Substances of Concern in Textiles: REACH, SCIP, and DPP Requirements

The textile industry uses over 8,000 synthetic chemicals in manufacturing, and 72 of those chemicals are classified as toxic in dyeing processes alone. Starting October 10, 2026, the EU will ban PFHxA-related PFAS in clothing and footwear under REACH Annex XVII, while the upcoming ESPR delegated act for textiles will require every digital product passport to disclose all substances of concern present in a product. Companies that cannot trace hazardous chemicals across their supply chain will face both regulatory penalties and market access barriers.

This guide explains what substances of concern are, which regulations apply, what data companies must collect, and how to prepare before the 2027–2028 compliance deadlines.

What Are Substances of Concern in Textiles?

Substances of concern are chemicals present in textile products that pose risks to human health or the environment due to their toxic, persistent, bioaccumulative, or endocrine-disrupting properties. Under ESPR Article 7(5), the definition covers three categories: substances of very high concern (SVHC) listed on the REACH Candidate List, chemicals classified under the CLP Regulation as carcinogenic, mutagenic, or toxic to reproduction (CMR), and substances that negatively affect product reuse or recycling.

For textiles specifically, the most common substances of concern fall into five groups:

Azo dyes. Certain azo dyes break down into carcinogenic aromatic amines during use or disposal. REACH Annex XVII restricts any azo dye that releases 30 mg or more of listed aromatic amines per kilogram of textile. Over 3,600 textile dyes exist on the market, and approximately 5% of them can release banned aromatic amines.

PFAS (per- and polyfluoroalkyl substances). Known as "forever chemicals" because they do not break down in the environment, PFAS are used in water-repellent and stain-resistant textile finishes. The REACH restriction on PFHxA-related substances takes effect for clothing and footwear on October 10, 2026.

Formaldehyde. Used as a finishing agent for wrinkle-resistance and color fastness, formaldehyde in textiles is restricted to a maximum of 75 mg/kg under REACH. Chronic exposure causes respiratory irritation and is classified as carcinogenic.

Heavy metals. Chromium VI, lead, cadmium, and nickel appear in dyes, pigments, and metal accessories. These metals are restricted under multiple REACH entries and pose risks through skin contact and environmental contamination.

Flame retardants. Brominated and organophosphorus flame retardants used in protective and children's textiles include several SVHCs. DBDPE (1,1'-(ethane-1,2-diyl)bis[pentabromobenzene]) was added to the SVHC Candidate List specifically for being very persistent and very bioaccumulative.

Key finding: The REACH SVHC Candidate List contains 253 entries as of February 2026, with new substances added regularly. Each entry may cover a group of related chemicals, so the actual number of restricted substances is significantly higher.

Why Do Substances of Concern Matter for Textile Companies?

Substances of concern create three distinct risk categories for textile companies: regulatory non-compliance, health liability, and market exclusion. Understanding each risk is essential for prioritizing chemical management investments.

Regulatory risk

The regulatory landscape is tightening from multiple directions simultaneously. REACH Annex XVII already restricts 33 CMR substances in clothing and footwear since November 2020 (Entry 72). The PFAS restriction on PFHxA compounds takes effect in October 2026. The broader ECHA restriction proposal covering over 10,000 PFAS substances is under review, with a European Commission decision expected in 2027.

Meanwhile, the ESPR delegated act for textiles, expected to be adopted in 2027, will require substances of concern data in every digital product passport. Companies that cannot identify and report these substances will be unable to place products on the EU market once the DPP mandate takes effect.

Health liability

Academic research published between 2019 and 2025 documents elevated health risks from textile chemicals for both workers and consumers. Phthalates in infant clothing, PFAS in water-repellent fabrics, and carcinogenic aromatic amines from azo dyes pose measurable risks. Workers in textile manufacturing face higher rates of dermatitis (prevalence above 1%), respiratory diseases including "brown lung" from cotton dust, and reproductive health effects from chronic exposure to azo dyes.

For consumers, dermal exposure to chemicals through skin-contact textiles presents potential systemic and cancer risks under specific exposure conditions. The EU's precautionary approach means these findings translate directly into stricter regulation.

Market exclusion

Beyond legal penalties, brands and retailers increasingly require chemical compliance as a sourcing condition. Major EU retailers now mandate ZDHC MRSL (Manufacturing Restricted Substances List) conformance from their suppliers. The ZDHC MRSL v3.1 extends restrictions beyond finished-product safety to include chemicals used in manufacturing processes, protecting workers and the environment in addition to consumers.

Companies without robust chemical management systems risk losing access to the largest retail channels in Europe, regardless of formal regulatory enforcement.

Key finding: Entry 72 of REACH Annex XVII restricts 33 CMR substances in textiles and footwear. Any product containing these substances above threshold levels has been non-compliant since November 2020.

Which EU Regulations Cover Substances of Concern in Textiles?

Five overlapping regulatory frameworks govern hazardous chemicals in textiles sold in the EU. Each addresses a different aspect of the chemical lifecycle, from manufacturing inputs to end-of-life waste.

REACH and the SVHC Candidate List

The REACH Regulation is the primary chemical safety framework in the EU. For textiles, two REACH mechanisms are most relevant:

The Candidate List currently contains 253 SVHC entries. Any article (including textile products) containing a Candidate List substance above 0.1% weight by weight must be communicated down the supply chain. Importers of articles containing SVHCs above 1 tonne per year must notify ECHA.

Annex XVII restrictions set specific concentration limits for chemicals in consumer products. For textiles, this includes Entry 43 (azo dyes releasing carcinogenic aromatic amines), Entry 72 (33 CMR substances in clothing and footwear), and upcoming Entry 68 (PFHxA restriction from October 2026).

The SCIP Database

The SCIP database, maintained by ECHA under the Waste Framework Directive, requires companies to notify articles containing Candidate List SVHCs above 0.1% w/w. Since January 5, 2021, every manufacturer, importer, and distributor placing such articles on the EU market must submit a SCIP notification.

For textile companies, this means any product containing an SVHC above threshold must be notified with:

• Article identification (name, identifiers)
• SVHC identity and concentration range
• Safe use instructions
• Information on disassembly (if applicable)

The SCIP database is publicly accessible, meaning competitors, customers, and civil society can review a company's notifications. This transparency mechanism creates both compliance pressure and reputational risk.

ESPR and the Digital Product Passport

The ESPR regulation introduces the most comprehensive chemical disclosure requirement through the digital product passport. Under Article 7(5), delegated acts may require DPPs to include:

• The name, concentration range, and location of substances of concern in the product
• Maximum concentration thresholds
• Substance tracking requirements across the entire value chain
• Information enabling safe handling and end-of-life treatment

The European Commission published its first ESPR Working Plan on April 16, 2025, designating textiles as one of the first product groups. The delegated act for textiles is expected to be adopted in 2027, with compliance obligations phasing in around 2028.

Unlike REACH, which focuses on individual substance restrictions, the ESPR requires comprehensive disclosure of all substances of concern in a structured, machine-readable format within the DPP. This represents a fundamental shift from "restrict and ban" to "identify and disclose."

---

Want to know which substances of concern apply to your products? Get a free screening of your bestseller →

---

How Will the Digital Product Passport Handle Substances of Concern?

The digital product passport will serve as the central disclosure mechanism for substances of concern under ESPR. While the exact data fields will be defined in the textile delegated act (expected 2027), the ESPR regulation establishes clear principles for what DPPs must contain.

Required data points

Based on ESPR Article 7(5) and existing delegated acts for other product groups (notably batteries), textile DPPs are expected to include:

• Substance identification: Chemical name, CAS number, and EC number for each substance of concern present above the defined threshold
• Concentration range: The amount of each substance, likely expressed as a weight percentage range (e.g., 0.1–0.5% w/w)
• Location in product: Where in the product the substance is present (e.g., outer fabric, coating, accessories, dye)
• Function: Why the substance is used (e.g., water repellency, flame retardancy, color fixation)
• Safe use information: Handling instructions to minimize exposure during use
• End-of-life guidance: Information enabling safe recycling or disposal, particularly for substances that affect recyclability

Access levels

ESPR defines different access levels for DPP data. Substance of concern information will likely follow a tiered model:

• Public access: Presence and identity of substances above threshold (consumers and waste operators need this)
• Authorized access: Exact concentrations and supply chain origin (market surveillance authorities and authorized recyclers)
• Restricted access: Proprietary formulation details (only competent authorities under confidentiality)

This tiered approach balances transparency with trade secret protection, a key concern for chemical suppliers and formulators in the textile value chain.

Technical implementation

DPP data on substances of concern must be machine-readable and linked to the product via a unique identifier, most likely a GS1 Digital Link encoded in a QR code. The data must be interoperable with the EU DPP Registry and the ESPR Web Portal, allowing automated verification by market surveillance authorities.

For a live example of how DPP data is structured and accessed, visit our DPP showcase.

Key finding: Unlike REACH's substance-by-substance restrictions, the ESPR requires systematic disclosure of all substances of concern in a product. This means companies need complete chemical inventories, not just compliance checks against individual restriction lists.

What Is the PFAS Ban and How Does It Affect Textiles?

PFAS (per- and polyfluoroalkyl substances) are a family of over 10,000 synthetic chemicals used extensively in textiles for water repellency, stain resistance, and oil resistance. They are called "forever chemicals" because they do not break down in the environment and accumulate in human blood and tissue.

The EU is implementing PFAS restrictions through two parallel regulatory tracks:

PFHxA restriction (October 2026)

The REACH restriction on perfluorohexanoic acid (PFHxA) and related substances takes effect on October 10, 2026, for clothing, accessories, and footwear. This restriction targets a specific subgroup of PFAS widely used in textile treatments after earlier restrictions on PFOA and PFOS made those substances unavailable.

Key parameters:

• Effective date: October 10, 2026
• Scope: Clothing, accessories, footwear, food-contact paper, consumer mixtures
• Threshold: Substances must not be present above the defined concentration limit
• Transition: Products manufactured before the restriction date may remain on the market for a 12-month sell-through period

Broader PFAS restriction proposal

In parallel, ECHA is reviewing a comprehensive restriction proposal covering all PFAS substances. Five EU Member States (Germany, Denmark, Netherlands, Norway, and Sweden) submitted the proposal. ECHA's scientific assessment is expected to conclude by late 2026, with a European Commission decision likely in 2027.

If adopted, this broader restriction would affect virtually all water-repellent textile finishes currently on the market. Textile companies should begin transitioning to PFAS-free alternatives now, rather than waiting for the final decision.

Alternatives to PFAS in textiles

Several PFAS-free alternatives are commercially available for textile water repellency:

The ZDHC (Zero Discharge of Hazardous Chemicals) foundation updated its MRSL to include PFAS treatments, signaling that the industry standard is moving decisively toward elimination.

Key finding: The PFHxA ban takes effect for clothing on October 10, 2026, with a 12-month sell-through period for existing stock. Companies still using PFHxA-based finishes have less than 5 months to reformulate or switch suppliers.

How Should Companies Map Substances of Concern Across Their Supply Chain?

Mapping substances of concern requires tracing chemical inputs from raw material processing through finished product. For most textile companies, the challenge is that chemical decisions happen at Tier 2–4 of the supply chain (dyehouses, finishing mills, fiber producers), while compliance obligations fall on the brand or importer at Tier 0–1.

Our detailed guide on collecting supplier data for DPP covers the full methodology. Here, we focus specifically on chemical data collection.

Chemical data by supply chain tier

Five methods for collecting chemical data

1. ZDHC MRSL conformance. Request that all Tier 2 suppliers demonstrate ZDHC MRSL conformance at Level 1 minimum (document review plus formulation testing). Level 2 (on-site management system assessment) provides higher assurance.

2. Product testing. Commission third-party laboratory testing for restricted substances against REACH Annex XVII limits. Focus on high-risk categories: azo dyes in colored textiles, formaldehyde in finished fabrics, PFAS in water-repellent products, heavy metals in accessories.

3. OEKO-TEX or bluesign certification. These industry certifications verify compliance with restricted substance limits. OEKO-TEX STANDARD 100 tests finished products; bluesign certifies the entire production process. Both provide third-party assurance recognized by EU authorities.

4. Material Safety Data Sheets (SDS). Collect SDS for every chemical product used in Tier 2 manufacturing. Cross-reference active ingredients against the SVHC Candidate List, REACH Annex XVII, and the ZDHC MRSL.

5. Digital supply chain platforms. Use platforms that aggregate chemical data from suppliers into a centralized system. This approach scales across large supplier bases and enables automated compliance checking against evolving regulation.

Common obstacles and solutions

Supplier resistance. Chemical formulations are often considered trade secrets. Use standardized disclosure formats (ZDHC Chemical Module) that report substance presence without revealing exact formulations. Contractual confidentiality agreements can address remaining concerns.

Data gaps at Tier 3–4. Many brands lack visibility beyond Tier 2. Start with certifications (organic, BCI, OEKO-TEX) as proxy evidence, then progressively require direct chemical data as supplier relationships mature.

Evolving substance lists. The SVHC Candidate List grows by 2–10 substances per year. Implement automated monitoring of ECHA updates and re-screen your chemical inventory after each addition.

What Is the SCIP Database and Who Must Report?

The SCIP database (Substances of Concern In articles as such or in complex objects/Products) is a publicly accessible database maintained by ECHA. It ensures that information about hazardous substances in products remains available throughout the product lifecycle, including at the waste stage.

Who must notify

Three categories of companies must submit SCIP notifications:

1. EU manufacturers producing articles containing Candidate List SVHCs above 0.1% w/w
2. EU importers importing such articles into the EU
3. EU distributors and retailers supplying such articles (downstream notification obligation)

The obligation has been in force since January 5, 2021. Non-compliance is enforced at national level by Member State authorities.

What to notify

Each SCIP notification must include:

• Article identification: Name, primary article identifier, article category, production country
• SVHC information: Substance name, EC/CAS number, concentration range
• Safe use instructions: Information enabling safe use and end-of-life handling
• Complex object structure: For products made of multiple articles (e.g., a jacket with buttons, zippers, fabric), each component containing an SVHC must be identified separately

SCIP and the DPP connection

The SCIP database and the ESPR digital product passport will coexist, but serve different purposes. SCIP focuses on waste-stage information and covers only Candidate List SVHCs. The DPP will cover all substances of concern (broader than SVHCs) and will be linked to the product throughout its lifecycle.

Companies already submitting SCIP notifications have a head start on DPP compliance. The substance identification, concentration data, and safe use information collected for SCIP directly maps to DPP data requirements. Building on existing SCIP processes rather than starting from scratch will significantly reduce the effort needed for DPP implementation.

Key finding: Companies already reporting to the SCIP database have collected much of the substance data that the DPP will require. The transition from SCIP to DPP is an extension, not a restart.

How Do Industry Standards Like ZDHC MRSL and OEKO-TEX Relate to Regulatory Requirements?

Industry chemical management standards are voluntary, but they overlap significantly with regulatory requirements and increasingly serve as proof of compliance.

ZDHC MRSL

The ZDHC Manufacturing Restricted Substances List goes beyond product-level safety to restrict chemicals used in the manufacturing process. ZDHC MRSL v3.1 covers approximately 28 chemical groups with specific concentration limits.

Key differences from regulatory RSLs:

• Scope: Manufacturing inputs (chemicals used in dyeing, finishing, printing), not just finished-product residues
• Goal: Protect workers and the environment during manufacturing, in addition to consumer safety
• Conformance levels: Level 1 (testing), Level 2 (management system), Level 3 (hazard assessment capability)
• PFAS coverage: v3.1 explicitly includes PFAS treatments for textiles, leather, and footwear

OEKO-TEX STANDARD 100

OEKO-TEX tests finished textile products against limits for over 100 substance groups, including many that overlap with REACH restrictions. Certification provides product-level assurance but does not cover manufacturing-process chemicals.

bluesign

bluesign certifies the entire textile production process, from chemical inputs through finished product. It is the most comprehensive industry standard, covering environmental impact, worker safety, and consumer protection.

Mapping standards to regulations

For companies building a chemical management program, the most efficient approach is to implement ZDHC MRSL conformance at Tier 2 suppliers and require OEKO-TEX or bluesign certification as baseline evidence. This covers the majority of current regulatory requirements and positions the company well for upcoming DPP obligations.

What Are the Penalties for Non-Compliance with Chemical Regulations?

Penalties for chemical non-compliance come from multiple regulatory sources and can combine for severe consequences.

REACH violations. Penalties are set by each Member State. Fines typically range from EUR 10,000 to EUR 2 million depending on the severity and the Member State. France, Germany, and the Netherlands enforce most aggressively. Placing a restricted substance above threshold on the EU market can result in product recalls, import bans, and administrative fines.

SCIP non-compliance. Failure to submit required SCIP notifications is enforced at national level. While enforcement has been inconsistent during the initial years, authorities are increasing scrutiny as the database matures.

ESPR penalties. Article 72 of the ESPR requires Member States to establish penalties that are effective, proportionate, and dissuasive. These will apply to DPP non-compliance including missing or inaccurate substance of concern data. Penalties must include financial fines and temporary exclusion from public procurement.

Market consequences. Beyond regulatory fines, chemical non-compliance triggers commercial penalties: retailer delisting, lost sourcing contracts, consumer lawsuits, and reputational damage. Major retailers routinely test incoming shipments for restricted substances and reject non-compliant batches.

How to Build a Substances of Concern Compliance Roadmap

With multiple overlapping regulations and evolving substance lists, textile companies need a structured approach to chemical compliance. The following roadmap covers immediate actions through full DPP readiness.

Phase 1: Baseline assessment (Month 1–3)

Inventory your chemical exposure. Identify every product category you sell in the EU and map which substances of concern are most likely present based on the product type (e.g., water-repellent outerwear = PFAS risk, colored knits = azo dye risk, children's wear = formaldehyde and phthalate risk).

Audit current compliance. Verify that existing products meet REACH Annex XVII limits through third-party test reports. Check whether SCIP notifications are up to date for products containing SVHCs above 0.1%.

Assess PFAS exposure. With the PFHxA ban taking effect October 10, 2026, identify every product using PFHxA-based finishes and initiate reformulation or supplier switch immediately.

Phase 2: Supply chain engagement (Month 3–9)

Implement ZDHC MRSL requirements for all Tier 2 chemical suppliers. Require Level 1 conformance as minimum, with a roadmap to Level 2 within 18 months.

Collect chemical inventories from dyehouses and finishing mills. Use standardized formats (ZDHC Chemical Module, BHive) to aggregate data efficiently.

Establish testing protocols. Define which products require routine testing for restricted substances, based on risk assessment. High-risk categories (children's wear, skin-contact garments, water-repellent items) should be tested every season.

Phase 3: DPP preparation (Month 9–18)

Structure your substance data for DPP. The data you've collected in Phases 1–2 needs to be organized in a format compatible with the DPP data model. This means standardized chemical identifiers (CAS/EC numbers), concentration ranges, and product-component mapping.

Implement a DPP platform that can ingest chemical data from suppliers, link it to product models, and generate the required disclosures. The platform should integrate with existing chemical management tools and support automated compliance checking as substance lists evolve.

Prepare for the delegated act. Monitor the European Commission's progress on the textile delegated act. When published, review the specific substance of concern data requirements and adjust your data collection accordingly.

For a comprehensive guide to environmental footprint calculation and its intersection with chemical data, see our environmental impact methodology page.

Phase 4: Continuous compliance (Ongoing)

Monitor substance list updates. The SVHC Candidate List is updated at least twice per year. Subscribe to ECHA notifications and re-screen your chemical inventory after each update.

Re-test periodically. Supply chain changes, new suppliers, and formulation adjustments can introduce new chemical risks. Establish a re-testing cadence aligned with your sourcing cycles.

Integrate with circular economy processes. Substance of concern data is essential for safe recycling and reuse. Products containing certain chemicals may require special handling at end-of-life. Your DPP should communicate this information to waste operators and recyclers.

FAQ

What is the difference between substances of concern and SVHCs?

Substances of Very High Concern (SVHCs) are a specific subset of substances of concern, identified on the REACH Candidate List based on their carcinogenic, mutagenic, reprotoxic, persistent, bioaccumulative, or endocrine-disrupting properties. Substances of concern under ESPR is a broader category that includes SVHCs plus other chemicals classified under CLP and substances that negatively affect recycling. The SVHC Candidate List contained 253 entries as of February 2026.

Are PFAS banned in textiles in the EU?

Partially. The PFHxA restriction takes effect for clothing and footwear on October 10, 2026. A broader restriction covering all PFAS substances is under review by ECHA, with a European Commission decision expected in 2027. Products manufactured before the restriction date have a 12-month sell-through period.

What is the SCIP database and do textile companies need to report?

The SCIP database is maintained by ECHA under the Waste Framework Directive. Any company placing articles containing Candidate List SVHCs above 0.1% w/w on the EU market must submit a SCIP notification. This obligation has been in force since January 5, 2021, and applies to manufacturers, importers, and distributors.

How will the digital product passport disclose substances of concern?

The DPP will include machine-readable data on substance identity (name, CAS number), concentration range, location in the product, function, safe use instructions, and end-of-life guidance. Access levels will be tiered: public for basic substance presence, authorized for exact concentrations, and restricted for proprietary formulation details. The specific requirements will be defined in the textile delegated act expected in 2027.

What is the ZDHC MRSL and is it legally required?

The ZDHC Manufacturing Restricted Substances List is a voluntary industry standard that restricts chemicals used in textile manufacturing processes. It is not legally required, but major retailers and brands mandate ZDHC MRSL conformance from their suppliers. Version 3.1 includes PFAS restrictions and covers approximately 28 chemical groups. Conformance is assessed at three levels: testing (Level 1), management system (Level 2), and hazard assessment capability (Level 3).

How many chemicals are used in textile manufacturing?

Over 8,000 synthetic chemicals are used across the textile manufacturing process. This includes more than 3,600 textile dyes, with 72 chemicals classified as toxic in dyeing alone. The actual number of individual chemical substances is higher because many commercial products are mixtures of multiple chemicals.

What happens if a product contains an SVHC above 0.1%?

The company must communicate safe use information down the supply chain (REACH Article 33), submit a SCIP notification to ECHA, and notify ECHA if the substance is imported in articles exceeding 1 tonne per year. Under the upcoming ESPR, this information will also need to be included in the digital product passport.

Can certifications like OEKO-TEX replace regulatory compliance testing?

Certifications provide strong evidence of compliance but do not replace the legal obligation to ensure products meet regulatory limits. OEKO-TEX STANDARD 100 tests against limits that often exceed REACH requirements, making it a reliable indicator. However, companies remain legally responsible for compliance and should maintain their own testing protocols, particularly for high-risk product categories.

Next Steps

The October 2026 PFAS deadline and the upcoming ESPR delegated act for textiles make chemical compliance an immediate priority. Here is what to do now:

1. Screen your product portfolio for substances of concern exposure. Use our environmental impact calculator to identify which product categories carry the highest chemical risk.
2. Read our supplier data collection guide for a step-by-step methodology for gathering chemical data from your supply chain.
3. Get a free compliance screening to assess your readiness for PFAS restrictions and DPP substance disclosure. Contact our team →