Export readiness · 07 of 10
4 min read
Chemicals and the certificate question: what is enough today
Chemical data has the longest supplier lead time and the least available information of anything on this list. Here is what is realistic to do about it this month.
What already binds
REACH Art. 33 already applies, and it is not textile-specific. A supplier of an article containing a substance of very high concern above 0.1 percent by weight has to pass on enough information for safe use, and has to answer a consumer asking about it within 45 days. That obligation did not wait for any product passport.
What is proposed on top
ESPR Art. 7(5) points toward the identity and the location of substances of concern being recorded. That is a much higher resolution than what the sector currently produces, and it is proposed rather than binding. Worth knowing about. Not worth panicking about, and certainly not worth buying anything for yet.
Where the sector actually is
The Commission's own research service looked at this and found the widely used product certificates to be the most prevalent chemical verification mechanism in the sector, working on a pass or fail basis, with substance-level concentration and location data not reported and not available in a form that could be disclosed reliably (JRC, 13 May 2026). So recording a certificate reference with its scope is not a shortcut. It is where the industry is, as the Commission's own researchers found it.
What to do this month
Ask your fabric supplier whether it holds a chemical safety certificate, and ask for the copy and its scope: which article class, which date, which mill. Most suppliers have one and simply never send it, because nobody asked. That is a free step and it is usually the whole job. If nobody in the chain holds one, write a dated supplier declaration instead, record what you know, and record plainly that you do not know the rest.
The essentials
- REACH Art. 33 already binds, above 0.1 percent by weight, with a 45 day answer to consumers.
- A certificate reference with its scope is current industry practice, not a shortcut.
- Asking your supplier for a copy is free, and it is usually the whole job.
Primary sources
- Regulation (EC) No 1907/2006 (REACH), Art. 33. Checked 17 August 2026
- Regulation (EU) 2024/1781 (ESPR), Art. 7(5). Checked 17 August 2026
- JRC, study on digital product passport content for textile apparel products, 13 May 2026
Criteria here are drawn from the ESPR text and the JRC preparatory study. Sources last checked 17 August 2026, and re-checked at every JRC milestone. Binding requirements for textiles begin only after the textile act is adopted and its lead time has run.
Where we stand
Mula is not affiliated with the European Commission, the JRC, or any certification body. What we do is readiness: getting your own evidence into order. We are not an economic operator, we do not register products in any system, and we never state that a product meets a rule. That judgement belongs to the party placing the product on the market and to the authorities.
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