Compliance
Industry Insight
REACH Testing for Pakistan Textiles, Leather and Footwear
REACH testing for Pakistan textile and leather exports: SVHC duties, Annex XVII limits for azo dyes, formaldehyde, chromium VI and nickel, and usable reports.
REACH reaches a textile or leather article through three separate duties. Buyers usually ask about one. An order can clear every Annex XVII limit and still fail the communication duty attached to the candidate list of substances of very high concern. Which duty applies decides whether a Pakistani test report is accepted at the buyer's compliance desk. The evidence must match the duty.
Key Takeaways
REACH puts three distinct duties on articles: candidate-list communication, Annex XVII limits, and waste-stage information to ECHA.
Annex XVII entry 72 caps formaldehyde at 75 mg/kg in consumer clothing, textiles and footwear.
Azo amines, chromium VI and nickel each carry a separate entry, limit and accredited test method.
A test report is evidence only when the named method sits inside the laboratory's accreditation scope.
TTI holds ISO/IEC 17025 accreditation through PNAC, published as LAB-022.
Three REACH duties, and how they differ
REACH is one regulation carrying several obligations, and they behave differently. A textile or leather exporter meets three of them.
The first is a communication duty. Article 33 requires the supplier of an article to pass on enough information for safe use when a candidate-list substance is present above 0.1 percent by weight.
The second is restriction. Annex XVII sets substance-level limits that apply to the article itself. A garment above an entry's limit cannot be placed on the EU market. No disclosure cures that.
The third sits in 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 from 5 January 2021, while 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 it added textile waste rules and producer responsibility for textiles, which puts the waste stage inside a textile compliance file (European Commission).
Duty | Where it sits | What triggers it | What it asks |
|---|---|---|---|
SVHC communication | REACH Article 33 | A candidate-list substance above 0.1 percent by weight | Tell the recipient the substance name and how to use the article safely |
Notification to ECHA | REACH Article 7(2) | The same threshold, plus more than one tonne a year | Notify the agency. The EU importer carries this duty |
Restricted substances | REACH Annex XVII | The entry's own scope and limit | Prove the article meets the limit before it ships |
Waste-stage information | Waste Framework Directive Article 9(1) | Article 33(1) information exists for the article | Supply that information to ECHA from 5 January 2021 |
The duties do not overlap, so clearing one proves nothing about the others. A fabric with no restricted substance above any Annex XVII limit can still contain a candidate-list substance at 0.2 percent, and that presence alone switches on Article 33 entirely.
Which Annex XVII restrictions catch textile and leather goods
Five entries carry most of the exposure for Pakistani exports. Each has its own scope. A garment panel does not transfer to a tannery's output.
Entry | Substance | Scope | Limit |
|---|---|---|---|
43 | Azo dyes that release listed aromatic amines | Textile and leather articles contacting skin or the mouth | 30 mg/kg per amine |
72 | CMR substances, formaldehyde included | Consumer clothing, textiles and footwear | Formaldehyde 75 mg/kg, chromium VI 1 mg/kg |
47 | Chromium VI | Leather articles and leather parts contacting skin | 3 mg/kg of dry leather |
27 | Nickel release | Metal items with prolonged skin contact | 0.5 micrograms per square centimetre per week |
77 | Formaldehyde emissions | Articles placed on the market | 0.062 and 0.080 mg/m3 from 6 August 2026 |
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, but exempts articles made exclusively of natural leather, fur or hide. That exemption moves a leather order onto entry 47 and entry 43 instead.
Entry 77 works differently. Commission Regulation (EU) 2023/1464 restricts formaldehyde emitted from articles, measured in a test chamber, from 6 August 2026. It does not replace the content limit in entry 72. It measures air concentration, not milligrams per kilogram of material.
Azo dyes, formaldehyde, chromium VI and nickel
Azo dyes. Entry 43 targets the aromatic amines a dye can release, not the dye molecule itself, so a laboratory applies reductive cleavage and 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 instead, and a report citing Part 1 alone leaves the Part 3 amine untested. The guide to reading a Pakistani test report sets that gap out.
Formaldehyde. The content limit is 75 mg/kg in consumer clothing, textiles and footwear, while 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, and leather uses EN ISO 17226-1 or EN ISO 17226-2 instead.
Chromium VI. Entry 47 sets 3 mg/kg on the dry weight of leather. 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. Entry 27 governs release rather than content, because the risk is skin sensitisation from a metal surface. The limits are 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 for wear and corrosion simulation, followed by EN 1811:2023, and on a pair of jeans the exposure sits in the rivets, buttons and zip pulls.
The SVHC candidate list, and what it asks of an exporter
The candidate list is not a limit list: it names substances meeting the criteria in Article 57 after an Article 59 assessment, and ECHA publishes and maintains it. Membership adds no concentration ceiling of its own.
What membership adds is a trigger. Above 0.1 percent by weight in an article, Article 33 switches on. Above the same threshold, notification to ECHA under Article 7(2) can apply. It binds the importer when a substance exceeds one tonne a year.
Two points follow 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.
What a test report must show to count as evidence
A result on its own is not evidence. Six elements turn a page of numbers into something a buyer's compliance desk can file.
Element | Where it appears | Why it decides the outcome |
|---|---|---|
Accredited method code with its year | Results table | Ties the result to the exact method version the buyer's standard names |
Accreditation identity and scope reference | Report header and scope document | Shows the method sits inside the accredited scope |
The limit applied, and the entry behind it | Results table | A number without a limit cannot be judged |
Measurement uncertainty | Uncertainty statement | Decides a borderline result |
Sample identification and sampling basis | Sample section | Links the result to the goods in the order |
Report dates and laboratory identity | Header and signature block | Places the result in time against the shipment |
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. Swapping them invalidates the conclusion.
TTI's accreditation scope is published as a 19-page document through the Pakistan National Accreditation Council, so a buyer can check that a method sits inside it.
Where REACH files usually fail
Five failures account for most rejected documents.
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.
The frequent cause is a purchase order that says "REACH compliant" without naming an entry, a limit or a method.
How TTI supports REACH testing
TTI Testing Laboratories holds ISO/IEC 17025 accreditation through the Pakistan National Accreditation Council, published as LAB-022, and the scope covers textiles and apparel, leather and footwear, and chemical testing.
The leather and footwear laboratory runs chromium VI screening by ion chromatography to EN ISO 17075-2, and it works to the full REACH restricted substances panel alongside EN, ISO, AATCC, ASTM, SATRA and IULTCS methods and the AFIRM RSL.
The testing division publishes 544 accredited methods and 378 accredited parameters across its sectors, and for textile programmes the textiles and apparel services cover restricted substances and RSL analysis inside the same accredited house.
TTI reports results for the samples submitted and the methods performed, and it does not certify a product. A passing report does not establish market compliance.
FAQ
What is REACH testing for textiles? Laboratory analysis of a textile or leather article against the substance limits in REACH Annex XVII, plus screening for candidate-list substances. It produces evidence, not a REACH certificate.
What is the difference between the SVHC candidate list and Annex XVII? Annex XVII sets concentration limits an article must meet. The candidate list sets no limit. It triggers a communication duty above 0.1 percent by weight.
Which substances matter most for Pakistani textile and leather exports? Azo dyes that release listed aromatic amines, formaldehyde, chromium VI in leather, and nickel release from metal trims. Phthalates, PAHs and solvent residues share the same entry 72 list.
Do buyers accept a test report from any laboratory? Rarely. Buyers check that the method sits inside the laboratory's accreditation scope. A report citing a method outside that scope is not the evidence they asked for.
Does a passing report prove REACH compliance? No. It proves the sample met the stated limit by the stated method on the stated date. Compliance also depends on testing the right entry and the current candidate list.
Conclusion
REACH applies three separate duties to articles, and clearing one says nothing about the others.
The entry decides the limit, the method and the material, so textile and leather panels are not interchangeable.
The candidate list moves, so an SVHC screen is only as good as the list version it names.
A usable report shows the accredited method, the scope reference, the limit, the uncertainty and the sample identity.
Book REACH restricted substance testing with TTI Testing Laboratories. UAN 111 786 001. ISO/IEC 17025 accredited, PNAC LAB-022.
References
Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), EUR-Lex, https://eur-lex.europa.eu/eli/reg/2006/1907/oj/eng
Commission Regulation (EU) 2018/1513 amending Annex XVII to Regulation (EC) No 1907/2006 as regards certain substances classified as carcinogenic, mutagenic or toxic for reproduction (Annex XVII entry 72), EUR-Lex, https://eur-lex.europa.eu/eli/reg/2018/1513/oj/eng
Commission Regulation (EU) No 301/2014 amending Annex XVII to Regulation (EC) No 1907/2006 as regards chromium VI in leather articles (Annex XVII entry 47), EUR-Lex, https://eur-lex.europa.eu/eli/reg/2014/301/oj/eng
Commission Regulation (EU) 2023/1464 amending Annex XVII to Regulation (EC) No 1907/2006 as regards formaldehyde and formaldehyde releasers (Annex XVII entry 77), EUR-Lex, https://eur-lex.europa.eu/eli/reg/2023/1464/oj/eng
Directive 2008/98/EC on waste, consolidated text of 16 October 2025, Article 9(1)(i) and Article 9(2), EUR-Lex, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02008L0098-20251016
Waste Framework Directive, European Commission, https://environment.ec.europa.eu/topics/waste-and-recycling/waste-framework-directive_en
AFIRM Restricted Substances List, English edition, AFIRM Group, https://afirm-group.com/AFIRM_RSL_EN
AFIRM Restricted Substances List hub, AFIRM Group, https://afirm-group.com/afirm-rsl/
Accreditation scope LAB-022, Pakistan National Accreditation Council, https://pnac.gov.pk/pdfFiles/LAB-022
Analytical testing services, TTI Testing Laboratories, https://ttilabs.net/testing
Leather and footwear testing, TTI Testing Laboratories, https://ttilabs.net/leather-footwear
Textiles and apparel testing, TTI Testing Laboratories, https://ttilabs.net/textiles-apparel
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