Status Quo Analysis - Textile Sector

The current regulatory framework, particularly in the EU, centres on REACH and the upcoming ESPR requirements. However, significant challenges exist in implementation. According to the Swedish Chemicals Agency (2014) report, textile articles consumed in the EU, of which approximately 80% are imported from non-EU countries, include a wide variety of categories such as clothing, household items, and other related goods. Carpets are explicitly mentioned as a part of the household textile category, dominating this segment with a 38% market share. Even though there are existing mechanisms, such as REACH Article 33 (SVHC information on articles) or pending obligations, such as the Digital Product Passport under ESPR, information availability, especially in imported articles, is inherently scarcer.

Data availability under REACH presents a complex challenge for chemical traceability in textiles. Of approximately 3,500 substances identified as relevant for textile use, about 2,000 remain unregistered under REACH for various reasons, which poses a potential compliance issue (Swedish Chemicals Agency, 2014). Some substances may fall below REACH's one-tonne annual threshold for registration requirements, while others might be classified as intermediates or fall under other specific regulatory categories. This registration gap should not be interpreted solely as a potential compliance issue, but rather as a reflection of REACH's structured approach to chemical registration, which includes various thresholds and exemptions. Furthermore, current REACH information requirements for articles only cover Substances of Very High Concern (SVHC) listed on the Candidate list, leaving out many potentially harmful substances, including most sensitizing chemicals. This combination of registration thresholds and limited information requirements for articles creates challenges for comprehensive chemical traceability in the textile sector.