Spielwarenmesse: Stricter limits: regulations to consider with CMR substances in textiles

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Stricter limits: regulations to consider with CMR substances in textiles

from Dr. Magdalena Krause

Changes in connection with the European chemicals regulation REACH have applied to companies in the textile and footwear industry since October 2018.

The (EU) Regulation 2018/1513 was published in a "fast track" procedure and the new restrictions included in Entry 72 of Annex XVII. The new concentration limits apply to CMR substances (carcinogenic, mutagenic, reproductive toxicity) in clothing, textiles that come into contact with the skin and footwear. If the limits are exceeded, these products may no longer be placed on the market after 1 November 2020.

The restrictions set forth in REACH Annex XVII serve to protect consumers from specific substances and restrict their use in specific, particularly relevant areas. Typical restrictions include, for example, nickel in costume jewellery, formaldehyde in cleaning agents, PAH in plastic parts or azo dyes in textiles.

In October 2015, the EU Commission announced its plans to restrict CMR substances in textiles. The procedure for enacting the restriction was developed using the "fast-track" procedure outlined in REACH Art. 68(2). In this abridged procedure, certain elements of the normal procedure such as the preparation of an Annex XV dossier and opinions by RAC and SEAC can be avoided. In this case it was justified by the fact that the harmfulness of the substances concerned had already been sufficiently proven, since only substances classified as CMR 1A or 1B were eligible for inclusion in the restriction.

The number of substances considered for inclusion in the restriction was initially relatively high at 286. In the following consultation rounds and public hearings, the list of substances was reduced to 33 CMR substances. Entry No 12 of Annex XVII contains 33 substances of the following groups:

  • Heavy metals
  • PAH
  • Chlorinated toluene compounds
  • Phthalates
  • Dyes
  • Other substances

Appendix 72 lists specific limit values for each substance. As far as concentration limits are concerned, where different limits are set in other entries in Annex XVII of REACH or in other EU legislation, the stricter concentration limit always applies. This applies, for example, to the concentration limits for polycyclic aromatic hydrocarbons (PAHs) in Entry 50 and in the Toy Directive 2009/48/EC.

A list of available analytical methods for specific matrices that can be used to determine the different substances is provided in the ECHA Guidance Document. The document recommends using the most effective method in each case.

Restrictions apply to these articles

Clothing or related accessories such as:

  • tops, shirts, blouses, trousers, dresses, skirts, suits
  • jackets, coats, raincoats, capes,
  • underwear, nightwear
  • hosiery (e.g. socks, tights, stockings, leggings)
  • sportswear, swimwear (e.g. swimsuits, bikinis, swimming trunks)
  • gloves (including latex gloves not covered by Regulation (EU) 2016/425 or Regulation (EU) 2017/745), mittens, muffs
  • shawls, scarves, stoles, ties, cravats
  • hats, caps, beanies, veils
  • bags such as handbags, backpacks, briefcases
  • watch straps
  • masks and fancy dress costumes

Textiles other than clothing which, under normal or reasonably foreseeable conditions of use, come into contact with human skin to an extent similar to clothing:

  • bed linen (e.g. sheets, duvet covers and pillowcases)
  • blankets, bedspreads, upholstery, seat cushion covers, sleeping bags
  • bathrobes, towels
  • reusable nappies and sanitary pads
  • yarns and fabrics intended for the end consumer


Printing and coatings applied directly to textile items are subject to the restriction.

The restriction does not apply to the following products

  • accessories that are not clothing accessories, such as jewellery, glasses and sunglasses
  • curtains, napkins and table linen
  • carpets and textile floor coverings for indoor use, rugs and runners
  • textile lampshades and wall decorations
  • fillings for chairs, armchairs and sofas
  • clothing, related accessories or footwear, or parts of clothing, related accessories or footwear, made exclusively of natural leather, fur or hide;
  • non-textile fasteners and non-textile decorative attachments (except printings) such as buttons, zip fasteners, Velcro fasteners, rivets, press studs, fasteners or buckles, eyelets, snap fasteners, toggles, hooks, sequins, pearls, stones or metal mesh. Printing and coating are not regarded as decorative elements within the meaning of this exception.
  • second-hand articles
  • disposable nappies and sanitary pads
  • articles covered by Regulation (EU) 2016/425 of the European Parliament and of the Council on personal protective equipment
  • Articles covered by Regulation (EU) 2017/745 of the European Parliament and of the Council on medical products

Author of this article:

Dr. Magdalena Krause, DEKRA

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