REACH Annex XVII: The Restricted Substances List
Customs holds a container of children's textiles. The note gives one reason: azo dyes.
The importer has a test report, but it covers the wrong dye. Nobody checked which entry actually applied before the goods shipped.
That entry is a line in REACH Annex XVII. It is where REACH stops describing chemicals and starts drawing hard limits.
Knowing how an entry is built is what would have kept that container moving.
At a glance:
- Annex XVII is the restriction list of REACH: a limit or a ban you cannot exceed.
- Each entry ties a substance to a use and a limit, so one chemical can be legal in one product and banned in another.
- The list holds more than 70 entries, and it grows as the EU adds restrictions.
- The entries importers meet most cover nickel, azo dyes, chromium VI, phthalates, and formaldehyde.
- Your HS or CN code points to the entries worth checking for a given part.
What is REACH Annex XVII?
Annex XVII is the restriction list of REACH. It names substances that may not be manufactured, sold, or used in the EU beyond set conditions.
A restriction is a hard rule, not a warning. It fixes a concentration cap, a specific ban, or a labelling duty that you cannot exceed when you place a product on the EU market.
The Candidate List is about disclosure, whereas Annex XVII is about limits. This is the part of REACH with real teeth for finished goods.
It holds more than 70 entries, and it grows as the EU adds new restrictions. Each entry is its own small rule.
How a restriction is built
An Annex XVII entry is not just a banned chemical. It is a substance tied to a use and a limit.
Read any entry and you find three parts:
- The substance, or a group of them.
- The condition of use: which products or situations the rule covers.
- The limit: a concentration cap, a specific ban, or a labelling duty.
So the same substance can be fine in one product and banned in another. The use is half the rule.
That is why a blanket "is it restricted?" rarely has a yes or no answer until you name the product and the part.
A restriction can bite at three levels: the substance on its own, the substance in a mixture, and the substance in a finished article. A dye sold in a drum and the same dye fixed in a shirt are both in scope. What changes is how you prove it, by supplier data for the raw chemical or by a test on the finished part.
The entries importers hit most
A handful of entries account for a large share of everyday restriction checks. If you import consumer goods, you will meet these.
| Entry | Substance | What it restricts |
|---|---|---|
| 27 | Nickel | Nickel release from items in prolonged skin contact, such as jewellery, zips, and buttons. |
| 43 | Azo dyes | Certain azo colourants in textiles and leather that touch the skin. |
| 47 | Chromium VI | Chromium VI in leather articles that contact the skin. |
| 51 | Phthalates | Certain phthalate plasticisers in toys and childcare articles, and in wider articles. |
| 77 | Formaldehyde | Formaldehyde released from a range of consumer articles, with limits applying from 6 August 2026. |
| 79 | PFHxA | PFHxA and related substances, added as part of the wider EU move on PFAS. |
Entry 77 on formaldehyde applies from 6 August 2026 under Regulation (EU) 2023/1464. Entry 79 on PFHxA was added by Regulation (EU) 2024/2462. New entries keep arriving, so a check that passed last year can fail this year.
Two cautions before you rely on any row. First, an entry can carry exemptions, derogations, and transition dates, so read the full text, not a one-line summary. Second, the scope wording controls: "skin contact", "childcare article", and "placed on the market" each has a precise meaning that decides whether your part is in or out.
A worked example: the held textiles
Take the container from the top: it holds children's cotton shirts, dyed and in direct skin contact.
Start with the product, not the chemical, because a dyed textile that touches the skin puts entry 43 on azo dyes in scope. That is the restriction to prove before anything ships.
Now read the entry. Entry 43 bans certain azo colourants in textiles and leather that touch the skin. So the question is not whether the shirt is safe in general. It is whether the dye actually used sits on the banned list, and whether the importer can demonstrate that it does not.
The test report the importer held tested a different dye, so it proved nothing about the colourant actually present in the cloth. A correct check names the dye in the shirt, matches it to entry 43, and retains the report that covers it. That single mismatch is what held the consignment.
Annex XVII vs the Candidate List
These two lists get mixed up constantly, although they do genuinely different jobs.
The Candidate List is a disclosure trigger. It flags substances of very high concern, and it makes you tell your customers, answer consumers, and notify SCIP. It does not ban anything.
Annex XVII sets a hard rule: a limit or a ban you cannot exceed. A substance can be on the Candidate List, restricted under Annex XVII, or both at once.
For an importer, that means two questions per part, not one. What must I disclose, and what am I not allowed to place on the market at all.
The link to your HS code
Annex XVII lines up with what you are actually shipping. Most entries are written around product types, textiles, leather, toys, jewellery, and those map to how goods are classified for customs.
That is the useful link. The HS or CN code you already assign for the tariff is a strong signal for which Annex XVII entries are worth checking for that product.
So classification is not only a duty question; it is also the fastest route to the restriction shortlist for a given component.
How Bindu screens each part
The work in Annex XVII is matching, the substance, the use, and the entry, for every part in a bill of materials.
Bindu screens each part against the Annex XVII limits that apply to it. It checks the Candidate List version of the day at the same time. Then it pins the result to a dated declaration that carries the entry and the statement a customs entry needs. Start with what is REACH for the full picture. See the REACH breakdown.
FAQ
What is REACH Annex XVII? Annex XVII is the restriction list of REACH. It sets limits and bans on specific substances in specific uses, covering substances on their own, in mixtures, and in finished articles placed on the EU market.
Source: ECHA: Substances restricted under REACH (Annex XVII)
How is Annex XVII different from the Candidate List? The Candidate List flags substances of very high concern and triggers disclosure duties, but does not ban them. Annex XVII sets a hard limit or ban. A substance can appear on both.
Source: ECHA: Candidate List of substances of very high concern
How many entries are in Annex XVII? There are more than 70 entries, and the list grows as the EU adopts new restrictions. Each entry ties a substance, or group of substances, to a condition of use and a limit.
Source: ECHA: Substances restricted under REACH (Annex XVII)
Which Annex XVII restrictions affect consumer goods most? Common ones are entry 27 on nickel and entry 43 on azo dyes. Others are entry 47 on chromium VI, entry 51 on phthalates, and entry 77 on formaldehyde.
Source: EUR-Lex: Regulation (EU) 2023/1464 (formaldehyde, Annex XVII entry 77)
How do I know which Annex XVII entries apply to my product? Start from what the product is and what it is made of. The product type and its HS or CN code point to the likely entries, then each part is checked against the substance limits in those entries.
Source: ECHA: Substances restricted under REACH (Annex XVII)