REACH
REACH for Indian exporters: who registers, and what your buyer needs
Importer versus Only Representative, SVHC duties on articles at 0.1%, and the restriction entries that actually hit textiles, leather and jewellery exporters.
By Aaryan Kakani · · 14 min read
Does REACH apply to you if you export finished goods, not chemicals?
The most common misconception among Indian exporters is that REACH (Regulation (EC) No 1907/2006) is only for chemical shippers. It is not. REACH catches exporters of finished articles through three separate hooks, and each works differently.
First, registration duties on substances and mixtures. Under Article 6(1), any EU manufacturer or importer of a substance (on its own or in a mixture) at 1 tonne/year or more must register it with ECHA. This hook is relevant if you export dyes, textile auxiliaries, tanning chemicals or formulated mixtures: someone on the EU side must register your product before it can lawfully be imported at that volume.
Second, article duties. Article 7 imposes notification duties on articles in narrow cases, and Article 33 imposes communication duties whenever an article contains a Candidate List substance of very high concern (SVHC) above 0.1% w/w. These apply to garments, bags, shoes and jewellery. The everyday exports of Tirupur, Kanpur and Jaipur.
Third, Annex XVII restrictions. These ban or limit specific substances in specific article types at ANY tonnage. There is no volume threshold: a single leather bag whose leather exceeds the chromium VI limit, or one earring failing the nickel migration limit, is non-compliant. Market surveillance authorities and marketplaces test articles, not tonnage.
The honest framing for this page: the legal duties under REACH mostly sit on the EU side of the transaction. The importer, not you. But the Indian exporter who cannot evidence compliance loses the buyer, because the importer will not carry a duty it cannot discharge. Your job is to know which hook applies to your product family and to hand your buyer the evidence. For the general export document stack (invoice, packing list, shipping bill, certificates), see our export documentation guide. This page stays on the REACH-specific layer.
Who registers with ECHA. You, your EU importer, or an Only Representative?
The burden allocation is precise, and worth stating precisely: under Article 6(1), the registration duty falls on the EU manufacturer or importer of a substance (on its own or in mixtures) at 1 tonne/year or more. An Indian exporter has no direct registration duty with ECHA. ECHA will not accept a registration from a non-EU entity in its own name.
That leaves a choice for exporters of substances and mixtures. Option one: leave registration with each EU importer. Each importer registers its own imported tonnage, and each bears the cost and the data burden. Option two: the Indian manufacturer appoints an Only Representative (OR) established in the EU, under Article 8(1), by mutual agreement.
The Article 8 mechanics matter. The OR fulfils the importers' registration obligations in their place. It must have sufficient background in the practical handling of substances and the information related to them, and must keep available and up-to-date records of the quantities imported and the customers sold to. The non-EU manufacturer must inform the importers in its supply chain of the appointment. And once informed, those importers are treated as downstream users and relieved of the registration duty (Article 8(2)-(3)).
One nuance for article exporters: Article 7(1) requires registration by a producer or importer of articles only where the substance is present above 1 tonne/year AND is intended to be released under normal or reasonably foreseeable conditions of use. Think scented erasers or perfumed products, where releasing the substance is the point. Most garments, bags and jewellery never trigger it, because nothing is intended to be released.
| Scenario | Who registers | Legal basis | Cost sits with |
|---|---|---|---|
| Indian firm exports dye/chemical mixtures, EU importer imports ≥1 t/yr | The EU importer | Art 6(1) | Importer |
| Indian manufacturer appoints an Only Representative | The OR (importers become downstream users) | Art 8(1)-(3) | Indian manufacturer (via OR fees) |
| Indian firm exports articles with intended release of a substance ≥1 t/yr | EU importer of the articles (or OR) | Art 7(1) | Importer / manufacturer |
| Indian firm exports ordinary articles (garments, bags, jewellery), no intended release | Nobody registers. But Art 7(2)/33 SVHC duties and Annex XVII still apply | Art 7(3), Art 33 | n/a |
When is appointing an Only Representative worth it for an Indian exporter?
This is a commercial decision, not a legal one. The law gives you the option, and the economics decide it. An OR makes sense in three situations.
You sell the same substance or mixture to multiple EU importers. One registration via the OR replaces a registration by each importer. And, just as importantly, your formulation data goes into the OR's dossier rather than into your buyers' hands.
Your importers are small and refuse the registration burden. A small distributor faced with a REACH registration will often simply not buy. Appointing an OR removes their duty entirely (they become downstream users) and makes you an easier supplier to say yes to.
You want to control the dossier and confidential business information. The party that registers controls what is disclosed. An OR keeps that control on your side of the relationship.
And the situation where an OR is pointless: you only export ordinary articles with no intended release. There is nothing to register, so there is nothing for an OR to do. Do not pay for one.
The practicalities come straight from Article 8: appointment is by mutual agreement; the OR must be established in the EU with a sufficient background in the practical handling of substances; and you must notify the importers in your chain so they take downstream-user status. Note honestly: ECHA's practical OR guidance pages could not be verified for this update, so operational details (fees, typical contract terms) should be confirmed directly with the OR provider you engage.
What are your SVHC duties when a Candidate List substance is in your product?
Two distinct duties get conflated here, and separating them saves a lot of confusion in buyer questionnaires.
Duty one: Article 7(2) notification to ECHA. This is triggered only when a Candidate List (SVHC) substance is present in articles above 0.1% w/w and the producer or importer's total of that substance across its articles exceeds 1 tonne/year. The duty sits on the EU importer, not on you. There is an exemption where the producer or importer can exclude exposure to humans or the environment during normal use and disposal (Article 7(3)), and the information the notification must contain is listed in Article 7(4).
Duty two: Article 33 communication. This is triggered at any tonnage , the moment an SVHC exceeds 0.1% w/w in an article. Every supplier in the chain must give the recipient sufficient information for safe use (at minimum the name of the substance) and must answer a consumer's request for that information free of charge within 45 days (Article 33(1)-(2)). One shipment is enough.
The 0.1% threshold is weight-for-weight, per article as supplied. Not per shipment, not per material batch. And the practical consequence for the Indian exporter is simple: your EU buyer will demand an SVHC declaration per shipment or per SKU, screened against the current Candidate List. The list is updated roughly twice a year, and the current substance count was not verified for this page. Always check ECHA's live list before issuing a declaration.
One item to treat as unverified rather than asserted: buyers may also reference the SCIP database notification duty under the Waste Framework Directive. The primary source for that duty was not confirmed in this research run, so if a buyer raises SCIP, confirm the requirement with them directly rather than assuming its scope from this page.
Which Annex XVII restrictions hit textile exports. Azo dyes today, PFAS from October 2026?
Two restrictions dominate for apparel and home-textile exporters: one that has been live for years, and one whose deadline is now months away.
Azo dyes (entry 43). Azodyes that can release any of the Appendix 8 aromatic amines above 30 mg/kg (0.003% w/w) must not be used in textile and leather articles that may come into direct and prolonged contact with skin or the oral cavity. The entry's scope covers clothing, bedding, footwear, gloves, watch straps, handbags, textile toys, and yarn or fabric sold to final consumers. Non-conforming articles cannot be placed on the market. The trap: a dyer's verbal assurance is not compliance. The restriction bites on the finished dyed article, so without test reports on that article the exporter has no defence when a marketplace or a market surveillance authority asks.
PFHxA / PFAS (entry 79, inserted by Regulation (EU) 2024/2462). From 10 October 2026, PFHxA, its salts and PFHxA-related substances are banned at or above 25 ppb (sum of PFHxA and its salts) and 1,000 ppb (sum of PFHxA-related substances) in homogeneous material in textiles, leather, furs and hides in consumer clothing and related accessories, and in consumer footwear. From 10 October 2027 the limits extend to other consumer textiles. The planning point is blunt: stock with old water-repellent finishes placed on the market after 10 October 2026 is unsellable. Order PFHxA-free finishes and test now, not after the date. Separately, C9-C14 PFCAs (entry 68) have already been restricted since 25 February 2023.
| Restriction | Limit | Articles caught | In force |
|---|---|---|---|
| Azo dyes (entry 43) | 30 mg/kg releasable Appendix 8 amines | Textile/leather articles with prolonged skin or oral contact | Now |
| PFHxA + salts (entry 79) | 25 ppb in homogeneous material | Consumer clothing, related accessories, footwear | 10 Oct 2026 |
| PFHxA-related substances (entry 79) | 1,000 ppb in homogeneous material | Same; other consumer textiles follow 10 Oct 2027 | 10 Oct 2026 / 2027 |
| C9-C14 PFCAs (entry 68) | Entry-specific limits | Substances, mixtures and articles | Since 25 Feb 2023 |
What must leather exporters test for. And why is chromium VI the dealbreaker?
Chromium VI (entry 47, paragraphs 5-6). Leather articles, and articles containing leather parts , coming into contact with the skin must not be placed on the EU market if the leather contains chromium VI at or above 3 mg/kg (0.0003% of the total dry weight of the leather).
This is the highest-risk limit for Indian tanneries for a chemical reason: chromium VI forms after tanning, through oxidation of the trivalent chrome used in the tanning process. A passing test on wet-blue does not guarantee a passing test on the finished article. Heat, UV exposure and alkaline conditions during finishing, storage and transit can all convert CrIII to CrVI. Test the finished article, and consider ageing tests, because a bag that passed at dispatch can fail after six weeks in a container.
Three other restrictions travel with leather goods. Azo dyes (entry 43) apply equally to dyed leather. The limits and scope are covered in the textile section above . PFHxA (entry 79) explicitly covers leather, furs and hides in consumer clothing, accessories and footwear from 10 October 2026. Leather footwear exporters are squarely caught. And nickel (entry 27) catches the metal fittings on leather goods. Buckles, rivets and zips on watch straps and bags in prolonged skin contact. Covered in the jewellery section below .
What a serious EU importer will ask for, per shipment: per-lot chromium VI test reports on the finished leather, azo-amine reports on dyed components, and an SVHC declaration. Build that pack once and it becomes routine. Note also that cattle-derived leather faces a separate EU regime on deforestation-free supply chains (see our EUDR guide) which is out of this page's scope.
Which limits apply to jewellery. Lead, cadmium and nickel release?
Lead (entry 63, paragraphs 1-5 and 7). Lead and its compounds must not be used in, or placed on the market in, ANY individual part of jewellery articles at or above 0.05% by weight. The scope is wide: jewellery, imitation jewellery, hair accessories, bracelets, necklaces, rings, piercing jewellery, wrist watches and wrist-wear, brooches and cufflinks. There are derogations for crystal glass, inaccessible internal components of watches, non-synthetic and reconstructed precious and semiprecious stones (unless treated with lead), and vitreous enamels. Entry 63 also restricts lead at 0.05% in articles supplied to the general public that can be mouthed by children. Kill the "plated is fine" myth here: the limit applies to every individual part. Including solder, clasps and components sold for jewellery-making. A compliant pendant on a non-compliant solder joint is a non-compliant article.
Nickel (entry 27, paragraphs 1-3). Post assemblies inserted into pierced ears or other pierced body parts must have a nickel release rate below 0.2 µg/cm²/week. Articles in direct and prolonged contact with the skin (earrings, necklaces, bracelets and chains, rings, watch cases and straps, and rivets, zippers and buttons used in garments) must not release more than 0.5 µg/cm²/week. And where a coating is used to hold the limit, it must do so for at least two years of normal use. Which is why plating thickness matters commercially, and why CEN standards are the reference test methods for demonstrating conformity.
Cadmium (entry 23). The verified paragraph: mixtures and articles produced from listed plastics (PVC, PUR, LDPE, PET, PP and others) must not be placed on the market if the cadmium concentration is equal to or greater than 0.01% by weight of the plastic. Entry 23's later paragraphs also restrict cadmium in metal jewellery, paints and brazing fillers. But the specific jewellery-metal limit was not verified in this research run, so it is deliberately not printed here: check the live entry text before relying on a figure.
As an unharmonised consumer product, jewellery also needs a GPSR Responsible Person in the EU. See our GPSR guide for that role.
| Substance | Limit | Scope | Entry |
|---|---|---|---|
| Lead | <0.05% w/w in any individual part | Jewellery, imitation jewellery, hair accessories, watches, brooches, cufflinks | Annex XVII entry 63 |
| Nickel (piercing posts) | <0.2 µg/cm²/week release | Post assemblies in pierced ears/body parts | Annex XVII entry 27 |
| Nickel (skin contact) | ≤0.5 µg/cm²/week release, held ≥2 years for coatings | Earrings, necklaces, rings, watch cases/straps, garment rivets/zips/buttons | Annex XVII entry 27 |
| Cadmium (plastics) | <0.01% w/w of the plastic | Articles from PVC, PUR, LDPE, PET, PP etc. | Annex XVII entry 23 para 1 |
What is your REACH checklist before the next EU shipment?
Three blocks: settle scope and registration once, run SVHC and restriction checks per SKU, and assemble the buyer pack per shipment.
Block A. Scope & registration
- Classify what you ship (substance/mixture versus article) for every export line
- If substances/mixtures reach ≥1 t/yr to any importer, confirm in writing who registers. The importer, or your Only Representative under Art 8
- If you appoint an OR, notify every EU importer in your chain so they take downstream-user status
- Check the Art 7(1) intended-release edge case for articles (scented or substance-releasing products)
Block B. SVHC & restrictions
- Screen each SKU's bill of materials against the CURRENT ECHA Candidate List (it updates roughly twice a year)
- Where any SVHC exceeds 0.1% w/w, prepare the Art 33 safe-use information (minimum: the substance name) and keep it ready for the 45-day consumer-request clock
- Run category tests. Azo amines ≤30 mg/kg on dyed textiles/leather, CrVI <3 mg/kg on finished leather, lead <0.05% on every jewellery part, nickel release on skin-contact metal, and PFHxA before the 10 Oct 2026 date for clothing/accessories/footwear
- Keep dated accredited-lab reports per lot/SKU on file
Block C. Buyer pack
- Send the SVHC declaration, test reports and OR mandate copy (if any) with the commercial documents
- Do not conflate roles. Confirm separately who acts as the GPSR Responsible Person for consumer articles
- Diarise 10 Oct 2026 (PFHxA in clothing/footwear) and 10 Oct 2027 (other consumer textiles)
REACH is one layer of the EU stack. If your goods are in CBAM scope, see the CBAM guide for Indian exporters ; for preferential and non-preferential origin evidence, see proof of origin by regime ; and for the general document stack, the export documentation guide .
Arjun Leathers, Kanpur, exports chrome-tanned leather handbags with nickel-plated brass fittings and a water-repellent finished leather travel-accessories line to a German importer. A new order is confirmed in September 2026 for delivery landing in Hamburg in November 2026. The importer's compliance team sends a REACH questionnaire before releasing the PO. </> } result= >
| Step | What happens | Outcome |
|---|---|---|
| 1. Registration | The bags are articles with no intended release of any substance, so Article 7(1) registration is not triggered; Article 6(1) registration sits with EU importers of substances, not with Arjun. | Nothing to register, no Only Representative needed (Arjun exports no chemicals). |
| 2. SVHC screen | The BOM (leather, dyes, PU coating, brass fittings) is screened against the current ECHA Candidate List; a plasticiser in the PU trim tests at 0.04% w/w. Below 0.1%. | No Article 33 duty and no Article 7(2) notification for the importer, but Arjun issues a dated SVHC declaration anyway because the questionnaire demands it. |
| 3. Annex XVII tests | Chromium VI on finished leather: 1.8 mg/kg (limit: below 3 mg/kg, entry 47. Pass, retested after ageing because CrVI can form post-tanning). Azo-amine testing on dyed leather: all Appendix 8 amines under 30 mg/kg (entry 43. Pass). Nickel release on plated fittings: 0.3 µg/cm²/week. Under the 0.5 µg/cm²/week skin-contact limit of entry 27, with plating specified to hold it for two years. | Handbag line passes all applicable entries. |
| 4. The date trap | The travel-accessories line uses an old C6-chemistry water-repellent finish. The goods will be placed on the EU market in November 2026 (after 10 October 2026) so entry 79's PFHxA limits (25 ppb / 1,000 ppb in homogeneous material) apply to leather accessories for the general public. | Lab results show the finish exceeds 1,000 ppb PFHxA-related substances. Fail. |
| 5. Fix and buyer pack | Arjun switches to a PFHxA-free finish for this order, re-tests, and sends the importer: SVHC declaration, CrVI and azo reports per lot, nickel-release certificate for the fittings, and PFHxA test results. Plus a note that the GPSR Responsible Person named on the packaging is the importer itself, a separate role from anything under REACH. | Questionnaire cleared; PO released. |
Frequently asked questions
Do Indian garment or jewellery exporters need to register with ECHA under REACH?
No. Under Article 6(1) of Regulation (EC) No 1907/2006, the registration duty for substances at 1 tonne/year or more sits on the EU manufacturer or importer, never on the non-EU exporter. Articles like garments and jewellery only trigger registration under Article 7(1) where a substance is intended to be released under normal use and exceeds 1 tonne/year, which ordinary garments, bags and jewellery do not. However, Article 33 SVHC communication duties and the Annex XVII restrictions (azo dyes, chromium VI, lead, nickel, PFHxA) still apply to the articles themselves at any tonnage, so exporters must test and supply evidence even though they never register.
What is the difference between a REACH Only Representative and a GPSR Responsible Person?
They are two entirely separate roles under two different regulations. A REACH Only Representative is appointed under Article 8 of Regulation (EC) No 1907/2006 by a non-EU manufacturer to fulfil the chemical registration obligations of its EU importers. Its mandate covers chemical registration only. A GPSR Responsible Person is the EU-established economic operator required under Article 16 of Regulation (EU) 2023/988 for all consumer products since 13 December 2024, responsible for product safety tasks. An OR mandate does not satisfy the GPSR requirement, and vice versa, unless the same entity is separately mandated for each role.
What must I do if my article contains a Candidate List SVHC above 0.1%?
Article 33 of REACH is triggered at any tonnage the moment a Candidate List SVHC exceeds 0.1% weight-for-weight in an article. Every supplier in the chain must give the recipient sufficient information for safe use (at minimum the name of the substance) and must answer a consumer's request for that information free of charge within 45 days. Separately, if the producer or importer's total of that substance also exceeds 1 tonne/year, the EU importer must notify ECHA under Article 7(2) unless exposure can be excluded. In practice your EU buyer will demand a tested, dated SVHC declaration per shipment or per SKU.
When does the PFHxA (PFAS) restriction start applying to clothing and footwear sold in the EU?
From 10 October 2026. REACH Annex XVII entry 79, inserted by Commission Regulation (EU) 2024/2462, bans PFHxA, its salts and PFHxA-related substances at or above 25 ppb (sum of PFHxA and its salts) and 1,000 ppb (sum of PFHxA-related substances) in homogeneous material in consumer clothing, related accessories and footwear. From 10 October 2027 the limits extend to other consumer textiles. Stock carrying old C6-chemistry water-repellent finishes cannot lawfully be placed on the EU market after the applicable date, so Indian textile, leather and footwear exporters should switch finishes and test now.
Is my dye supplier's declaration enough to prove azo-dye compliance under REACH?
No. Annex XVII entry 43 restricts the finished dyed article. Textile and leather articles in direct and prolonged contact with skin or the oral cavity must not release any Appendix 8 aromatic amine above 30 mg/kg. A dyer's verbal or written assurance about the dyestuff does not prove what the finished article releases, and it gives you no defence when a marketplace or market surveillance authority tests the article itself. The safe evidence is an accredited-laboratory test report on the finished dyed article, per lot, kept dated and on file.
Sources & citations
- [Regulation (EC) No 1907/2006 (REACH), consolidated text. EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02006R1907-20260511).
- [Regulation (EU) 2023/988 (General Product Safety Regulation). EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R0988).
- [Regulation (EU) 2019/1020 (Market Surveillance). EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020).
Update history
- First published.