EU: Restrictions on CMRs 1A and 1B in Textiles and Clothing, Guidance Document, June 2018

“The purpose of this explanatory guide is to clarify the scope of the articles intended to be covered by the Commission Regulation Commission Regulation (EU) 2018/1513 of 10 October 2018 amending Annex XVII to REACH Regulation as regards certain substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR) category 1A or 1B (entry 72 of REACH, Annex XVII).

The list of articles below is not exhaustive but aims to give illustrate examples of products available for use by consumers that are considered as being covered by the restriction, in particular by paragraph 1(a) clothing and related accessories, and paragraph 1(b) textiles other than clothing which, under normal or reasonably foreseeable conditions of use, come into contact with human skin to an extent similar to clothing.

The restriction covers products of the categories in paragraphs 1(a) – 1(c) that consumers acquire themselves, but also products they use in a private capacity or when using a product within the context of a service provided to the general public (e.g. bed linen in a hospital or upholstery in a public library).

For deciding whether other articles not listed below are to be interpreted as being covered (point 1 below), or not covered (point 2 below), by the restriction, a case-by-case assessment is necessary.

Such a case-by-case assessment is to be undertaken considering the wording of the restriction; the examples given can provide useful elements for this assessment.

With regards to concentration limits in Appendix 12, where different concentration limits are set in other entries in Annex XVII to REACH or in other EU legislation, the stricter limits always apply. This refers, amongst other, to the limits set in entry 50 on Polycyclic-aromatic hydrocarbons (PAH) and in the Toy Safety Directive 2009/48/EC.

Finally, in point 3, this guide also provides for a list of available analytical methods in certain matrixes that can be used for the determination of the different substances. It is suggested to use the most performant method. The list is not exhaustive and some of the methods might require some adaptations depending on the matrix.”

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