REACH Compliance for Bags: What Substances Are Restricted?

What Kind of Instrument Is REACH and Why Does That Matter?

REACH is a regulation of the European Union on the registration, evaluation, authorisation and restriction of chemicals. It is not a product standard and it is not a quality mark, which is why there is no such thing as a REACH certificate for a bag. What exists instead is a body of obligations that attach to substances, to mixtures and to articles, and a set of documents that evidence them.

The distinction matters commercially because suppliers are asked for "REACH compliance" as though it were a single test. It is not. It is a set of separate duties with separate triggers, and a supplier can be fully in line with one of them and silent on another. The buyer has to know which duty applies to which substance in which component, because the answer differs by construction.

Does REACH Apply to a Bag Made Outside the European Union?

Yes, through the importer. A manufacturer outside the European Union does not carry the registration and article duties directly; the legal entity that places the article on the European Union market does. That entity is normally your importer of record, or your own European Union establishment if you have one. This is why the question "is your supplier REACH compliant" is the wrong question, and "what evidence will my importer need" is the right one.

Practically, it means the documentation has to be capable of being handed to a European Union entity and defended there. A declaration written by a mill in Asia that nobody in the European Union has reviewed does not discharge an importer's duty. The importer has to be able to show that the article meets the restrictions that apply to it, and that means holding evidence tied to the article rather than to the mill.

What Is the Difference Between a Restriction, an Authorisation and a Candidate-List Duty?

A restriction says a substance may not be present above a stated limit in the uses covered, or may not be used at all. An authorisation says a listed substance may only be placed on the market if an authorisation has been granted for that use. The candidate-list duty says that if an article contains a substance on the candidate list above the stated threshold, information has to be communicated to the recipient, and in some cases notified. Three duties, three triggers, three different documents.

Which Substance Families Actually Matter for Soft Goods?

Bags are assemblies of coated textile, foam, trim, metal hardware and print, and each layer has its own chemistry. In practice the families that a bag programme has to think about are those used in dyeing, in coating and finishing, in plasticising flexible polymers, in metal finishing and plated hardware, and in flame retardancy and water repellency where those finishes are specified. Which of them is restricted, and for which use, is a question answered by the restriction list rather than by the material name.

How Do You Work Out Which Restrictions Apply to Your Construction?

By reading the restriction against the use, not against the material name. Restrictions are written with conditions: a substance, a concentration, and the articles or uses it is restricted in. Some apply to all articles, some only to articles that contact skin, some only to textiles, some only to children's articles. The same substance can be restricted in one use and unrestricted in another, so a generic "contains no restricted substances" declaration carries no information.

The way through it is a bill of materials with a named chemistry per component, then a check of each component against the current restriction list for the use it represents. That is a document exercise before it is a test exercise, and doing the document exercise first is what keeps the test scope and the test cost proportionate rather than testing everything for everything.

What Does the Candidate-List Threshold Mean in Practice?

There is a threshold, expressed as a percentage by weight of the article, above which a candidate-list substance has to be communicated to the recipient of the article. The threshold is set in the regulation and is commonly cited at a fraction of one percent by weight; confirm the current figure against the official text before you rely on it, because the candidate list itself is updated periodically and the article concerned changes with it.

The consequence for a bag programme is a recurring check rather than a one-off. Because the list is updated, a construction that was clear last season can fall inside a communication duty this season without anything about the bag having changed. The disciplined response is to re-screen the components of any style still in production when the list is updated, and to record the date of the list you checked against.

What Evidence Should an Importer Actually Hold?

Four things, held together and tied to the article. A bill of materials that names every component and its supplier. Declarations from each component supplier covering the substances that apply to that component. Laboratory reports on the components that carry the risk, issued by an accredited laboratory against a stated method. And a record of which version of the restriction list and the candidate list the position was checked against, with a date.

How Is the Testing Scoped Without Testing Everything?

By risk, by material and by duty. Start with the components that carry chemistry — dyed cloth, coated cloth, soft polymer trim, printed panels, plated hardware — and screen those. Leave components with no plausible chemistry to a declaration. Then narrow the substance list to what the restriction for that material and use actually covers, rather than ordering a screen against every substance in the regulation.

Two disciplines keep this proportionate. The first is to test the lot you will ship, or a sample drawn from it, rather than a "representative" sample from a different production run. The second is to record the detection limit on every result, because a report that says "not detected" without a detection limit cannot be compared against a threshold.

Where Do Buyers Most Often Get REACH Wrong?

Three places. The first is treating it as a certificate to be collected rather than a position to be built. The second is accepting a declaration that names no substances. The third is assuming a test report from a previous season still describes the current lot, when the dyehouse, the coating or the hardware source has changed and nothing in the file says so.

All three are documentation failures rather than chemistry failures, and all three cost little to prevent. Ask for named substances, ask for the lot the test was drawn from, and re-check the file whenever a component source changes. That is the whole discipline, and it is the same discipline that makes a reorder consistent with the order before it.

The reason to insist on this at specification stage rather than at delivery is that the correction is never merely administrative. If a report arrives naming no substances, the options are to commission a new screen and wait for it, or to ship without evidence. One of those costs calendar time at the end of a programme, when the shipping window and the retail submission date are already fixed and moving.

How Does REACH Fit With the Rest of the Compliance File?

It sits alongside rather than instead of the others. Restricted-substance screening under REACH answers whether the article may be placed on the European Union market. Product-specific rules answer different questions: toy safety where an article is also a toy, food-contact rules where an article is also a food-contact material, and electrical rules where an article contains electrics. A bag can be inside two regimes at once, and holding evidence for one does not answer the other.

It also sits alongside market-specific rules elsewhere. California operates its own listing and warning regime, and the United States operates its own children's product rules. A single test report can serve several masters if the substances and the limits overlap, but the decision about which regime applies is made by the market, not by the laboratory.

What Should You Write Into the Specification?

Name the components and the chemistry rather than naming the regulation. A clause that lists the restricted-substance standard you are buying to, the substance list you require screening against, the components that must be reported rather than declared, and the requirement that reports carry a method and a detection limit, gives a laboratory something it can act on and gives you something you can check.

Add the change-control sentence. Require notice before any dyehouse, coating, trim or hardware source changes, and require re-screening when it does. Without that sentence the file quietly becomes stale, and it becomes stale at exactly the moment a customer or an authority asks to see it.

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