and finishing are coordinated under one point of contact, the chemical inventory, process records and test results converge under a single responsibility; when the supply chain is fragmented, the evidence of each link must be gathered separately. Our coordinated contract network advantage and certificate scope show how this evidence chain comes together. Let us clarify together which documents are valid for a specific shipment.
Frequently asked questions
Is a supplier's single "REACH compliant" declaration sufficient proof for the buyer?
No. REACH compliance is an outcome, not a document; a standalone declaration is not accepted as valid evidence in an audit. It must be assessed together with the restricted-substance test reports, chemical inventory and dyeing process records that substantiate the claim. A mature B2B process links the evidence documents to the shipment/batch number and requires periodic refreshing.
What does the 0.1% threshold mean for SVHCs and when is notification required?
When an article contains an SVHC (Substance of Very High Concern) above 0.1% by weight, an obligation arises to notify it along the supply chain and to register it in the SCIP database. The SVHC candidate list is not fixed; it expands periodically. That is why the industry norm is to reference the "SVHC list in force on the shipment date" in contracts; an old screening report does not cover substances added later.
What exactly is the difference between OEKO-TEX STANDARD 100 and REACH?
REACH is a mandatory EU regulation and a legal precondition for placing a product on the market; non-compliance triggers direct legal sanctions. OEKO-TEX STANDARD 100, by contrast, is a voluntary but widespread product certification; it demonstrates that the finished product has been tested for harmful substances in an accredited laboratory. OEKO-TEX limits are stricter than REACH for most substances and are usually tightened early, anticipating new REACH restrictions.
What are the OEKO-TEX product classes and which limit applies to which product?
Testing is carried out in four product classes according to the product's degree of skin contact. The strictest limits apply to baby products (Class I); the most lenient limits apply to decoration products that do not contact the skin (Class IV). Testing covers all components, from yarn to accessories; banned azo dyes, formaldehyde, extractable heavy metals, pesticides, chlorinated phenols and phthalates are all checked.
Why is ZDHC/MRSL needed in addition to REACH and OEKO-TEX testing?
REACH and OEKO-TEX inspect residues in the finished product; these tests are sampling-based and may not catch every batch. The MRSL produced by ZDHC reverses the logic: it restricts the chemical formulations entering production at their source, so harmful substances are blocked before they ever enter the product. Skipping the MRSL means losing the only mechanism that guarantees a chemical never enters production in the first place.
As a buyer, which documents should I request for a shipment?
Each framework is evidenced by a different document: for REACH Annex XVII, the restricted-substance test report and declaration of conformity; for SVHC/SCIP, the screening result and, where required, the SCIP registration; for OEKO-TEX, the valid certificate number, product class and date; for ZDHC MRSL, the compliant chemical inventory/Gateway record; for wastewater, an accredited test report. The documents must be current and traceable to the batch/shipment.