Chemical Substances and SVHC: Traceability Obligations for Textiles Under ESPR
The ESPR mandates disclosure of hazardous chemicals in textile products—here's how REACH data integrates into your Digital Product Passport.
- The ESPR requires disclosure of **Substances of Very High Concern (SVHCs)** above 0.1% weight concentration in textile products
- REACH registration data becomes a primary source for DPP chemical information
- Brands must trace SVHCs across multi-tier supply chains, not just finished goods
- The SCIP database and DPP will work together to ensure lifecycle transparency
- Non-compliance risks include market bans, fines, and reputational damage
The Chemical Disclosure Challenge#
Textiles are chemically complex. A single garment can involve dozens of substances—from dyes and finishing agents to flame retardants and water-repellent coatings. Many of these chemicals fall under regulatory scrutiny, and the EU's Ecodesign for Sustainable Products Regulation (ESPR) now makes their disclosure mandatory for products entering the European market.
At the heart of this requirement sits REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), the EU's foundational chemical regulation. Under Article 33 of REACH, suppliers must already communicate the presence of SVHCs in articles when concentrations exceed 0.1% by weight (ECHA, 2023). The ESPR extends this obligation into the Digital Product Passport itself.
For fashion brands and textile manufacturers, this means one thing: chemical traceability is no longer optional.
What ESPR Requires for Chemical Disclosure#
The ESPR delegated acts for textiles (expected 2025–2026) will specify exact data fields, but the framework is clear. Products must disclose:
| Disclosure Category | Required Information | Data Source |
|---|---|---|
| SVHC presence | Substance name, CAS number, concentration | Supplier declarations, REACH dossiers |
| Restricted substances | Compliance with REACH Annex XVII | Lab testing, certifications |
| Recycled content chemicals | Contaminants in recycled feedstock | Traceability records |
| End-of-life hazards | Safe disposal/recycling instructions | Material composition data |
The ECHA Candidate List currently includes 240 SVHCs (ECHA, 2024), with new substances added twice yearly. Textile-relevant SVHCs include certain phthalates, per- and polyfluoroalkyl substances (PFAS), and specific azo dyes that release carcinogenic amines.
The REACH-DPP Integration Architecture#
How does REACH data flow into your Digital Product Passport? The architecture involves multiple data handoffs across your supply chain.
SCIP Database: The Existing Foundation#
Since January 2021, companies placing articles containing SVHCs on the EU market must submit notifications to ECHA's SCIP database (Substances of Concern In articles as such or in complex objects/Products). Over 123 million article notifications have been submitted to date (ECHA, 2024).
The DPP builds on SCIP rather than replacing it. Where SCIP captures basic SVHC presence for waste operators, the DPP provides richer, product-specific data accessible throughout the product lifecycle—including to consumers, recyclers, and market surveillance authorities.
Brands already submitting SCIP notifications have a head start: the same underlying data feeds both systems.
Practical Steps for Compliance#
1. Audit your chemical footprint Map which SVHCs appear in your product portfolio. Start with high-risk categories: coatings, dyes, and functional finishes.
2. Require supplier declarations Implement standardised SVHC declaration forms across your supply chain. The ZDHC MRSL (Manufacturing Restricted Substances List) provides a useful baseline beyond regulatory minimums (ZDHC, 2023).
3. Centralise chemical data Spreadsheets don't scale. You need a system that links chemical data to specific products, suppliers, and production batches.
4. Test strategically Third-party lab testing validates supplier claims. Prioritise testing for materials from new suppliers or high-risk geographies.
Frequently asked questions
Do I need to disclose ALL chemicals, or just SVHCs?
The ESPR focuses on SVHCs (Candidate List substances above 0.1% w/w) and restricted substances under REACH Annex XVII. Full formulation disclosure is not required—but brands pursuing voluntary certifications like OEKO-TEX or bluesign may disclose more comprehensively.
What if my supplier won't share chemical information?
This is a common challenge, especially in deep supply chains. The ESPR creates legal pressure: if you cannot demonstrate compliance, you cannot sell in the EU. Frame supplier requests as market access requirements, not optional audits.
How often must DPP chemical data be updated?
The DPP reflects the product as placed on the market. If formulations change, new products require updated passports. The ECHA Candidate List updates (typically January and July) may also trigger reassessment of existing products.
Moving Forward#
Chemical traceability represents one of the more technically demanding aspects of DPP compliance. The data exists—scattered across supplier declarations, Safety Data Sheets, and lab reports—but consolidating it into passport-ready format requires infrastructure.
Trama helps brands centralise chemical data alongside material composition, supplier information, and care instructions—structuring it for DPP requirements while maintaining the audit trail regulators expect.
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