Decide who owns the REACH paperwork before you place the order
If you import garment labels into the EU, the importer named on the customs entry is the one the authorities contact when something is wrong. That is usually you, not the factory in Quanzhou. So before you approve a label spec, decide whether you are buying finished labels as articles, or buying chemicals and inks applied to your garment. The answer changes what reach compliance for garment labels actually requires from your supplier.
REACH (EC 1907/2006) regulates chemical substances in the EU. It is not a labelling law like the fibre naming rules or the US federal care labelling rules. It applies to what the label is made of, not to what the label says.
How REACH applies to garment labels as articles
Most labels, patches and hang tags are "articles" under REACH: objects with a shape, surface or design that determines their function more than their chemical composition does. For articles, the main obligations are:
- Substances of Very High Concern (SVHC) on the candidate list. If an article contains a listed substance above 0.1% by weight of the article, the supplier must give the recipient enough information for safe use. Above one tonne per year per producer or importer, notification to ECHA also applies.
- Annex XVII restrictions. These limit or ban specific substances in specific uses. Some are relevant to trims, such as certain azo dyes and nickel release from metal parts that touch skin.
- The SCIP database. Suppliers of articles containing candidate-list substances above 0.1% must submit information to ECHA's SCIP database before placing them on the EU market.
In practice, your label supplier should be able to confirm whether an SVHC declaration exists for each material in the label, and whether any Annex XVII restriction touches it.
Where the real risk sits in a label spec
Plain woven polyester or cotton labels are usually low risk. The trouble tends to come from the parts nobody lists on the purchase order:
| Label type | Main materials | Typical REACH concern | What to request |
|---|---|---|---|
| Woven labels | Polyester or cotton yarn, dye | Azo dyes, dye carriers | SVHC declaration, dye safety data |
| Printed labels | Fabric plus ink | Ink solvents, phthalates, heavy metals | Ink safety data sheet, SVHC declaration |
| Heat transfer labels |
