A dated declaration
A declaration pinned to a Candidate List version, naming each substance with its EC or CAS number and concentration, signed by a named person. This is what a buyer contract actually asks for.
Regulation (EC) 1907/2006 · REACH · SVHC Candidate List, more than 250 substances of very high concern
REACH: what an importer must prove.
A substance on the Candidate List, above 0.1% of any one component, and the whole product carries the duty. There is no REACH certificate. What a buyer accepts is a dated declaration, and the list behind it moves twice a year.
SVHC and the Candidate List
One substance in one small part puts the whole product in scope.
A five-gram zipper pull can put a six-hundred-gram jacket in scope. If a substance of very high concern (SVHC) on the Candidate List sits above 0.1% of the weight of any one component, the whole product carries the duty. The threshold is measured against the part, not the finished product, so building the part into something bigger never dilutes it away.
A substance hides in the smallest part. The 0.1% threshold is measured against that part, and the duty still lands on whoever brings the finished product across the border.
250+substances on the Candidate List, and it grows twice a year
45days you have to answer a consumer who asks, and the answer is free
0official REACH certificates exist. The proof is a dated declaration
Once an item is an article, it stays an article. The 0.1% threshold applies to every component article, even after it is built into a larger product.
The holding of C-106/14, Court of Justice of the EU, in plain wordsREACH declaration process
The seven steps to a REACH declaration.
The answer is scattered across every part in the product and every supplier behind it. Getting to one dated declaration takes seven moves. This is the work REACH asks for. REACH screening is not live in Bindu yet; today, Bindu files EUDR end to end and carries substance answers on the textile product passport.
01 / 07 · Decompose
Break the product into its parts.
The product has to come apart to the lowest article level, because the 0.1% threshold is measured against each component, not the whole product.
component articleslowest level0.1% denominator
Annex XVII restrictions
What the border checks, restriction by restriction.
This page covers the textile rule set first: footwear and apparel, customs chapters 61 to 64. Two restrictions land in 2026, on top of the Candidate List that always applies. Pick a restriction.
Candidate List250+ substances, above 0.1% per part
Candidate ListInform business buyers (Art. 33)
Candidate ListAnswer consumers free within 45 days
Candidate ListUpdated about twice a year
FormaldehydeAnnex XVII, entry 77
Formaldehyde0.062 mg/m³ for furniture and wood
Formaldehyde0.080 mg/m³ for other articles
FormaldehydeApplies from 6 August 2026
PFHxAAnnex XVII, entry 79
PFHxAConsumer textiles and footwear
PFHxA25 ppb, 1,000 ppb for the sums
PFHxAApplies from 10 October 2026
Azo dyesAnnex XVII, entry 43
Azo dyes22 restricted aromatic amines
Azo dyes30 mg/kg per amine, skin contact
Azo dyesTested by EN 14362
Chromium VIAnnex XVII, entry 47
Chromium VIChromium VI in leather
Chromium VI3 mg/kg limit
Chromium VITested by ISO 17075
PhthalatesAnnex XVII, entry 51
PhthalatesDEHP, DBP, BBP and DIBP
Phthalates0.1% by weight, as a sum
PhthalatesPlasticised materials
NickelAnnex XVII, entry 27
NickelProlonged skin contact
Nickel0.5 µg/cm² a week release
NickelTested by EN 1811
Private buyer standards like AFIRM and OEKO-TEX sit above this legal floor. The restrictions here are the floor the border enforces, and the Candidate List behind them moves about twice a year.
REACH compliance proof
What proof holds up.
There is no REACH certificate. What a buyer accepts is a dated declaration, not a badge, and buyers know the difference.
A one-line letter
A generic 'REACH compliant' note with no list version and no substance names proves nothing. It also expires the moment the list moves, which it does twice a year.
A test report
A lab result against a specific restriction limit backs a claim on a part. The accreditation body's public register is where a human confirms the lab, since those registers have no API.
The Y-code, the customs remark code that tells the border a REACH restriction was checked, has been on the customs form since 2023. From 2026, checking it is where enforcement is moving, not a certificate. A claim is only as good as the list version it is pinned to.
REACH deadlines
The REACH dates that apply to you.
REACH has no single start date. The Candidate List grows twice a year, and two textile restrictions land in 2026. The two dates in cobalt are where it gets real for an importer.
Formaldehyde emission limits under Annex XVII entry 77 apply to consumer articles, including textiles and wood-based furniture.
Why REACH answers expire
Why a REACH answer expires.
Screen a product today and it is clean. Then the Candidate List adds two substances, and one of them is in a dye you use. The answer you filed is now wrong, and nobody told you.
That is the treadmill. The list moves about twice a year, and every update re-opens every prior screening. The work is not screening once; it is screening again, on every change, across every part you ever declared: a job for a system that re-runs the screen on every change, so the answer stays true instead of quietly going stale.
- the answer goes stale
- the buyer re-asks
- a new substance lands
- a part slips through
REACH screening
The six pieces a REACH screening needs.
REACH is screening against a list that keeps moving, part by part. The pipeline below is what that takes: parts in, a dated declaration out, re-run every time the list changes. None of it is live in Bindu yet. Pick a piece.
The denominator
Article decomposer
Planned. Breaks each product into its component articles, because the 0.1% is measured against the part, not the whole. A complex product becomes the list of parts it is really made of.
- Component articles
- Lowest level
- 0.1% base
From the blog
Read more from the blog.
Fundamentals · 7 min readWhat is REACH? EU Chemical Rules for ImportersREACH is the EU regulation that controls chemicals in the products you import. What it covers, who carries the duty, and the four steps behind the name.Fundamentals · 7 min readWhat is an SVHC? The REACH Candidate List ExplainedAn SVHC is a substance of very high concern under REACH. What puts a substance on the Candidate List, the 0.1% rule, and the duties it triggers for importers.Reference · 7 min readREACH Annex XVII: The Restricted Substances ListREACH Annex XVII is the list of restricted substances and the limits on them. How restrictions work, the entries importers hit most, and what to check per part.
FAQ
Frequently asked questions.
REACH covers chemical substances made in or imported into the EU, on their own, in mixtures, and inside articles. It works through four duties: registration, evaluation, authorisation and restriction. For an importer of finished goods, the duties that bite are the Candidate List obligations for substances of very high concern and the Annex XVII restrictions, which apply to imports.
A substance of very high concern (SVHC) is a chemical identified as, for example, carcinogenic, mutagenic, toxic to reproduction, or persistent and bioaccumulative. Substances so identified are added to the Candidate List, which holds more than 250 substances of very high concern; ECHA updates it about twice a year, so check the list for the exact current count.
Source: ECHA: REACH Candidate List of substances of very high concern
If a Candidate List substance is present above 0.1% by weight of a component article, the supplier must pass information down the chain. The threshold is measured against each component, not the assembled product, so a small part with a concentrated substance still puts the finished product in scope. Dilution across an assembly never removes the duty.
No. Neither a REACH certificate nor an accredited REACH certification scheme exists in the regulation. What buyers ask for is a self-declaration: a dated statement pinned to a Candidate List version, naming any substance present above the threshold, with the substance name and EC or CAS number. A generic 'REACH compliant' letter with no list version and no substance names is not proof.
Identify the substances in each component, screen them against the current Candidate List and the Annex XVII restrictions, and provide a dated declaration. Business customers must be informed under Article 33 of REACH; a consumer who asks must receive an answer free of charge within 45 days.
The Candidate List now holds more than 250 substances of very high concern, and ECHA updates it about twice a year. Two restricted-substance entries that bite on textiles take effect under Annex XVII: formaldehyde emission limits from 6 August 2026, and PFHxA in consumer textiles and footwear from 10 October 2026. The planned REACH revision was shelved in April 2026, with enforcement shifting to the border, where customs declarations already carry REACH Y-codes per CN code.
Source: ECHA: REACH Candidate List of substances of very high concern
For a maker or importer of chemicals it means registering and managing them under REACH. For an importer of finished goods it is narrower: screen the substances in each component against the current Candidate List and the Annex XVII restrictions, pass the required information down the chain, and hold a dated declaration. There is no REACH certificate, so compliance is evidenced by that declaration, not by a stamp.
REACH covers chemical substances across all products, on their own, in mixtures and inside articles. RoHS restricts a short list of hazardous substances, such as lead, cadmium and certain phthalates, specifically in electrical and electronic equipment. They overlap for electronics, where both can apply, but REACH is far broader in scope.
Source: EUR-Lex: EU RoHS Directive
Yes. REACH reaches substances inside imported articles, so an importer of finished goods inherits the duties even though it makes no chemicals: it must communicate any Candidate List substance present above 0.1% of a component (Article 33) and meet the Annex XVII restrictions on what may be placed on the EU market. Enforcement increasingly happens at the border, against the customs declaration.
No. Since Brexit, Great Britain runs its own UK REACH regime, kept in domestic law and administered by the Health and Safety Executive rather than ECHA, with a separate candidate list and its own registration duties. Northern Ireland continues to follow EU REACH under the Windsor Framework. A supplier selling into both the EU and Great Britain has to meet two regimes whose lists can drift apart over time. Bindu screens against EU and EU-Northern-Ireland REACH.
There is no legal definition of REACH compliant and no body certifies it, so on a datasheet the phrase is only a supplier's own claim. It should mean the article has been screened against the current candidate list and the restricted-substances list, that any substance of very high concern above 0.1% of a component is being communicated, and that nothing breaches a restriction. Treat a bare REACH compliant stamp with no candidate-list version and no named substances as marketing, not evidence.
Source: EUR-Lex: EU REACH Regulation, Article 33 and Annex XVII
REACH does not require you to test every article. The duty is to know whether a candidate-list substance is present above 0.1% of a component, and you can establish that from supplier declarations, safety data sheets, and bills of materials where the composition is reliably known. Analytical testing helps when the composition is unknown, a supplier's information is missing or doubtful, or you want to verify a claim before signing your own declaration. It is a way to get the evidence, not a legal requirement in itself.
Pricing
Book a 30-minute demoWhat REACH screening costs.
REACH · covered by the PPWR offer
€0extra. REACH checks ship as part of the PPWR packaging offer.
Includedone offer covers packaging and REACH, no separate charge
- REACH screening is in build and ships as part of the PPWR packaging offer, at no separate charge.
- The design: you ask a supplier up the chain for the one document you need.
- They approve it in their own workspace, pinned to the Candidate List version of the day.
Industry: Consultancies bill this by the hour. With Bindu it is included in the packaging offer.
Keeping your workspace live is €20 a month. EU-hosted, GDPR compliant. Prices exclude VAT.
Candidate list updates
Bring one shipment to the demo.
A REACH answer means breaking a product into its parts, screening each against the dated list, asking suppliers for what is missing, and building a declaration a buyer will accept. That screening is not live in Bindu yet, so what we can do today is go through one shipment with you and show you what REACH will ask of it. The substance answers themselves ride the textile product passport.
250+ and risingsubstances on the Candidate List every part is screened against
0.1% per partmeasured against each component, not the whole product
Dated proofa declaration pinned to a list version, not a badge
45-day answera consumer question answered inside the deadline, free
Never finalan answer only holds until the list next moves