A European buyer asked for a declaration that our tees contain no restricted azo dyes. What does the rule cover?

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Flat illustration of a certificate with a seal, a warning triangle and a knit fabric swatch

A European buyer asked for a declaration that our tees contain no restricted azo dyes. What does the rule cover?

Entry 43 restricts azo colourants that can release listed aromatic amines above a limit in textile articles in direct, prolonged skin contact. Ask suppliers for dye information and a test report.

Labels, Packaging & ComplianceKnitwear Talk3 min readKnitwear Base Editorial Team
Flat illustration of a certificate with a seal, a warning triangle and a knit fabric swatch
Buyer question

A European retailer’s supplier manual asks us to confirm in writing that our dyed tees and underwear comply with the REACH azo dye restriction. What does the restriction mean and what do we need?

Main answer
Knitwear Base Editorial Team
Main answer

Azo colourants are a large family of synthetic dyes. Most are not a concern, but some can break down, under certain conditions, into aromatic amines that are classified as carcinogenic. The EU restricts them in REACH Annex XVII, entry 43. The summary below reflects ECHA’s published material; check the current legal text with a qualified adviser for your market.

What the entry says

Entry 43 prohibits azo colourants that can release one or more of the aromatic amines listed in Appendix 8 of Annex XVII, in detectable concentrations, meaning above 30 mg/kg, in the articles or in the dyed parts of the articles. It applies to textile and leather articles that may come into direct and prolonged contact with human skin or the oral cavity, and clothing is within that group. ECHA publishes the list of aromatic amines in Appendix 8.

What it means for knitwear

Tees, underwear, hoodies and leggings are clothing that touches skin, so the restriction is relevant. The test looks at whether the finished dyed fabric or garment can release the listed amines under a defined reductive procedure. Prints and coloured trims or threads are also dyed parts to consider.

How compliance is shown

The usual route is a lab report for the dyed fabric or garment using the EU’s harmonised methods, which are EN ISO 14362-1 and -3 for textiles. Ask the fabric mill for a current report that covers each colour or colour group you sell and that names the method and the limit. Ask dye houses for information on the dye classes they use, and require them to tell you if a dye changes.

Certificates and labels

A separate scheme such as OEKO-TEX STANDARD 100 includes limits for amines from azo colourants among its criteria, but a certificate covers only the products, scope and dates it names. Verify it on the issuer’s check tool and do not treat it as a general approval.

What to answer the buyer

Reply with the supplier reports and the list of styles they cover, and keep them updated when fabric or dye sources change. Do not sign a broad declaration you cannot support: say which styles, colours and reports it covers, and state the date. If a colour is not yet covered by a report, order the test before the first shipment, since a test report is much cheaper than a rejected consignment or a delisted style.

Sources and further reading

Standards and rules are summarised from their published scope or official guidance. Use the current edition and confirm requirements for your market.

Three perspectives on this question

Knitwear Base Editorial Team
Purchasing perspective

I'd ask the mill for a current test report per colour group naming the method and the limit, and for notice of any dye change.

Knitwear Base Editorial Team
Merchandising perspective

A new colour from a new dye house is where a gap in testing is most likely, so I'd tie colour launches to updated reports.

Knitwear Base Editorial Team
QC perspective

We'd match each style's colours to the report scope and hold new testing for any colour not covered.

Working on a similar program?Send your tech pack, fabric references and test requirements. We reply with a quote and the questions we need answered.

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