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EU and India · Textiles and leather

Azo dyes and restricted substances in textiles and leather made in India

In the EU, REACH Annex XVII entry 43 bans azo dyes that can release listed aromatic amines above 30 mg/kg in textile and leather articles that touch the skin or mouth for long periods. Entry 72 adds limits for 33 CMR substances in clothing, footwear and skin-contact textiles. India separately bans the handling of 112 hazardous dyes.

EU azo rule
REACH Annex XVII entry 43: 30 mg/kg per listed amine
EU CMR rule
Entry 72, from 1 Nov 2020, 33 substances or groups
India
Handling of 112 benzidine-based and azo dyes prohibited under the Environment (Protection) Act 1986
Proof
Lab test to EN ISO 14362 (textiles) or EN ISO 17234 (leather)
Buyer lists
RSLs such as AFIRM; ZDHC MRSL for chemical inputs

Key takeaways

  • REACH entry 43 limits each listed amine released from azo dyes to 30 mg/kg in skin-contact textile and leather articles, including chair covers and bedding.
  • REACH entry 72 sets limits for 33 CMR substances in clothing, footwear and textiles with similar skin contact, such as bed linen and upholstery.
  • India has prohibited the handling of 112 benzidine-based and azo dyes, and imported textiles must not contain them.
  • Buyer restricted substance lists (RSLs) are often stricter than the law and are written into purchase contracts.
  • Only a lab can measure amines and CMR substances. An inspection checks that the tested materials are the ones in production.

REACH entry 43: the EU azo dye restriction

Entry 43 of Annex XVII to the EU REACH Regulation (EC) No 1907/2006 restricts azo colourants. Its current wording was set by Regulation (EC) No 552/2009. It has three parts.

  • Articles. Azo dyes that can release one or more of the aromatic amines listed in Appendix 8, in concentrations above 30 mg/kg (0.003% by weight) in the article or its dyed parts, must not be used in textile and leather articles that may come into direct and prolonged contact with the skin or the mouth. Such articles cannot be placed on the EU market.
  • Examples named in the law. Clothing, bedding, towels, hats, nappies, sleeping bags, footwear, gloves, wristwatch straps, handbags, purses and wallets, briefcases, chair covers, textile or leather toys, and yarn and fabrics sold to the final consumer.
  • Dyes as substances. The azo dyes listed in Appendix 9 must not be placed on the market or used in mixtures above 0.1% by weight to colour textile and leather articles.
MaterialTest method listed in Appendix 10
TextilesEN ISO 14362-1:2017 (amines from azo colourants, with and without extracting the fibres) and EN ISO 14362-3:2017 (azo colourants that may release 4-aminoazobenzene)
LeatherEN ISO 17234-1:2015 (aromatic amines from azo colourants) and EN ISO 17234-2:2011 (4-aminoazobenzene)
Source: Appendix 10 to REACH Annex XVII as replaced by Regulation (EU) 2020/2096, reviewed 13 Oct 2026.

The rule reaches home furnishings as well as apparel. A cushion cover, a dyed cotton throw or a leather chair cover sold in the EU is in scope.

REACH entry 72: CMR substances in textiles and footwear

Regulation (EU) 2018/1513 added entry 72 to Annex XVII. From 1 November 2020, 33 substances or groups classed as carcinogenic, mutagenic or toxic for reproduction (CMR) must not exceed set limits in clothing and related accessories, footwear, and other textiles that touch the skin to a similar extent, when these are for consumers. The recitals give bed linen, blankets, upholstery and reusable nappies as examples. Limits are measured in homogeneous material.

Substance or groupLimit
Cadmium, chromium VI, arsenic and lead compounds1 mg/kg after extraction, each
Listed polycyclic aromatic hydrocarbons (PAHs), for example benzo[a]pyrene1 mg/kg each
Benzene5 mg/kg
Formaldehyde75 mg/kg (300 mg/kg was allowed in jackets, coats and upholstery until 1 Nov 2023)
Listed phthalates1,000 mg/kg, alone or combined with other CMR phthalates
Solvents NMP, DMAC and DMF3,000 mg/kg each
Dyes C.I. Disperse Blue 1, Basic Red 9 and Basic Violet 3; quinoline50 mg/kg each
Source: Regulation (EU) 2018/1513, Appendix 12 (selection). Check the consolidated Annex XVII for later amendments.

Entry 72 does not apply to items made only of natural leather, fur or hide, to non-textile fasteners and decorations, to second-hand goods, to wall-to-wall carpets, rugs and runners, or to disposable textiles. Personal protective equipment and medical devices are also excluded.

India's own ban on hazardous dyes, and what it means for exporters

India restricts the same chemistry at home. The Ministry of Environment and Forests prohibited the handling of 42 benzidine-based dyes by a notification of January 1990, effective from 1993. A Gazette notification of 26 March 1997 added 70 azo dyes, bringing the total to 112 dyes that can release harmful amines. The legal basis is clause (d) of section 6(2) of the Environment (Protection) Act, 1986.

Imports are covered too. Under DGFT Notification No. 19/2015-2020 of 4 September 2015, textiles and textile articles may be imported only if they contain none of these prohibited dyes, backed by a certificate from an accredited textile testing laboratory in the country of origin.

For an overseas buyer, the Indian ban is a useful baseline but not proof. It governs what Indian dye houses may handle, not the amine content of a finished article. The REACH limits apply to the article as sold. In practice the risks in an Indian supply chain are:

  • Unbranded or repacked dyes bought by small dye houses and printers, with no safety data sheet or supplier declaration.
  • Job-work processing. Yarn or fabric may be dyed or printed by a sub-contractor the buyer has never seen.
  • Leather tanned and dyed elsewhere, with no test report linking the hide lot to the finished bag or chair cover.
  • Colour changes after approval. A new shade can mean a new dye recipe that was never tested.

Buyer restricted substance lists: AFIRM and ZDHC

Most brands and importers go beyond the law with their own restricted substance list (RSL), written into the purchase contract. Two industry references are common:

ListWhat it controlsWho uses it
Legal limits (REACH entries 43 and 72)Substances in the finished article sold in the EURequired by law for every EU sale
AFIRM RSLSubstances in finished apparel and footwear products and materials; updated each year by 1 FebruaryBrands that adopt it as their RSL or base their own list on it
ZDHC MRSLSubstances in the chemical formulations used in production, such as dyes and auxiliaries, with limits for eachBrands that require mills and dye houses to use compliant chemicals
Sources: AFIRM Group; ZDHC Roadmap to Zero. Reviewed 13 Oct 2026.

The difference matters. An RSL is checked by testing the product. A manufacturing RSL (MRSL) is checked by looking at the chemicals in the dye house store and their declarations. A supplier can pass one and fail the other. OEKO-TEX STANDARD 100 is another common buyer requirement; see OEKO-TEX and GOTS.

What an inspection can verify, and what needs a lab

An inspector at the factory can checkOnly a lab can establish
Test reports exist for each fabric, colourway and leather article, and name the material, shade and supplier actually in productionWhether any listed amine is released above 30 mg/kg (EN ISO 14362, EN ISO 17234)
Dye house records: dye names, batch numbers and supplier declarations for the shades in the orderFormaldehyde, heavy metals, PAHs, phthalates and other entry 72 substances
The colour and fabric of production match the approved and tested sampleCompliance with a buyer RSL or MRSL limit
Labels, hangtags and claims such as “azo-free” are backed by a current reportWhether a substituted dye or leather lot still passes

A report dated before a shade change, or issued for a different mill, does not cover the goods. Ask for a new test when the dye recipe, fabric mill or tannery changes.

How Clear To Load checks this in India

On a home textiles inspection in India, the inspector compares the fabric, shade and leather in production with your approved samples and test reports, and photographs dye house records and supplier declarations where the factory provides them. Where you need a test, we pull and seal samples from the production lot and send them to an ISO/IEC 17025-accredited lab you choose or we suggest, through lab testing coordination. We have no partner labs and take no lab commissions.

The report ends in a verdict: Cleared to load, Hold or Not cleared. An inspection does not certify chemical compliance; that rests on the lab reports. To add these checks to an order, book an inspection.

Sources

  1. Regulation (EC) No 552/2009, Annex XVII entry 43 (EUR-Lex)
  2. Regulation (EU) 2018/1513, entry 72 and Appendix 12 (EUR-Lex)
  3. Regulation (EU) 2020/2096, Appendix 10 test methods (EUR-Lex)
  4. ECHA: Substances restricted under REACH
  5. JNCH Customs Public Notice No. 81/2015: testing of imported textiles for hazardous dyes
  6. Central Coir Research Institute: banned dyes and amines in India
  7. AFIRM Restricted Substances List
  8. ZDHC Manufacturing Restricted Substances List

Frequently asked questions

Does the 30 mg/kg azo limit apply to home textiles?

Yes, where the article may be in direct and prolonged contact with the skin. REACH entry 43 names bedding, towels and chair covers among its examples, along with yarn and fabrics sold to consumers. Cushion covers, throws and bed linen are normally treated as in scope.

Is an “azo-free” certificate from the dye supplier enough?

No. A dye supplier declaration shows what was bought, not what is in the finished article. REACH limits apply to the article or its dyed parts. Buyers usually require a lab report to EN ISO 14362 for textiles or EN ISO 17234 for leather, tied to the production lot.

Does entry 72 cover rugs and carpets?

No. Entry 72 excludes wall-to-wall carpets, textile floor coverings for indoor use, rugs and runners. Entry 43 on azo dyes and other REACH restrictions can still apply, so check each one.

Does India's azo dye ban mean Indian textiles are compliant?

Not by itself. India prohibits handling of 112 hazardous dyes, but enforcement in small dye houses varies and the REACH limits apply to the finished article. Treat the Indian ban as a baseline and still test the goods.

What is the difference between an RSL and an MRSL?

An RSL limits substances in the finished product and is checked by product testing. An MRSL, such as the ZDHC MRSL, limits substances in the chemical formulations used at the mill or dye house and is checked by reviewing chemical inventories and declarations.

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