CHEMICALS GUIDE
REACH Entry 72: The Chemical Limits Already in Force for Clothing, Textiles and Footwear
REACH Annex XVII Entry 72 is not a proposal, and it is not a future Digital Product Passport requirement. It is law that has applied since 1 November 2020, and the consolidated text of REACH (22 June 2026) shows it exactly as adopted in 2018. It caps 33 substances or substance groups classified as carcinogenic, mutagenic or toxic for reproduction (CMR, category 1A or 1B) in clothing, related accessories, skin-contact textiles and footwear for use by consumers.
This guide covers what Entry 72 covers and exempts, the limits substance by substance, who it reaches under REACH's definition of "placing on the market", four neighbouring REACH entries that also apply to garments, and how Entry 72 relates to ESPR's substances-of-concern rules. For the PFAS side of the same topic, see our PFAS guide.
1 Nov 2020
The date from which Entry 72 bars the listed CMR substances at or above their Appendix 12 limits in consumer clothing, skin-contact textiles and footwear (Commission Regulation (EU) 2018/1513). REACH's consolidated text of 22 June 2026 still shows it as adopted.
33 entries
Appendix 12 lists 33 substances or substance groups, with limits from 1 mg/kg (the four metal groups after extraction, PAHs, chlorinated toluenes) up to 3,000 mg/kg (three solvents).
Import counts
REACH defines placing on the market as supplying or making available to a third party, free of charge or not — and deems import to be placing on the market.
1. What Entry 72 is
Entry 72 was added to Annex XVII of the REACH Regulation (Regulation (EC) No 1907/2006) by Commission Regulation (EU) 2018/1513 of 10 October 2018, using the simplified procedure in Article 68(2) REACH. The Commission's recitals explain the choice: it had developed criteria for identifying articles that contain CMR substances and could be used by consumers, and "clothing, other textiles and footwear are considered a priority case" (recital 2). "CMR substances" here means substances classified as carcinogenic, mutagenic or toxic for reproduction in category 1A or 1B under the CLP Regulation (recital 1).
Why they matter in garments: the Commission notes that certain CMR substances are present in clothing and related accessories, other textiles and footwear "either as impurities from the production process or because they have been added intentionally to give them specific properties" (recital 3), and that consumers can be exposed "through contact with the skin or through inhalation" (recital 4).
The restriction applies from 1 November 2020: the Commission's recital 11 speaks of a restriction that "should therefore only apply from a specified date", and the entry's own wording is "after 1 November 2020". Entry 72 and its Appendix 12 appear in REACH's consolidated text of 22 June 2026 (the version read for this guide) exactly as adopted in 2018: the consolidated text marks both with the 2018 Regulation as the only amending act. The operative rule, in the Regulation's own words:
Entry 72, paragraph 1 — Annex XVII to Regulation (EC) No 1907/2006
"Shall not be placed on the market after 1 November 2020 in any of the following: (a) clothing or related accessories; (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; (c) footwear; if the clothing, related accessory, textile other than clothing or footwear is for use by consumers and the substance is present in a concentration, measured in homogeneous material, equal to or greater than that specified for that substance in Appendix 12."
2. What it covers — and what it exempts
Entry 72 applies to three product groups: clothing or related accessories; textiles other than clothing that, "under normal or reasonably foreseeable conditions of use, come into contact with human skin to an extent similar to clothing"; and footwear. It applies only where the article "is for use by consumers" and a listed substance is present "in a concentration, measured in homogeneous material, equal to or greater than" its Appendix 12 limit. The Commission's recitals give examples: sportswear and bags among the clothing and related accessories covered; bedlinen, blankets, upholstery or reusable nappies among skin-contact textiles; and consumer use includes use within a service to the general public, such as bedlinen in a hospital or upholstery in a public library (recital 4).
Paragraphs 3 to 5 of Entry 72 then list what it does not apply to:
| Exempt | Where | Note |
|---|---|---|
| Clothing, related accessories or footwear — or parts of them — made exclusively of natural leather, fur or hide | Paragraph 3(a) | The Commission's reason (recital 7): different substances and processes are used in their production. Chromium VI in leather has its own rule — see Entry 47 below. |
| Non-textile fasteners and non-textile decorative attachments | Paragraph 3(b) | Also covered by recital 7. |
| Second-hand clothing, related accessories, textiles other than clothing or footwear | Paragraph 3(c) | Other REACH entries treat second-hand articles differently (see the FAQ). |
| Wall-to-wall carpets and textile floor coverings for indoor use, rugs and runners | Paragraph 3(d) | Exempted "for the time being" (recital 8); paragraph 7 requires the Commission to review the exemption. |
| Items within the scope of the Personal Protective Equipment Regulation (EU) 2016/425 or the Medical Devices Regulation (EU) 2017/745 | Paragraph 4 | Recital 9: such equipment and devices must meet specific safety and functionality requirements. |
| Disposable textiles — but only as regards textiles other than clothing (paragraph 1(b)) | Paragraph 5 | Defined as textiles designed to be used only once or for a limited time and not intended for subsequent use for the same or a similar purpose. |
Two further points from the text. Under paragraph 6, Entry 72 applies "without prejudice to the application of any stricter restrictions set out in this Annex or in other applicable Union legislation" — it is a floor, not a safe harbour. And under paragraph 2, formaldehyde in jackets, coats or upholstery had a temporary, less strict limit of 300 mg/kg between 1 November 2020 and 1 November 2023; since then the Appendix 12 limit applies to them too.
3. The limits, substance by substance
Appendix 12 is headed "restricted substances and maximum concentration limits by weight in homogeneous materials". Grouped by type, its 33 entries are:
| Substances | Limit in Appendix 12 | Note |
|---|---|---|
| Cadmium and its compounds; chromium VI compounds; arsenic compounds; lead and its compounds (in each case those listed in Annex XVII Entries 28, 29 and 30, Appendices 1–6) | 1 mg/kg after extraction | Expressed as the metal (or as Cr VI) that can be extracted from the material. Which compounds count follows the lists in Entries 28–30, which are amended from time to time — for example by Commission Regulation (EU) 2025/1731 of 8 August 2025, which added substances to Appendices 2, 4 and 6 (and a derogation to Appendix 11) but did not touch Entry 72 or Appendix 12. None of the added substances is a compound of cadmium, chromium VI, arsenic or lead. |
| Benzene | 5 mg/kg | |
| Eight polycyclic aromatic hydrocarbons (PAHs): benz[a]anthracene, benz[e]acephenanthrylene, benzo[a]pyrene, benzo[e]pyrene, benzo[j]fluoranthene, benzo[k]fluoranthene, chrysene, dibenz[a,h]anthracene | 1 mg/kg | Per substance. |
| Three chlorinated toluenes: p-chlorobenzotrichloride, benzotrichloride, benzyl chloride | 1 mg/kg | Per substance. |
| Formaldehyde | 75 mg/kg | Jackets, coats and upholstery: 300 mg/kg until 1 November 2023. |
| Five phthalates: di-C6-8-branched alkyl esters (C7-rich), bis(2-methoxyethyl) phthalate, diisopentyl phthalate, di-n-pentyl phthalate, di-n-hexyl phthalate | 1,000 mg/kg | Individually or in combination with other phthalates in this entry or in other Annex XVII entries that are classified in Part 3 of Annex VI to the CLP Regulation in any of the hazard classes carcinogenicity, germ cell mutagenicity or reproductive toxicity, category 1A or 1B. |
| Three solvents: N-methyl-2-pyrrolidone (NMP), N,N-dimethylacetamide (DMAC), N,N-dimethylformamide (DMF) | 3,000 mg/kg | Per substance. |
| Three dyes: C.I. Disperse Blue 1, C.I. Basic Red 9, C.I. Basic Violet 3 (with ≥ 0.1 % of Michler's ketone) | 50 mg/kg | Per substance. |
| Four aromatic amine salts: 4-chloro-o-toluidinium chloride, 2-naphthylammonium acetate, 2,4-diaminoanisole sulphate, 2,4,5-trimethylaniline hydrochloride | 30 mg/kg | Per substance. |
| Quinoline | 50 mg/kg |
The entry names no test method. That is a difference from Entry 43 on azo dyes, which points to the test methods in its Appendix 10, and from Entry 27 on nickel, which points to CEN standards. The Commission's recital 6 says the limits were set "taking into account the technical feasibility of achieving those limits and the availability of appropriate analytical methods", and that the substances "are used in different processes in the clothing and related accessories, textile and footwear industries"; for formaldehyde it notes use in jackets and coats (structural properties) and in upholstery (flame retardancy).
DPP AUDIT
The supplier records behind Entry 72 are the kind of records a passport would draw on.
Test reports, material declarations and product-to-supplier mapping serve REACH compliance today and are the raw material for any substance disclosure ESPR later requires. We help you build that data once, correctly. Under NDA.
Start Your DPP Audit4. Who it reaches: "placing on the market"
Entry 72 is a restriction on supply, not a certification scheme or a documentation duty. Under Article 67(1) REACH, a substance in an article for which Annex XVII contains a restriction "shall not be manufactured, placed on the market or used unless it complies with the conditions of that restriction", and Entry 72's own wording is "Shall not be placed on the market". REACH defines that act broadly:
Article 3(12), Regulation (EC) No 1907/2006 (REACH)
"placing on the market: means supplying or making available, whether in return for payment or free of charge, to a third party. Import shall be deemed to be placing on the market"
On the text's own terms, supplying a garment to a third party — even free of charge — is placing it on the market, and so is importing it. The prohibition attaches to that act rather than to a particular role: a brand importing finished garments, a wholesaler and a retailer who supplies a garment to a customer each perform it. On the wording, the relevant date is when the article is supplied or imported, not when it was made: the restriction is framed as "shall not be placed on the market after 1 November 2020".
Enforcement sits with the Member States. Article 125 requires them to "maintain a system of official controls", and Article 126 leaves penalties to national law, which must be "effective, proportionate and dissuasive". This guide does not map national penalty regimes.
5. Four neighbouring REACH entries
Entry 72 is not the only REACH restriction that bites on garments. Four others — each with its own limits, scope and exemptions — are worth knowing alongside it. This is not a complete list of what applies to a garment:
| Entry | What it limits | Scope and key limit |
|---|---|---|
| Entry 43 | Azo dyes that can release listed aromatic amines | Above 30 mg/kg (0.003 % by weight) of the listed aromatic amines that the dyes can release, measured in the article or in its dyed parts, in textile and leather articles that may come into direct and prolonged contact with the skin or oral cavity — clothing, bedding, towels, footwear, gloves, handbags, yarn and fabrics for consumers and similar. Test methods are listed in the entry's Appendix 10. |
| Entry 46a | Nonylphenol ethoxylates (NPE) | At or above 0.01 % by weight of the textile article or of each part, in textile articles (defined as products, or products with a part, of at least 80 % textile fibres by weight) that can reasonably be expected to be washed in water during their normal lifecycle; applies to placing on the market after 3 February 2021. Not applied to second-hand textile articles or to new articles made without NPE exclusively from recycled textiles. |
| Entry 47 (paragraphs 5–7) | Chromium VI in leather | Leather articles coming into contact with the skin, and articles with leather parts in skin contact: not to be placed on the market at 3 mg/kg (0.0003 % by weight) of dry leather weight or more. Second-hand articles in end-use in the Union before 1 May 2015 are exempt. Our footwear guide covers the footwear side. |
| Entry 27 | Nickel | Nickel release above 0.5 µg/cm²/week from parts in direct and prolonged skin contact, including rivet buttons, tighteners, rivets, zippers and metal marks used in garments; for coated parts, the coating must keep release below that limit for at least two years of normal use. CEN standards are the test methods. |
The REACH restriction on PFHxA, a PFAS substance, is a separate entry (Annex XVII Entry 79): from 10 October 2026, PFHxA, its salts and PFHxA-related substances at or above the limits set there may not be placed on the market or used in textiles, leather, furs and hides in clothing and related accessories for the general public, or in footwear for the general public; other textiles, leather, furs and hides for the general public follow from 10 October 2027. The entry does not apply to articles placed on the market before the respective date, and it has further exemptions, for example for certain personal protective equipment, medical devices and construction textiles. It is covered in our PFAS guide. Entry 72's paragraph 6 makes the relationship explicit: where another entry is stricter, it applies in addition.
6. How Entry 72 connects to the DPP
Entry 72 does not depend on the Digital Product Passport. It applies today, whether or not a textile delegated act or passport exists, and it contains no documentation or declaration duty of its own.
The link is through substance data. ESPR defines a "substance of concern" (Article 2(27)) to include substances classified in Part 3 of Annex VI to the CLP Regulation in listed hazard classes — among them "carcinogenicity categories 1 and 2", "germ cell mutagenicity categories 1 and 2" and "reproductive toxicity categories 1 and 2", the same three CMR hazard classes Entry 72 is built on (Entry 72 names categories 1A and 1B; ESPR lists categories 1 and 2). Appendix 12 identifies most of its substances by their CLP Annex VI index numbers. So much of what Entry 72 forces you to keep out of garments sits inside the category that ESPR's substance rules are written around.
What the textile passport will actually have to say about substances is not decided. No adoption date has been fixed for the textile (apparel) delegated act. The Commission's first ESPR Working Plan (April 2025) gives 2027 as the indicative year; its Digital Product Passport pages list adoption for Q3–Q4 2027 (DPP timeline, together with aluminium and tyres) and for Q4 2027 (textile-apparel page), both marked indicative. Our substances-of-concern guide explains what ESPR's definition and information rules do and do not require. What you can do today is treat supplier test reports and material declarations as one record: they serve Entry 72 now and are the raw material for any substance disclosure later.
7. What to do now
Map your range against the scope: consumer clothing and accessories, footwear, and non-clothing textiles in skin contact — including home textiles such as bedlinen and upholstery — unless an exemption applies. Read "made exclusively of natural leather, fur or hide" narrowly: in a mixed article, the textile parts stay in scope.
Ask suppliers for test evidence against the Appendix 12 list, in the unit and on the basis the entry uses (mg/kg; the four metal groups "after extraction"; "homogeneous material"). Because Entry 72 names no test method, agree the laboratory method in your supplier terms — that is practice, not something the Regulation prescribes.
Check the neighbouring entries too — azo dyes, NPE, chromium VI in leather and nickel in metal trims — and keep second-hand and new stock apart: on the ordinary meaning of "second-hand" (REACH does not define it), the exemption covers used articles, not unsold new stock. For resale models see our second-hand guide.
Frequently asked questions
Does Entry 72 cover accessories such as bags?
Does a jacket with leather trim fall under Entry 72?
Are second-hand and vintage garments covered?
Who enforces Entry 72, and what are the penalties?
Do I have to put Entry 72 test results into the Digital Product Passport?
Sources
- REACH Entry 72 — the adopting actCommission Regulation (EU) 2018/1513 of 10 October 2018 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards certain substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR), category 1A or 1B. Recitals 1–4, 6–9 and 11; Annex (Entry 72 and Appendix 12). CELEX 32018R1513 ↗
- REACH — consolidated textRegulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC — consolidated version of 22 June 2026, which is the text read here. Article 3(10)–(12); Article 67(1); Articles 125–126; Annex XVII Entries 27, 43, 46a, 47, 72 and 79; Appendix 12. CELEX 02006R1907-20260622 (consolidated) ↗
- REACH Entries 28–30 — the lists the metal rows point toCommission Regulation (EU) 2025/1731 of 8 August 2025 amending Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards carcinogens, germ cell mutagens or reproductive toxicants subject to restrictions. Annex (additions to Appendices 2, 4 and 6, and to Appendix 11, of Annex XVII). CELEX 32025R1731 ↗
- ESPR — substance of concernRegulation (EU) 2024/1781 of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC. Article 2(27) (definition of "substance of concern"). See our substances-of-concern guide for what follows from it. CELEX 32024R1781 ↗
- Commission — textile delegated act timelineCommunication from the Commission, Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187 final of 16 April 2025 (indicative timeline for adoption, textiles/apparel: 2027); European Commission, Digital Product Passport page, DPP timeline (adoption of the ESPR delegated acts for textiles, aluminium and tyres: Q3–Q4 2027); European Commission, "Textile Apparel and the Digital Product Passport (DPP)" page — indicative timeline entry "Q4 2027: Planned adoption of the ESPR Delegated Act for textiles". Both Commission timelines are marked indicative. CELEX 52025DC0187 ↗ · DPP page ↗ · textile-apparel page ↗
Regulations (EU) 2018/1513 and (EU) 2025/1731 and ESPR were read in the Official Journal versions published by the EU Publications Office (EUR-Lex); REACH was read in its consolidated version of 22 June 2026, a documentation tool without legal effect, the authentic text being the Official Journal; the European Commission textile-apparel page was accessed on 02.10.2026; that page, the Commission's Digital Product Passport page and the Working Plan (COM(2025) 187 final) were accessed on 13.10.2026. This is general information, not legal, financial or investment advice.