Chemical compliance

EU REACH: new and emerging  restrictions for textiles

Chemical and environmental compliance requirements affecting textile and apparel supply chains continue to develop across multiple jurisdictions.

Depending on the market, businesses may face Extended Producer Responsibility (EPR) obligations, chemical restrictions affecting fibres, dyes and finishes, product-safety requirements, and obligations relating to circularity and supply-chain information.

Two EU REACH developments illustrate this changing compliance landscape:

PFHxA, its salts and related substances

From 10 October 2026, restrictions apply to undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances in clothing and related accessories, footwear and certain other consumer products.

The restriction sets concentration limits of 25 ppb for the sum of PFHxA and its salts and 1,000 ppb for the sum of PFHxA-related substances, measured in homogeneous material.

The same limits also apply to paper and cardboard food-contact materials, consumer mixtures and cosmetic products. The details of the restrictions are available here.

Businesses placing affected products on the EU market should confirm whether PFHxA-related substances may be present in materials, coatings or finishes and ensure that supporting supply-chain information is sufficient to demonstrate compliance.

The restriction will extend to other textiles, leather, fur and hides for the general public from 10 October 2027, subject to specified exemptions.

Skin-sensitising chemicals

The European Commission is also progressing a proposed restriction covering skin-sensitising substances in clothing, footwear and other articles that come into contact with the skin.

The file covers more than 1,000 substances and raises significant questions concerning compliance, enforcement and recycling. A draft restriction has not yet been published, but the Commission intends to present it as soon as possible.

These developments reinforce the need for textile and apparel businesses to understand the chemicals used in their materials, dyes, coatings and finishes, obtain reliable information from suppliers, and monitor both applicable and emerging requirements.

H2 Compliance supports brands, retailers and manufacturers with textile EPR strategy, producer registration, regulatory monitoring, reporting and data management.

Read more about these services here or contact the H2 Compliance team.

EU RoHS: hazardous substances in EEE

The EU Restriction of Hazardous Substances (RoHS) Directive limits the use of certain hazardous substances in electrical and electronic equipment (EEE). Under Directive (EU) 2025/2456, the European Chemicals Agency (ECHA) is taking on expanded scientific and technical responsibilities.

From 13 August 2027, ECHA will assess RoHS exemption applications and support the evaluation of substances that may be considered for future restrictions, while the European Commission will retain final decision-making authority. ECHA is developing harmonised guidance and application formats for RoHS exemptions.

Of particular importance to industry, ECHA is conducting a scoping study to identify substances used in EEE that may warrant possible future regulatory measures. This could provide an early indication of substances likely to face greater scrutiny under RoHS. The changes do not introduce immediate new substance restrictions. However, manufacturers, importers and suppliers of EEE should monitor ECHA’s work on RoHS as it can potentially affect them.

ECHA will explain its new responsibilities and preparations during a webinar on 26 November 2026. Further information is available here.

PIC Regulation: EU exporters notification requirement

The Prior Informed Consent (PIC) Regulation requires EU exporters to notify exports of listed hazardous chemicals before the first shipment in each calendar year.

Following updates to the PIC chemical lists from 1 October 2026, companies should screen planned exports against the current Annex I and Annex V entries, including mixtures above applicable concentration thresholds and, where relevant, articles containing listed chemicals in an unreacted form.

Export notifications must be submitted through ePIC to the exporter’s Designated National Authority at least 35 days before the expected export date and renewed before the first export in each subsequent year.

For a first export planned for 1 January 2027, the statutory deadline is 27 November 2026. Earlier submission is advisable to allow time for authority review and corrections.

Notification alone does not confirm that an export may proceed. Exporters must also determine whether explicit consent or an importing country decision applies, check for export prohibitions, use the applicable Reference Identification Number in the customs declaration, meet packaging, labelling and safety data sheet requirements, and report actual annual export quantities.

These obligations are particularly timely as an EU enforcement pilot project will inspect PIC compliance from 1 November 2026 to 15 May 2027.

For support contact the H2 Compliance team.