REACH

Definition

REACH is the regulation (EC) No 1907/2006 that aims to improve the protection of human health and the environment through the better and earlier identification of the intrinsic properties of chemical substances. REACH also aims to enhance innovation and competitiveness of the EU chemical industry. 

There is no a specific regulatory framework for garments and fashion in Europe, but there is a control on substances by the regulations on chemicals: 

  • REACH: Registration, Evaluation, Authorisation and Restriction of Chemicals. Regulation (EC) No 1907/2006 
  • POP: Persistent Organic Pollutants. Regulation (EC) No 850/2004. 

The REACH Regulations places responsibility on industry to manage the risks form chemicals, to provide safety information on the substances, and to register in ECHA (European Chemicals Agency). It follows the principle “no data no market”. 

Two years later, in 2008, the European Union issued the CLP Regulation for "Classification, Labelling and Packaging". It aimed to align the European system of classification, labelling and packaging of chemical substances and mixtures to the Globally Harmonised System (GHS). CLP don’t apply to food, as well to as other sector with specific regulations (Medical, cosmetics, etc.). 

In 2020, the EU published the “EU’s chemicals strategy for sustainability” towards a toxic-free environment, as a part of the EU’s Zero pollution ambition, which is a key commitment of the European Union (European Commission, 2020). 

Its objectives are to better protect citizens and the environment and to boost innovation for safe and sustainable chemicals. 

To do this, the strategy bans the most harmful chemicals in products (although they can be allowed if there is no alternative); takes into consideration the “cocktail effect” of mixing chemicals; phases out the use of per- and polyfluoroalkyl substances (PFAS); promotes the EU’s resilience of supply and sustainability of critical chemicals; and tries to play a leading role globally in this aspect, among other actions. 

The EU sees the transition to chemicals that are safe and sustainable by design as a great economic opportunity, as well as a key component of EU’s recovery from the COVID-19 crisis.  

The Annex XVII of REACH sets out the list of restrictions of the manufacture, placing on the market, and use of certain dangerous chemical substances, mixtures and articles.  

Some of the restricted or prohibited substances used in fashion and textiles are: 

  • Asbestos (prohibited) 
  • Cadmium (in plastics, painted articles and jewellery) 
  • Pesticides (prohibited) 
  • Nickel (in articles with direct contact with the skin) 
  • Azocolorants and azodyes (textile and leather articles) 
  • Chromium VI (in leather articles in contact with the skin) 
  • Phtalates (in toys and childcare articles) 
  • Lead (in jewellery or accessible parts) 
  • Flame retardants 
  • Formaldehydes 

The appearance of these substances in bigger quantities than allowed would lead to the recall of the products containing them. This is a real problem of sustainability, not only environmental because of the use of resources and the pollution, but mainly social, as these substances pose a danger to human health. 

The Commission Staff Work Document of 25th April 2022 points out the problem that recycling can pose in Europe in terms of chemical substances, when traceability of substances might be lost.  

The aim would be that the words “Recycled in the EU” would mean a benchmark worldwide because it ensures that substances of concern in products and recycled materials are minimised. In this case, the same limit value for hazardous substances should apply for virgin and recycled material. By the moment, it is not easy to apply.  

These regulations apply to recycling plastics and textiles, but also the packaging used for food. It is the main link between fashion and food in this topic.  

  

A lot of fashion companies have problems with chemical substances.  

On the contrary, some companies use the compliance with REACH as a marketing claim. It could be considered as a “greenwashing “claim, as the minimum for a company is to fulfil with these regulations. 

Communication From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions Chemicals Strategy for Sustainability Towards a Toxic-Free Environment, (2020). Brussels, 14.10.2020 COM (2020) 667 final. https://ec.europa.eu/environment/pdf/chemicals/2020/10/Strategy.pdf 

https://ec.europa.eu/environment/chemicals/reach/reach_en.htm

Commission Staff Working Document Restrictions Roadmap under the Chemicals Strategy for Sustainability (25/04/2022). https://ec.europa.eu/docsroom/documents/49734 

CLP Regulation https://echa.europa.eu/regulations/clp/legislation

European Commission. (2020). Chemicals strategy. Retrieved from https://environment.ec.europa.eu/strategy/chemicals-strategy_en#objectives