Page 44 - CITDBooklet

Guide on the application of REACH Regulation

IMPACT OF REACH ON VARIOUS INDUSTRY SECTORS IN INDIA

8.3 Textile /Leather Industry

Textile and Leather industry (processing houses, operational units, retailers, brand owners,
consumers) are concerned only with “Articles” under REACH as they handle yarns, fibers,
fabric, garments, non-wovens, hides, leather, shoes, bags, garments, gloves, belts, purses/
wallets etc. all of which may be defined as “Articles”.

Impact of REACH therefore is restricted to “Substances in Articles”.

Their concern related to REACH may be divided in three categories

1. Presence of substances ‘intended for release’

2. Presence of SVHC’s and substances subject to Authorization ( Annex XIV of
REACH)

3. Presence of Restricted substances (Annex XVII of REACH)

1. Textile containing substances intended for release.

Substances in “Articles” are subject to registration, evaluation and authorization under
REACH, only if they are intended for release under normal and foreseeable conditions and
exceed 1 tonne per annum.

Majority of the textile articles do not contain substances intended to be released. Here one
needs to clearly understand that releases during wash off (denims), wear and tear, improper
fastness, fading effects etc. do not fall under “intended releases”

The only types which may be affected. may be certain textiles intentionally coated with
substances (free or encapsulated) for certain specific effects such as Vitamin E coatings,
antibacterial coatings for control of perspiration odours, coatings for repellant effects etc.

Even in these cases, the quantity of substances (calculated as quantities per square meters)
and the total articles per year may not exceed the cut-off limit of 1 tone/annum thereby not
requiring registration.

Further such coatings will always be of preparations containing more than one component.
Hence calculations have to be done at component levels before deciding on the need for
registration.

Wherever these cut-off limits are crossed, registration needs to be done for such
substances.

2. Presence of SVHC’s

This is of more immediate concern. Textile manufacturers and importers in EU ( and non
EU exporters) need to constantly keep a tab on list of SVHC’s which is ever expanding as
more as more substances get incorporated in this list. The current list contains 161 substances
(dated 17.12.2014). However as eventually SVHC list will contain all CMR’s, vPvB’s, PBT’s and
Endocrine disruptors, this list may blow up to thousands.
It is not necessary and practically and economically viable to test for all SVHC’s. The
manufacturers need to examine the chemistry, theoretical possibilities of SVHC’s and do very
selective testing if necessary.
Textile industry needs to get certificates from manufacturers of colourants and auxiliaries
that their preparations meet the SVHC requirements of REACH. (not exceeding 0.1%).
Here again it is pertinent to note that cut-off limit may not always be 0.1% as Article 56- 6(b)
puts the cut-off limit as –“ for all other substances, below the lowest of the concentration
limits specified in Directive 1999/45/EC or in annex I of Directive 67/548/EC which result in
classification of the preparation as dangerous.”

44