REACH Annex XVII: the restricted substances in products you sell, and their limits

Annex XVII of REACH, Regulation (EC) No 1907/2006Regulation (EC) No 1907/2006, REACH (chemicals)The whole regulationClick opens the law on the EU Publications Office., is the list of restrictions. Each entry names a substance or a group of substances and the conditions under which it may be in a product. 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” (Art. 67(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 67, paragraph 1Click opens the article on EUR-Lex.). The limit sits on the product, whoever sells it.

Annex XVII runs to entry 83. Most entries restrict industrial chemicals, fuels or mixtures. These are the ones that name consumer articles or their materials. The entry that binds you is whichever one names your product or its material.

Exemptions that change the answer. The phthalate limit on all articles does not apply to, among others, articles only for industrial or agricultural use or only for outdoor use where no plasticised material touches mucous membranes or stays on the skin, food-contact materials, medical devices, electrical and electronic equipment within the scope of Directive 2011/65/EUDirective 2011/65/EU, Restriction of Hazardous Substances (RoHS)The whole regulationClick opens the law on the EU Publications Office., or articles placed on the market before 7 July 2020 (entry 51(4)). “Prolonged contact” there means more than 10 minutes continuously, or 30 minutes intermittently, per day (entry 51(5)(b)). The lead limit for small articles excludes, among others, keys and locks, musical instruments, brass with up to 0.5% lead, the tips of writing instruments, religious articles, and toys within the scope of Directive 2009/48/ECDirective 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office. (entry 63(8)). The PAH limits do not apply to articles first placed on the market before 27 December 2015 (entry 50(7)). The chromium VI limit does not apply to second-hand articles that were in end use in the EU before 1 May 2015 (entry 47(7)). The NPE limit does not apply to second-hand textiles, or to new textiles made only from recycled textiles without NPE (entry 46a(2)).

What counts as a part. The lead limit for jewellery covers “the materials from which the jewellery is made, as well as the individual components” (entry 63(2)). The PAH limits count in each rubber or plastic component (entry 50(5)). The phthalate limits count in the plasticised material, which the entry defines as PVC and other polymers, rubber except silicone rubber and natural latex coatings, surface coatings, prints, decals, adhesives, sealants, paints and inks (entry 51(5)(a)).

Entry 72 does not apply to parts made only of natural leather, fur or hide, to non-textile fasteners and non-textile decorative attachments, to second-hand items, or to wall-to-wall carpets, indoor textile floor coverings, rugs and runners (entry 72(3)). It does not apply to personal protective equipment or medical devices (entry 72(4)), and its point on other textiles does not apply to disposable textiles (entry 72(5)). Other entries still apply on top: a part made only of leather falls outside entry 72, but where it touches the skin it falls inside the chromium VI limit of entry 47.

Formaldehyde, entry 77. The limit is a release into air, measured in a test chamber under the conditions of Appendix 14: 23 °C, 45% relative humidity, one air change an hour. It does not apply to articles where formaldehyde is only naturally present in the materials, articles only for outdoor use, articles in constructions used only outside the building shell and vapour barrier that do not emit formaldehyde into indoor air, articles only for industrial or professional use unless they expose the general public, articles under entry 72, biocidal products, medical devices, personal protective equipment, food-contact articles, or second-hand articles (entry 77(1)). Clothing and footwear therefore stay under the 75 mg/kg content limit of entry 72, not the air-release limit. An item made only of leather, fur or hide is outside entry 72 (entry 72(3)(a)), so entry 77 covers it at 0.080 mg/m³. A leather part or a non-textile fastener on a garment that entry 72 covers is an edge case: entry 77(1)(e) exempts “articles for which the restriction laid down in entry 72 applies”, and the text does not say whether that reaches the parts entry 72(3) leaves out.

PFHxA, entry 79. The limits do not apply to personal protective equipment against the category III risks the entry names, medical and in vitro diagnostic devices, or construction textiles (entry 79(3)). Articles placed on the market before 10 October 2026, and for paragraph 2 before 10 October 2027, are outside the limit (entry 79(7)-(8)).

Microplastics, entry 78. The entry restricts the particles on their own and in mixtures. Natural polymers that are not chemically modified, degradable or soluble polymers proved under Appendices 15 and 16, and polymers without carbon are outside its definition. Paragraph 1 does not apply to particles contained by technical means, particles whose properties change in use so the entry no longer covers them, or particles permanently incorporated into a solid matrix during the end use (entry 78(5)). From 22 June 2028 that last derogation covers only an end use of one year or longer (Regulation (EU) 2026/1168). Products sold under the derogations of paragraph 5 carry instructions for use and disposal (entry 78(8)), and from 17 October 2031 until 16 October 2035 make-up, lip and nail products carry the statement “This product contains microplastics.” (entry 78(9)).

2,4-dinitrotoluene, entry 83. The limit does not apply to explosives, except pyrotechnic articles and ammunition, nor to articles for military use, ammunition for police or other security forces, toys under Regulation (EU) 2025/2509Regulation (EU) 2025/2509, Toy Safety RegulationThe whole regulationClick opens the law on the EU Publications Office., medical devices, or food-contact articles (entry 83(3)), nor to articles placed on the market in the EU before 11 May 2027 (entry 83(7)).

A substance can be on more than one list. Where a Candidate List substance is also restricted, the information duty at 0.1% applies alongside the limit, whatever the restriction allows. A restriction is proposed by ECHA at the Commission’s request or by an EU country through a dossier (Art. 69(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 69, paragraph 1Click opens the article on EUR-Lex., Art. 69(4)Regulation (EC) No 1907/2006, REACH (chemicals)Article 69, paragraph 4Click opens the article on EUR-Lex.), or, for consumer uses of carcinogenic, mutagenic or reproductive-toxic substances, by the Commission directly (Art. 68(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 68, paragraph 2Click opens the article on EUR-Lex.). It is adopted where there is “an unacceptable risk to human health or the environment” that needs EU-wide action (Art. 68(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 68, paragraph 1Click opens the article on EUR-Lex.). SVHC covers the Candidate List duties, and the EU CLP Regulation sets the hazard classes that entries 28 to 30 and Appendix 12 rest on. Some banned substances are not in Annex XVII at all: the POPs Regulation bans persistent organic pollutants in any article above a trace limit, and the EU PFAS ban page shows how entries 68, 73, 79 and 82 sit beside it.

Great Britain applies its own restrictions under UK REACH, which HSE publishes. HSE states that EU REACH, including Annex XVII, continues to apply in Northern Ireland. This page covers the EU’s Annex XVII.

REACH’s importer is “any natural or legal person established within the Community who is responsible for import” (Art. 3(11)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 11Click opens the article on EUR-Lex.). A business outside the EU is not that importer, so the business in the EU that brings the goods in carries the import duties. The limit itself does not depend on who that is: an online offer aimed at EU end users counts as making the product available in the EU (Art. 6Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 6Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.). REACH compliance sets out who the importer is on each route, and importer of record in the EU covers the customs side.

REACH is on the list of Union harmonisation legislation in Annex I, point 22, of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office., so its market surveillance rules reach articles under REACH. An authority can require you to bring the product into compliance, stop it being made available, withdraw or recall it, or destroy it (Art. 16(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 16, paragraph 3Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.). A product presenting a serious risk is withdrawn, recalled or banned, and the measure is notified to the Commission (Art. 19(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 19, paragraph 1Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.) through the rapid alert system (Art. 20(4)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.), now Safety Gate. At the border, customs suspend release of a product that lacks the documents or the labelling its law requires, among other grounds (Art. 26(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 26, paragraph 1Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.).

Chemical risk is the most notified risk on Safety Gate. The Commission’s Safety Gate 2025 results count 4,671 alerts in 2025, 53% of them for chemical risk, a share the report says also reflects the many alerts on cosmetics. The report states that “Phthalates are still very often detected in plastic toys and other products for children”, and that a web crawler, eSurveillance, finds notified products still sold or reappearing in web shops and online marketplaces. Alert summaries are published on the Safety Gate Portal.

What you can skip

What the law leaves open

• How to test phthalates, PAHs and lead in an article. Annex XVII names methods for nickel, azo dyes and formaldehyde release, but entries 50(5), 51(3) and 63(1) set limits with no method. Meanwhile, use a report that names its method, so any laboratory can repeat it.
• What “related accessories” covers in entry 72. The entry applies to clothing and “related accessories” and defines neither. Meanwhile, treat items worn with clothing, such as scarves, belts and textile bags, as inside it.
• When PFAS foams in portable fire extinguishers stop. Entry 82(1) bans PFAS foams “as of 23 October 2030”, while entry 82(5)(a) allows portable fire extinguishers with PFAS foam to be placed on the market “until 23 October 2026”. Recital 32 of Regulation (EU) 2025/1988 gives the intent: a 12-month transition for placing these extinguishers on the market. Meanwhile, plan on 23 October 2026, and 23 April 2027 for alcohol-resistant foam.