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, giving at least the substance name.

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 Jan 2021, and Article 9(2) required the agency to build a database for that data by 5 Jan 2020. A targeted revision of the directive entered into force on 16 Oct 2025 and focuses on food and textile waste (European Commission). That puts the waste stage inside a textile compliance file.

Six 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 or to a rug.

Entry 72 arrived through Commission Regulation (EU) 2018/1513, which restricts the substances in its Appendix 12 in consumer clothing, textiles and footwear from 1 Nov 2020. Listed phthalates (1,000 mg/kg), PAHs and solvent residues sit in the same Appendix. The entry does not apply to articles made exclusively of natural leather, fur or hide, to non-textile fasteners and decorative attachments, to wall-to-wall carpets, rugs and runners, to second-hand goods, or to PPE and medical devices. A leather order therefore moves onto entries 47 and 43, and the metal buttons on a shirt fall to entry 27 instead.

Commission Regulation (EU) 2023/1464 added entry 77, which limits formaldehyde released from articles into air, measured in a test chamber under its Appendix 14, from 6 Aug 2026. It does not apply to articles already covered by entry 72, so it does not stack on a consumer shirt. It does reach the products entry 72 leaves out. For a Pakistani rug or carpet exporter, entry 77 is now the formaldehyde rule that applies, and it is an emission test, not the milligrams per kilogram content test a garment report shows.

Commission Regulation (EU) 2024/2462 added entry 79 for PFHxA, a short-chain PFAS used in water and stain repellent finishes. Articles placed on the market before each date are exempt, but goods shipped after it are not.

Worked example: the 0.1 percent threshold applies to each component, not to the whole garment

The Court of Justice of the EU ruled on 10 Sep 2015 (Case C-106/14) that for a product made of several articles, the 0.1 percent threshold is checked for each constituent article. The supplier must inform the recipient when any one of them is above it.

Take a 600 g jacket with a 12 g printed PVC badge sewn on. The badge contains 0.06 g of a candidate-list substance that no Annex XVII entry restricts:

The badge result decides the outcome, so the supplier must name the substance to the buyer. A test that ground the whole jacket into one sample would have diluted the badge fifty-fold and reported nothing to disclose. SVHC screening has to sample by component: shell fabric, lining, print, badge, trims and coatings separately.

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, so the laboratory applies reductive cleavage and then looks for the listed amines. The AFIRM Restricted Substances List (2026, Version 11) 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 17234-1:2024 and EN ISO 17234-2:2011. A report citing Part 1 alone leaves the Part 3 amine untested. The guide to reading a Pakistani test report sets out how to spot 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 Nov 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, with Part 1 preferred where results are in doubt.

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. AFIRM asks for EN ISO 17075-1 with Part 2, the chromatographic method, to confirm results where the extract interferes; for textiles it screens total chromium first (EN 16711-2) and tests for chromium VI only if chromium is found.

Nickel is limited by release, not content, because the risk is skin sensitisation from a metal surface. The AFIRM RSL hub and list point 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.

A brand RSL can be stricter than the law

Most apparel buyers test against their own RSL, and many follow the AFIRM list. Where its limit is lower than the legal one, a report judged against the REACH figure can pass the law and still fail the buyer:

The report must state which limit it applied. One number judged against the wrong limit gives the wrong verdict.

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

ECHA publishes and maintains the candidate list. It names substances that meet the criteria in Article 57 after an Article 59 assessment. It held 253 entries after the update of 4 Feb 2026, and because no new SVHC proposals were submitted during 2026, ECHA expects the next update in Jun 2027. 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 a panel test, and the panel moves. 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.

Dates that change REACH testing in 2026 and 2027

The PFCA listing comes from Commission Delegated Regulation C(2026) 6059, adopted on 7 Sep 2026; C9 to C14 PFCAs were already restricted under REACH entry 68. The textile ecodesign date is the indicative one in the Commission's 2025 to 2030 working plan.

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: 75 mg/kg formaldehyde belongs to entry 72 and textiles, 3 mg/kg chromium VI to entry 47 and 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.

Seven errors that weaken a REACH file

• 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 run on the whole garment, which dilutes a print, badge or coating below 0.1 percent.

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

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

• A rug tested for formaldehyde content when entry 77 asks for emission from 6 Aug 2026.

• A result judged against the REACH limit when the buyer's RSL sets a lower one.

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

Write the requirement into the purchase order

• The Annex XVII entries that apply to the product, by number.

• The limit for each, and whether the buyer's RSL replaces it, with the RSL version.

• The test method and year for each substance and material.

• SVHC screening by component, against a named candidate list date.

• A laboratory accredited for those methods, quoted as a scope reference.

• Sampling from production, with the report dated before the goods ship.

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 has served the leather industry since 2012, lists REACH compliance support, and works to 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.

• Chemical testing for CPSIA, EU REACH and Proposition 65 compliance 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.