Substances of concern are the part of the Digital Product Passport that most fashion brand owners skip over, either because the chemistry feels intimidating or because they assume their products are “just fabric” and don’t contain anything problematic. Both assumptions are risky.
Under the ESPR, the substances of concern disclosure in your DPP is not optional. And under the existing REACH regulation, you already have legal obligations around substances of very high concern (SVHCs) that many fashion brands are unknowingly failing to meet.
This article explains what substances of concern actually are in the textile context, what your DPP must disclose, how to get this data from your suppliers, and what happens if you get it wrong. No chemistry degree required.
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What “substances of concern” means for textiles
The term “substances of concern” sounds like it belongs in a chemical plant safety manual, not in a fashion brand’s product data. But textiles are chemical products. Every dye, every finish, every coating, every water-repellent treatment involves chemistry. And some of those chemicals are regulated because they pose risks to human health or the environment.
Under the ESPR framework, the definition of “substance of concern” is broad. It includes any substance that is identified as a substance of very high concern (SVHC) under the REACH regulation, classified for chronic human or environmental hazards under the EU’s CLP regulation, regulated under the Persistent Organic Pollutants (POPs) regulation, or known to negatively affect the reuse or recycling of materials in the product.
That last criterion is particularly relevant for fashion. A garment made from recyclable fibres that’s been treated with a chemical finish incompatible with textile recycling processes has a substance-of-concern issue, even if the chemical itself is legal. The ESPR cares not just about human safety but about circularity.
As of early 2026, more than 4,600 substances fall within the ESPR definition of substances of concern. The SVHC candidate list alone contains 253 entries and is updated roughly every six months. This is a moving target, which means your compliance posture needs ongoing monitoring, not a one-time check.
What your DPP must disclose
The exact data fields for substances of concern in the textile DPP will be confirmed in the delegated act, which is expected between late 2026 and mid-2027. But the ESPR framework already establishes the direction clearly.
Your DPP will need to declare whether the product contains any substances of concern above the relevant concentration thresholds. For SVHCs, the established threshold under REACH is 0.1% by weight of the article. Your passport should name the specific substances present (not just “contains SVHCs”, that’s not sufficient), identify where in the product they’re found (the fabric, a coating, a trim, a button), and provide information for safe use and end-of-life handling.
This is not a new obligation created by the DPP, REACH Article 33 already requires suppliers and brands to communicate SVHC information down the supply chain and to consumers upon request. The DPP simply makes this disclosure structured, digital, and proactively accessible rather than buried in a supplier declaration that nobody reads.
The practical implication: if you’re a fashion brand that has never checked whether your products contain SVHCs, you may already be non-compliant with REACH, and the DPP will make that gap visible.
Common substances of concern in fashion
You don’t need to become a chemist, but you should know where the risks are in your product category. Here are the most common substance-of-concern issues in fashion textiles.
PFAS (per- and polyfluoroalkyl substances). Used in water-repellent and stain-resistant finishes on outerwear, activewear, and some workwear. Several PFAS are already on the SVHC candidate list, and a broad restriction proposal covering virtually all PFAS is under review. If your products use DWR (durable water repellent) finishes, this is your highest-priority area.
Formaldehyde. Used in wrinkle-resistant and easy-care finishes. Classified as a carcinogen. Restricted under REACH Annex XVII for direct-skin-contact textiles at concentrations above 75 mg/kg. Common in non-iron shirts and some cotton blends.
Phthalates. Used as plasticisers in PVC-based prints, logos, and coated fabrics. Several phthalates are SVHCs. If your products include plastic prints or faux-leather components, check for phthalate content.
Azo dyes that release restricted amines. Certain azo dyes can release carcinogenic aromatic amines during normal use. These are restricted under REACH Annex XVII. Most reputable dye houses have eliminated them, but verification matters, especially with new or smaller suppliers.
Dimethylformamide (DMF). A solvent used in polyurethane coatings, particularly in footwear and accessories. Classified as toxic to reproduction and listed as an SVHC. If your brand includes PU-coated materials, DMF exposure is worth investigating.
Heavy metals (lead, cadmium, chromium VI). Can be present in metal trims (buttons, zippers, rivets), some dyes, and leather tanning processes. Multiple heavy metals are SVHCs and restricted under REACH.
For most fashion brands, the highest-risk areas are finishes and coatings (PFAS, formaldehyde), printed/coated elements (phthalates, DMF), and metal trims (heavy metals). Plain, unfinished natural-fibre garments without prints or metal hardware are generally lowest risk.
How to get SVHC data from your suppliers
This is where theory meets operational reality. Your suppliers hold the chemical data, you need to get it from them in a structured, usable format.
The good news: REACH already requires your suppliers to inform you about SVHCs above 0.1% in articles they supply. This isn’t a new request, it’s an existing legal obligation that many fashion supply chains have been informally ignoring.
The bad news: many Tier 1 suppliers (garment factories) don’t know what chemicals their Tier 2 suppliers (fabric mills, dye houses, finishing facilities) are using. The chemical data lives upstream, and it doesn’t always flow down to your direct supplier.
Here’s the practical approach, building on the strategies from our supplier data collection guide.
Start with a supplier declaration. Request a written statement from each supplier confirming whether the articles they supply contain SVHCs above 0.1% by weight. Provide them with the current SVHC candidate list link from ECHA. Many suppliers will need the specific list, asking “do your products contain SVHCs?” without pointing them to the list is ineffective because they may not know what qualifies.
Request test reports for high-risk product categories. For products with DWR finishes, PVC prints, PU coatings, or metal trims, request third-party test reports. OEKO-TEX Standard 100 testing covers many restricted substances including SVHCs, so if your supplier already holds an OEKO-TEX certificate, request the test report that underlies it. The certificate alone isn’t enough for your DPP, you need the data behind it.
Ask your fabric supplier about their chemical input list. Mills and dye houses that follow the ZDHC (Zero Discharge of Hazardous Chemicals) Manufacturing Restricted Substances List (MRSL) already track chemical inputs at the facility level. If your supplier follows ZDHC, they should be able to provide a Chemical Input List (CIL) that documents what’s being used.
For metal trims, test or request supplier declarations separately. Buttons, zippers, and rivets come from different suppliers than your fabrics. Each needs its own SVHC assessment.
What to put in your DPP
For the substances of concern field in your DPP, you have three possible states for each product.
“No substances of concern above applicable thresholds.” This is the ideal declaration. It means you’ve checked (via supplier declarations, test reports, or certification data) and confirmed that the product is clean. This is only credible if you actually have evidence on file.
“Contains [specific substance] in [specific component] at [concentration].” This is a transparent disclosure. It names what’s present, where, and how much. It’s not an admission of wrongdoing, many SVHCs are legal to use at certain concentrations. The obligation is disclosure, not elimination.
“Not yet assessed.” This is honest but weak. It means you haven’t collected the data yet. For a DPP that’s live and consumer-facing, this signals a gap. It’s a temporary state, acceptable during a pilot, but not for a final compliance-ready passport.
Never use vague language like “may contain substances of concern.” The DPP requires specific, product-level information. “May contain” is a hang-tag-era hedge that doesn’t meet the structured data standard.
In your DPP, include the substance name, the CAS number (the universal chemical identifier), where in the product it’s found, the concentration if known, and safe-use or handling instructions.
Why this matters beyond compliance
There’s a business case for getting SVHC data right that goes beyond regulatory box-ticking.
- Recycler access. Textile recyclers, especially chemical recyclers doing fibre-to-fibre processing, need to know what chemicals are present in the feedstock. A garment with a PFAS-based DWR finish can’t be processed the same way as an untreated cotton garment. Your DPP’s substances of concern data is what tells the recycler whether your product is compatible with their process. Without it, your garment may be rejected from recycling entirely.
- Retailer requirements. Major European retailers are increasingly requiring SVHC declarations from their suppliers. Having this data structured in your DPP makes you a more attractive wholesale partner, you can respond to retailer questionnaires instantly because the data is already organised.
- Consumer trust. A DPP that proactively states “this product contains no substances of very high concern, verified by OEKO-TEX testing” is a powerful trust signal. It demonstrates that you’ve done the work, not just made the claim.
- Future-proofing. The SVHC candidate list grows every six months. A substance that’s legal today could be added tomorrow. Brands that already track chemical inputs at the product level can assess the impact of any new addition immediately. Brands that don’t will need to scramble through their entire catalogue.
A practical starting point
You don’t need to test every product in your catalogue on day one. Start with a risk-based approach.
Identify your highest-risk product categories: anything with DWR finishes, plastic prints, PU coatings, metal trims, or synthetic leather. Request supplier declarations and, where needed, third-party test reports for these categories first.
For your lowest-risk products, plain, unfinished natural-fibre garments without prints or coatings, a supplier SVHC declaration is usually sufficient.
Enter the results as structured data in your DPP platform. If your platform has a dedicated substances of concern field with CAS number support, use it. If it only offers a free-text field, structure your entry consistently so it’s machine-readable when the delegated act specifies the technical format.
Build a monitoring process. Subscribe to the ECHA candidate list updates (published roughly every six months) and cross-reference new additions against your product categories. This takes 30 minutes per update and prevents surprises.
Scan or click this QR code to see how substances of concern data appears in a live DPP.
Frequently asked questions
Are SVHCs banned in fashion products?
No. SVHCs on the candidate list are not banned, they’re flagged for disclosure. If a product contains an SVHC above 0.1% by weight, the manufacturer must inform the supply chain and, on request, consumers. Some substances are additionally restricted under REACH Annex XVII with specific concentration limits, but inclusion on the SVHC list itself is a disclosure obligation, not a ban.
Do I need laboratory testing for every product?
Not necessarily. For low-risk products (plain natural fibres, no finishes or coatings), a supplier SVHC declaration is generally sufficient. For higher-risk categories, products with chemical finishes, coatings, plastic prints, or metal hardware, third-party testing provides stronger evidence. An OEKO-TEX Standard 100 test report covers many restricted and SVHC substances.
What if my supplier says they don’t know about SVHCs?
This is common, especially with Tier 1 garment factories that don’t handle the chemical processes themselves. Help them by providing the ECHA candidate list link, specifying exactly what you need (a written declaration about SVHC content above 0.1%), and if needed, requesting that they ask their upstream fabric and chemical suppliers. Our supplier data guide covers escalation strategies.
How often does the SVHC list change?
ECHA typically updates the candidate list twice per year. As of February 2026, the list contains 253 entries. Each update can add new substances, which immediately triggers disclosure obligations. Monitoring these updates and cross-referencing against your product categories should be a routine twice-yearly process.
Does OEKO-TEX certification cover SVHC compliance?
Partially. OEKO-TEX Standard 100 tests for many restricted and hazardous substances, including many SVHCs. However, the OEKO-TEX scope doesn’t cover every substance on the SVHC candidate list, and the list is updated more frequently than OEKO-TEX revises its test criteria. An OEKO-TEX certificate provides strong evidence but shouldn’t be treated as a complete SVHC clearance without checking the underlying test report.
What’s the difference between “substances of concern” under ESPR and “SVHCs” under REACH?
SVHCs are a subset. The ESPR definition of “substances of concern” is broader, it includes SVHCs, but also substances classified under CLP for chronic hazards, substances regulated under the POPs regulation, and substances that negatively affect recycling. The ESPR definition covers over 4,600 substances compared to 253 on the SVHC candidate list. The DPP will need to address the broader ESPR definition, not just the REACH SVHCs.
This guide reflects the REACH and ESPR regulatory landscape as of June 2026. The SVHC candidate list is updated periodically, check ECHA for the latest version. Stay informed.
This article has been reviewed for accuracy by the Wetrack team.
Some illustrations may be AI-generated in which case they are labeled. Report any issue.