REACH Compliance and the Digital Product Passport: Chemical Transparency for Textile Brands

REACH — the EU's regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals — has applied to textile products for over a decade. The EU's Digital Product Passport under ESPR now requires that this chemical compliance information be digitally accessible at product level. This article explains the connection between REACH and DPP, and what textile brands need to document.

What REACH Requires for Textiles

REACH (Regulation EC No 1907/2006) applies to textile products at two primary points:

• Substances of Very High Concern (SVHCs): Under REACH Article 33, importers and suppliers of articles (including textiles) must inform recipients — and upon request, consumers — if an article contains a SVHC above 0.1% by weight. SVHCs include certain dyes, flame retardants, plasticisers, and heavy metal compounds.
• Restricted substances (Annex XVII): REACH Annex XVII restricts the use of specific substances in textile products. Key restrictions relevant to textiles include limits on certain azo dyes (which can release carcinogenic aromatic amines), nickel in accessories with prolonged skin contact, and certain flame retardants.

Textile brands importing products into the EU must be able to demonstrate compliance with both frameworks. Historically, this meant maintaining a Restricted Substances List (RSL) and requesting test reports from suppliers. The DPP makes this documentation machine-readable and publicly accessible.

How REACH Maps to the DPP Harmful Substances Field

epassportify's product wizard includes a Harmful Substances Declaration field in Step 4 (Compliance & Care). This is the primary field where REACH compliance evidence is documented in the DPP structure.

The field is a text-based declaration where you document the chemical compliance status of the product. Depending on your documentation approach, this can take several forms:

Option 1: Certificate Reference

If the product holds an OEKO-TEX Standard 100 certificate (which tests for REACH-restricted substances and SVHCs), reference it:

"All restricted substances comply with REACH Annex XVII and SVHC disclosure obligations. OEKO-TEX Standard 100 certificate [number] covers restricted substance testing for this product."

Option 2: Supplier Declaration Reference

If compliance is evidenced by supplier RSL test reports rather than a product certification:

"No substances from the REACH SVHC candidate list are present above 0.1% by weight. Compliance with REACH Annex XVII restrictions confirmed by supplier test reports dated [date], available upon request from authorised market surveillance authorities."

Option 3: Full SVHC Absence Declaration

For products where full testing has confirmed no SVHCs above threshold:

"This product does not contain Substances of Very High Concern (SVHCs) on the REACH candidate list above 0.1% by weight as of [date of assessment]. No REACH Annex XVII restricted substance limits are exceeded."

The ESPR Connection: Why DPP Makes REACH Obligations Stricter

Under REACH Article 33, SVHC disclosure to consumers is triggered only "upon request." The ESPR changes this dynamic: the DPP must be accessible to any consumer who scans a QR code. This means that any SVHC presence above threshold must be disclosed proactively — not reactively — in the DPP's harmful substances section.

This is a significant shift from current practice. Brands that have been managing REACH compliance reactively (responding to supplier or customer queries) now need to build that information into the product's DPP data from the point of manufacture.

Azo Dyes and Colour Documentation

One of the most common REACH compliance questions in textiles concerns azo dyes — a large family of synthetic colorants where certain compounds can release carcinogenic aromatic amines. REACH Annex XVII Entry 43 restricts the use of specific azo dyes in textiles intended to come into prolonged contact with skin or the mouth.

In epassportify, azo dye compliance is documented through the Harmful Substances Declaration field. If your dyeing process has been tested and confirmed compliant, reference the test report or certification. If the product uses certified natural dyes or dyes that have been confirmed free of restricted azo compounds, state this explicitly.

Connecting REACH to the Supply Chain Data

REACH compliance begins at the dyeing and finishing stage of textile production — which corresponds directly to the Dyeing & Printing Country field in epassportify's Supply Chain step (Step 3). Documenting the country where dyeing occurred, and the supplier responsible, creates the audit trail that connects your harmful substances declaration to the specific facility that processed the fabric.

Market surveillance authorities investigating a REACH compliance issue need to trace from the finished product back to the processing facility. The DPP supply chain data — dye house country, supplier name — provides this traceability layer.

What REACH Compliance Does Not Cover in the DPP

REACH addresses chemical substances. It does not cover the other DPP requirements that ESPR adds:

• Material fibre composition percentages
• Recycled content percentages
• Production country traceability beyond the article importer
• Care and durability information
• Microplastics shedding data

These additional data points must be collected and entered separately in the DPP. REACH compliance is necessary but not sufficient for a complete ESPR-compliant Digital Product Passport.

Practical Steps for Textile Brands

1. Review your current RSL compliance documentation — supplier test reports, OEKO-TEX certificates, or equivalent.
2. Draft a Harmful Substances Declaration statement that accurately reflects your compliance evidence. Do not overstate coverage (e.g., do not reference an OEKO-TEX certificate as covering REACH if the certificate has expired).
3. Enter this declaration in the Harmful Substances Declaration field in epassportify's Step 4 for each relevant product or variant.
4. Cross-reference with your dyeing supplier entry in Step 3 — the facility responsible for chemical compliance should be documented as a supplier.
5. Update the declaration when certificates are renewed or when the SVHC candidate list is updated (ECHA typically updates the list twice per year).

Conclusion

REACH and the Digital Product Passport are not separate compliance exercises — they are connected layers of the same EU chemical transparency framework. The DPP's Harmful Substances Declaration field is where REACH compliance becomes machine-readable and publicly verifiable. Textile brands that structure their existing REACH documentation into this field — rather than keeping it in supplier files — are building a verifiable compliance record that will satisfy both current obligations and the approaching ESPR mandate.