REACH Testing for Pakistan Textiles, Leather and Footwear

The three duties have separate triggers, so clearing one proves nothing about the others

Under REACH Article 33, the supplier of an article must pass on enough information for safe use when a candidate-list substance is present above 0.1 percent by weight.

Annex XVII restrictions set substance-level limits that apply to the article itself. A garment above an entry's limit cannot be placed on the EU market, and no disclosure cures that.

The third duty comes from waste law. Article 9(1) of the Waste Framework Directive requires suppliers of articles to give the Article 33(1) information to the European Chemicals Agency (ECHA) from 5 January 2021, and Article 9(2) required the agency to build a database for that data by 5 January 2020. A 2025 revision of the directive entered into force on 16 October 2025 and added textile waste rules and producer responsibility for textiles (European Commission). That puts the waste stage inside a textile compliance file.

Five Annex XVII entries carry most of the exposure for Pakistani exports

Each entry has its own scope, so a garment panel does not transfer to a tannery's output.

Entry 72 arrived through Commission Regulation (EU) 2018/1513, which restricts the substances in its Appendix 12 in clothing, textiles and footwear from 1 November 2020. Phthalates, PAHs and solvent residues share the same entry 72 list. It exempts articles made exclusively of natural leather, fur or hide, which moves a leather order onto entries 47 and 43.

Entry 77 works differently. Commission Regulation (EU) 2023/1464 restricts formaldehyde emitted from articles, measured in a test chamber, from 6 August 2026. It measures air concentration, not milligrams per kilogram of material, and it does not replace the content limit in entry 72.

Each substance has its own test method, and the method must match the material

For azo dyes, entry 43 targets the aromatic amines a dye can release, not the dye molecule itself, so a laboratory applies reductive cleavage, then looks for the listed amines. The AFIRM Restricted Substances List names EN ISO 14362-1:2017 for the main amine panel and EN ISO 14362-3:2017 for p-aminoazobenzene, while leather follows EN ISO 17234-1 and -2. A report citing Part 1 alone leaves the Part 3 amine untested. The guide to reading a Pakistani test report sets out that gap.

Formaldehyde's content limit is 75 mg/kg in consumer clothing, textiles and footwear. A 300 mg/kg figure applied to jackets, coats and upholstery during a transition that ended on 1 November 2023. The textile method is EN ISO 14184-1, a water-extraction measurement of free and hydrolysed formaldehyde. Leather uses EN ISO 17226-1 or EN ISO 17226-2.

Chromium VI in leather falls under entry 47, which sets 3 mg/kg on the dry weight. Commission Regulation (EU) No 301/2014 names EN ISO 17075 as the method and calls it the only internationally recognised route for chromium VI in leather.

Nickel is limited by release, not content, because the risk is skin sensitisation from a metal surface. Entry 27 sets 0.5 micrograms per square centimetre per week for prolonged skin contact and 0.2 for pierced parts. The AFIRM RSL hub points laboratories to EN 12472:2020 to simulate wear and corrosion, followed by EN 1811:2023. On a pair of jeans, the exposure sits in the rivets, buttons and zip pulls.

The candidate list sets no limit, but a listed substance above 0.1 percent triggers a duty to inform

ECHA publishes and maintains the list. It names substances that meet the criteria in Article 57 after an Article 59 assessment. Above the same 0.1 percent threshold, notification to ECHA under Article 7(2) can apply. It binds the importer when a substance exceeds one tonne a year.

For a Pakistani mill, the obligation is information, not a pass or fail result, so a certificate cannot answer it. SVHC screening is also a panel test, and the panel moves.

Buyers then ask two questions in one email: does the article breach an Annex XVII limit, and does it contain a candidate-list substance at all? A report is only as strong as the list version it names, because a superseded list never looked for the substance the buyer is asking about.

A test report is evidence only when its method sits inside the laboratory's accredited scope

Six elements turn a page of numbers into something a buyer's compliance desk can file.

A report naming EN ISO 14362-1 without a scope reference is weaker than one naming the method and its accreditation entry. The limits are not interchangeable either. A 75 mg/kg formaldehyde figure belongs to entry 72 and to textiles, a 3 mg/kg figure to entry 47 and to leather, and swapping them invalidates the conclusion.

Tti Labs' accreditation scope is published through the Pakistan National Accreditation Council as a 19-page document, so a buyer can check that a method sits inside it.

Five errors account for most rejected REACH files

• A textile panel applied to leather, ignoring the natural leather exemption in entry 72.

• An azo report covering EN ISO 14362-1 only, with no result for p-aminoazobenzene.

• An SVHC screen naming an out-of-date candidate list version.

• A report dated after the container left, which cannot gate a shipment.

• Nickel reported as total content when entry 27 asks for release.

Often the cause is a purchase order that says "REACH compliant" without naming an entry, a limit or a method.

What Tti Labs tests for REACH restricted substances

• ISO/IEC 17025 accreditation published as LAB-022, with a scope covering textiles and apparel, leather and footwear, and chemical testing.

• Chromium VI screening by ion chromatography to EN ISO 17075-2 in the leather and footwear laboratory, which works to the full REACH restricted substances panel alongside EN, ISO, AATCC, ASTM, SATRA and IULTCS methods and the AFIRM RSL.

• 544 accredited methods and 378 accredited parameters, published by the testing division across its sectors.

• Restricted substances and RSL analysis for textile programmes through the textiles and apparel services, inside the same accredited house.

Tti Labs reports results for the samples submitted and the methods performed. It does not certify a product, and a passing report does not establish market compliance.

Book REACH restricted substance testing with Tti Labs. UAN 111 786 001. ISO/IEC 17025 accredited, PNAC LAB-022.

Related guides: Denim QC in Pakistan: Shade, Wash and Measurement, EUDR and Pakistan Leather: What the Scope Change Means.