Ask two compliance consultancies whether the new EU formaldehyde restriction hits your sweaters on 6 August 2026 and you can get two opposite answers. We checked, because we were about to write something on the assumption that it does.
It does not. And the reason it does not is the same reason most EU textile compliance advice is confusing: each rule binds a different party, and several of the headline dates bind somebody other than you.
Here is what actually applies to a knitwear programme sold into the EU, what binds the factory, what binds the brand, and what is not law at all.
There are two separate formaldehyde restrictions in REACH Annex XVII, and they do different jobs.
Entry 72 limits formaldehyde content in textiles, clothing and footwear intended for consumers to 75 mg/kg. It has been in force since 1 November 2020. This is the one that applies to your sweaters.
Entry 77, introduced by Regulation (EU) 2023/1464, limits formaldehyde emissions — 0.062 mg/m³ for furniture and wood-based articles, 0.080 mg/m³ for other articles — and has applied since 6 August 2026 (vehicle interiors from 6 August 2027). Its derogations exclude, verbatim, "articles for which the restriction laid down in entry 72 applies" — you can read the clause yourself in Regulation (EU) 2023/1464 on EUR-Lex. Consumer clothing is governed by entry 72, so entry 77 excludes it by its own text.
So 6 August 2026 changes nothing for consumer knitwear. Your binding limit is, and since 2020 has been, 75 mg/kg of content. That date has now passed, and it changed nothing for knitwear. If a supplier or a consultant tells you a new formaldehyde limit landed in August 2026, ask which entry number they mean. This is worth insisting on: as of August 2026 several compliance advisories are still describing entry 77 as applying to textiles and clothing. It does not, and the derogation list linked above settles it in one line. The practical cost of believing otherwise is emission testing you do not need, and a supplier with a ready-made reason to reprice.
What binds the product — REACH entry 72
Entry 72 is the substance list your factory actually has to control. It covers 33 CMR substances in textiles, clothing and footwear for consumers, with limits including:
|
| Formaldehyde | 75 mg/kg |
| PAHs (8 listed) | 1 mg/kg |
| Extractable metals — lead, cadmium, arsenic, chromium VI | 1 mg/kg |
| Chlorotoluenes (3 listed) | 1 mg/kg each |
| Benzene | 5 mg/kg |
| Azo dye precursors (4 listed) | 30 mg/kg |
| Disperse dyes (3 listed), quinoline | 50 mg/kg |
| Phthalate plasticisers (5 listed) | 1,000 mg/kg combined |
| NMP, DMFa, DMAC | 3,000 mg/kg each |
Natural leather, fur and hide components are outside entry 72's scope.
This is the list to put in a test request. Asking a lab for "REACH testing" without naming entry 72 is how buyers end up paying for a broad SVHC screen that does not answer the question a customs officer or a retailer would ask.
From 19 July 2026, Article 25 of the Ecodesign for Sustainable Products Regulation — Regulation (EU) 2024/1781 — prohibits large companies from destroying unsold apparel, clothing accessories and footwear listed in its Annex VII.
Two qualifications matter:
- "Large" is defined. A company qualifies when it exceeds at least two of three thresholds: more than 250 employees, more than €50 million annual turnover, more than €25 million balance-sheet total. Medium-sized companies are not caught until 19 July 2030. Small companies are further out still.
- It binds the company holding the unsold stock, not the manufacturer that made it. Nothing your factory does changes your position under this article.
Destruction stays permissible in narrow, documented cases such as safety risks or damage beyond repair. A standardised disclosure format for reporting discarded volumes applies from February 2027.
If you are a growing brand under those thresholds, 19 July 2026 is a date to know about, not a date to act on.
What is coming, but is not here — textile EPR
The revised Waste Framework Directive entered into force on 16 October 2025 and makes extended producer responsibility for textiles binding on every Member State. But the sequence matters:
1. 16 October 2025 — directive in force, obligation lands on Member States
2. Mid-2027 — Member States must have transposed it into national law
3. April 2028 — national EPR schemes must be operational
You register with a national scheme when that scheme exists. Several Member States — France most notably — already run textile EPR ahead of the directive, so check country by country rather than assuming a single EU date. Cost-coverage obligations extend to micro-enterprises in 2029.
The General Product Safety Regulation, Regulation (EU) 2023/988, has applied since 13 December 2024. For knitwear it rarely changes the product, but it changes the paperwork:
- An economic operator established outside the EU must appoint a responsible person established in the Union for each product placed on the EU market. That person is the contact for market surveillance authorities and must be able to produce conformity documentation on request.
- Importers must add their own name and contact details to the product or packaging, alongside the manufacturer's.
This is the requirement most often discovered late, because it is administrative rather than technical. It is also the one a supplier can genuinely help with — we hold an appointed EU authorised representative under GPSR, and are registered under the German Packaging Act (LUCID DE4680505763138) for packaging placed on the German market.
OEKO-TEX Standard 100 is a voluntary certification, not legislation. Its limit values are in several places stricter than REACH entry 72, and revised limits applied from 1 June 2026 — but no authority will stop your goods for lacking it. Retailers may well require it; that is a commercial requirement, not a legal one. Treat it as such when you are deciding what to pay for.
The same goes for BSCI/amfori, Sedex and SA8000: they are social-audit schemes buyers ask for, not statutes.
The Carbon Border Adjustment Mechanism entered its definitive phase on 1 January 2026, and sourcing content now routinely lists it among the costs apparel importers must budget for. For knitwear, it is not one.
CBAM's definitive scope covers six emission-intensive sectors: iron and steel, aluminium, cement, fertilisers, electricity and hydrogen. Textiles, fabric and garments are not among them. A knitted garment imported into the EU carries no direct CBAM obligation and no CBAM cost today.
The only realistic exposure is indirect and small: the metal content of trims — zip components, metal buttons, hardware — belongs to a covered sector. In practice that is a supplier-declaration question at most, not a carbon liability attached to the garment.
Textiles do sit on the expansion watchlist, with a formal review scheduled for 2030 and possible inclusion in the years after. Budgeting CBAM into a 2026 or 2027 knitwear programme is planning for a rule that does not yet apply to the product.
Ask: "which entry number, and what does the test report actually cover?"
A factory that answers "REACH entry 72, and here is the report listing formaldehyde at X mg/kg against the 75 mg/kg limit" is telling you something verifiable. A factory that answers "yes, we are REACH compliant" is telling you nothing — REACH is a 1,000-page regulation and nobody is compliant with all of it.
The same test works on dates. Anyone citing 6 August 2026 as your formaldehyde deadline has not read the derogations.
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*Sources: REACH Annex XVII entries 72 and 77; Commission Regulation (EU) 2023/1464; Regulation (EU) 2024/1781 Article 25 and Annex VII; revised Waste Framework Directive (in force 16 October 2025); Regulation (EU) 2023/988. Verified against the regulation texts and testing-body guidance on 31 July 2026. This is sourcing guidance from a manufacturer, not legal advice — confirm your own position with your compliance counsel or test house.*
If you want the entry-72 substance list as a test-request template, or a view on which of these dates actually touch your programme, send us your product mix and target markets. We reply within 4 business hours.
What actually binds knitwear sold in the EU today?
Chemical restrictions on the product under REACH, plus fibre composition and care labelling. Those apply now. A great deal of what buyers are told is 'EU law' is either an obligation on the brand rather than the factory, or a rule that has been announced but is not yet in force.
What binds the brand rather than the factory?
The obligations that attach to placing goods on the market: labelling, producer responsibility registrations, and the accuracy of any environmental claim made in marketing. A factory can supply evidence for these but cannot discharge them on your behalf.
Which rules are coming but not yet in force?
Several, and the article separates them explicitly - because planning as if a future requirement already applies leads to specifying and paying for things you do not yet need, while genuinely current obligations get missed.
What is often overlooked but applies right now?
Labelling accuracy and substantiation of claims. Composition and care labelling have to be correct at production, and a sustainability claim made without the certification chain behind it is the exposure most brands underestimate.
What is not law at all?
A number of the certifications and schemes buyers treat as mandatory are voluntary market expectations. They may still be commercially necessary for your customer - but knowing which is which lets you spend the compliance budget where it is actually required.
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