Customers ask about chemicals in our clothing
Clothing and other textiles must meet the REACH Annex XVII restrictions: azo dyes releasing listed amines, nonylphenol ethoxylates in washable textiles, the CMR substances in Appendix 12 and, from 10 October 2026, PFHxA and related substances in consumer clothing and footwear. The fibre labelling rules do not cover chemicals. Hold supplier declarations and test results per material, and answer SVHC questions separately.
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Reviewed 5 October 2026 by the Conphora compliance team · Not legal advice
Why this happens
Chemical limits for clothing and other textiles do not come from the textile labelling rules. Regulation (EU) No 1007/2011 deals with fibre names, the labelling of fibre composition, non-textile parts of animal origin and fibre analysis (Article 1). The limits come from REACH, Regulation (EC) No 1907/2006. Under Article 67(1), a substance in an article for which Annex XVII contains a restriction shall not be placed on the market unless it complies with that restriction.[2][1]
Several Annex XVII entries are written for textiles. Entry 43 forbids the use of azo dyes that can release the aromatic amines in Appendix 8 above 30 mg/kg in textile and leather articles that may come into direct and prolonged contact with the skin or mouth, such as clothing, bedding, towels, hats, footwear, gloves and handbags, and such articles may not be placed on the market unless they conform (points 1 and 2). Entry 46a forbids nonylphenol ethoxylates at 0.01 % by weight or more in textile articles that can be expected to be washed in water, since 3 February 2021. Entry 61 forbids dimethylfumarate above 0.1 mg/kg in any article.[1]
Entry 72, applying since 1 November 2020, sets limits for the CMR substances in Appendix 12 in clothing and related accessories, in other textiles with skin contact similar to clothing, and in footwear, when they are for consumers. The limits are measured in homogeneous material: for example 1 mg/kg after extraction for cadmium, chromium VI, arsenic and lead compounds, 5 mg/kg for benzene, 1 mg/kg for several polycyclic aromatic hydrocarbons and 75 mg/kg for formaldehyde. The entry exempts natural leather, fur and hide, non-textile fasteners and decorations, second-hand items, wall-to-wall carpets and rugs, and products under the PPE and medical devices regulations; disposable textiles are exempt from the limb for textiles other than clothing (points 3 to 5).[1]
The newest entry for textiles concerns a group of PFAS. Entry 79 restricts PFHxA, its salts and PFHxA-related substances. From 10 October 2026 they may not be present at 25 ppb or more for PFHxA and its salts, or 1 000 ppb or more for related substances, measured in homogeneous material, in textiles, leather, furs and hides in clothing and related accessories for the general public, or in footwear for the general public. Other consumer textiles follow from 10 October 2027. Articles placed on the market before each date are exempt. Personal protective equipment against certain category III risks, medical and in vitro diagnostic medical devices and construction textiles are excluded (point 3). Entry 68 has restricted C9-C14 PFCAs in articles since 25 February 2023, at 25 ppb for the acids and their salts and 260 ppb for related substances. Entry 82 adds a wider PFAS definition, but in the consolidated text of 22 June 2026 it applies only to firefighting foams.[1]
Customers often mix these limits with substances of very high concern. Article 33 is a separate duty: a supplier of an article containing a Candidate List substance above 0.1 % weight by weight gives recipients the substance name and safe-use information, and consumers on request. When you communicate, note that from 27 September 2026 presenting legal requirements that apply to all products in the category as a distinctive feature of your offer is listed as an unfair commercial practice (Directive 2005/29/EC Annex I point 10a).[1][3]
The chemical limits do not replace the general safety duties. Clothing has no product-specific harmonisation act. The REACH restrictions apply alongside the General Product Safety Regulation, Regulation (EU) 2023/988, so manufacturers and importers follow both: the restriction, and the GPSR's risk analysis, technical documentation, identification and address duties (Articles 9 and 11).[4]
How to solve it
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Sort your products by the entries that apply
Clothing, accessories and textiles in skin contact fall under the Appendix 12 entry. Textiles and leather in prolonged skin contact fall under the azo dye entry. Washable textiles fall under the NPE entry. Consumer clothing and footwear fall under the PFHxA entry from 10 October 2026, other consumer textiles from 10 October 2027.
Regulation guidesKnow-how Free Open -
Check the PFHxA dates against your stock
The PFHxA limits are 25 ppb for PFHxA and its salts and 1 000 ppb for PFHxA-related substances. Articles placed on the market before 10 October 2026 are exempt from the first date. Ask suppliers of water-repellent and stain-resistant finishes which chemistry they use, and plan orders around the date.
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Get declarations and tests per homogeneous material
Several limits are measured in homogeneous material or per part of the article. Ask suppliers for a declaration against each relevant entry and test the risky materials, such as dyed fabrics, coated or finished fabrics, prints and leather parts, with the methods the entries name.
Knowledge & insightsKnow-how Free Open -
Answer the customer with the right instrument
A restriction answer says which Annex XVII entries you comply with. A substance of very high concern question is a separate duty under REACH Article 33, with the 0.1 % threshold per article. Keep the two apart in your reply.
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Do not advertise a legal ban as a feature
From 27 September 2026, presenting requirements imposed by law on all products in the category as a distinctive feature of your offer is an unfair commercial practice. A claim such as 'free from' a substance that is already banned for all clothing needs care.
Work through the steps in the platform with your own product.
What you need to show
| Document | Where it comes from | Legal ground |
|---|---|---|
| Supplier declarations against the relevant Annex XVII entries, per material | Fabric, trim and finishing suppliers | Regulation (EC) No 1907/2006 Article 67(1); Annex XVII entries 43, 46a, 68, 72 and 79 |
| Test reports for the materials with the highest risk | A laboratory, using the methods named in the entries | Regulation (EC) No 1907/2006 Annex XVII entry 43 and Appendix 10 |
| A written SVHC statement where asked | The supplier of the article | Regulation (EC) No 1907/2006 Article 33 |
If you do nothing
The article may not be placed on the market
A substance in an article for which Annex XVII contains a restriction may not be placed on the market unless it complies with the conditions of that restriction (Regulation (EC) No 1907/2006 Article 67(1)).[1]
PFHxA in consumer clothing from 10 October 2026
From 10 October 2026, PFHxA and its salts at 25 ppb or more, or PFHxA-related substances at 1 000 ppb or more, may not be in textiles, leather, furs and hides in clothing and related accessories or in footwear for the general public (REACH Annex XVII entry 79, point 1).[1]
Duties to customers asking about SVHCs
A supplier of an article containing a Candidate List substance above 0.1 % w/w must give recipients the substance name and safe-use information, and consumers on request (Regulation (EC) No 1907/2006 Article 33(1) and (2)).[1]
Questions about this problem
Does the textile labelling regulation say anything about chemicals?
No. Regulation (EU) No 1007/2011 lays down rules on fibre names, the labelling of fibre composition, non-textile parts of animal origin and fibre analysis (Article 1). Chemical limits for textiles come from REACH Annex XVII.
Is all PFAS banned in clothing?
Not as one group. Entry 79 restricts PFHxA, its salts and related substances in consumer clothing and footwear from 10 October 2026. Entry 68 has restricted C9-C14 PFCAs, their salts and related substances in articles since 25 February 2023. PFOA, PFOS and PFHxS fall under the POPs Regulation. Entry 82 covers PFAS in firefighting foams only.
Which substances does Appendix 12 cover?
It lists CMR substances with limits in homogeneous material, for example cadmium, chromium VI, arsenic and lead compounds at 1 mg/kg after extraction, benzene at 5 mg/kg, several polycyclic aromatic hydrocarbons at 1 mg/kg and formaldehyde at 75 mg/kg (REACH Annex XVII Appendix 12).
Are second-hand clothes covered?
Entry 72 does not apply to second-hand clothing, accessories, textiles or footwear (point 3(c)), and entry 46a does not apply to second-hand textiles or to new textiles made without NPE exclusively from recycled textiles (point 2). Check each entry, because the exemptions differ.
What is the nonylphenol ethoxylate limit?
Since 3 February 2021, textile articles that can be expected to be washed in water may not contain NPE at 0.01 % by weight or more of the article or of each part (REACH Annex XVII entry 46a, point 1).
Sources
- Regulation (EC) No 1907/2006 (REACH) (consolidated text of 22 June 2026) EUR-Lex · accessed 4 October 2026
- Regulation (EU) No 1007/2011 on textile fibre names and labelling (consolidated text of 15 February 2018) EUR-Lex · accessed 4 October 2026
- Directive 2005/29/EC on unfair commercial practices (consolidated text of 27 September 2026) EUR-Lex · accessed 4 October 2026
- Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 5 October 2026
About this page
- Reviewer
- Conphora compliance team
- Reviewed
- 5 October 2026
General information, not legal advice. Check the legal text or ask an adviser about your own product.
Conphora (2026). Customers ask about chemicals in our clothing. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/textile-chemicals/
Conphora (2026) Customers ask about chemicals in our clothing. Available at: https://www.conphora.com/solutions/problem/textile-chemicals/ (Accessed 13 October 2026).
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author = {Conphora},
title = {Customers ask about chemicals in our clothing},
year = {2026},
url = {https://www.conphora.com/solutions/problem/textile-chemicals/},
note = {Retrieved 13 October 2026}
} See it working before you add a product
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