REACH is the framework that governs chemicals in articles placed on the European market, and a zipper is an article in its own right. That single point causes more confusion than any other. A zipper is not merely a component of a jacket; it is an article with its own composition, its own supplier, and its own information obligations. When a brand asks a zipper supplier for a REACH declaration, it is asking for a statement about an article, not about a fabric.

This article separates the two obligations that are usually confused, the candidate list communication duty and the Annex XVII restrictions, explains how each applies to sliders, tapes and pullers, and describes a documentation routine that holds up when a customer audits the supply chain.

1. Scope: two different obligations

The first obligation concerns substances of very high concern. A candidate list is maintained and updated periodically, and where an article contains a listed substance above 0.1 per cent by weight, the supplier must give the recipient sufficient information to allow safe use, and must answer consumer requests within a defined period. Since early 2021 there has also been a notification duty to the SCIP database for articles containing candidate list substances above that threshold.

The second obligation concerns restrictions in Annex XVII. These are not information duties. A restriction sets a concentration limit or a use condition, and an article that exceeds it cannot be placed on the market at all. The distinction matters commercially: an SVHC above 0.1 per cent can be legal if it is communicated, whereas a restricted substance above its limit makes the product non-compliant regardless of what is written on the label.

The 2015 judgment of the Court of Justice on the interpretation of the 0.1 per cent threshold confirmed that the threshold applies to each article in a complex product, not to the product as a whole. For a zipper, that means the assessment is made on the zipper, and arguably on each article within it, rather than on the finished garment's total weight.

2. Key requirements that touch zipper hardware

Zipper components concentrate risk in a few places.

  • Nickel release. Nickel-releasing articles intended for prolonged skin contact are restricted, and the release rate is measured rather than the content. Sliders, pullers, snaps and rivets are the classic cases. A passivated or coated finish behaves differently from a bare polished finish, and wear changes the result.
  • Lead. Lead in articles supplied to the general public is restricted above a concentration threshold, with a list of derogations. Recycled zinc alloy is the usual entry point for lead in a slider or a puller.
  • Cadmium. Cadmium in plastics and in certain coatings is restricted at a low threshold, and cadmium pigments or stabilisers occasionally appear in coloured plastic components.
  • Chromium VI in leather. Leather pull tabs and leather-look trims are in scope of the chromium VI restriction, and the result depends on the tanning process rather than on the colour.
  • Azo dyes. Dyed tape and dyed thread can release restricted aromatic amines above the limit, particularly in certain deep shades and in low-cost dyehouses.
  • Phthalates. Plasticised PVC coatings on tape, soft PVC pullers and printed transfers are the relevant surfaces.
  • PAH. Rubberised or soft-touch grips and coated pullers can carry polycyclic aromatic hydrocarbons, and the restriction is concentration-based for articles in contact with skin.
  • CMR substances in textiles and clothing. A later entry in Annex XVII addresses carcinogenic, mutagenic and reprotoxic substances in clothing, related accessories, textiles and footwear, and it overlaps directly with zipper tape and trims.

The exact entry numbers, concentration limits and application dates should be read from the consolidated text of Annex XVII. Quoting a limit from memory is how non-compliance happens.

3. Test methods and how evidence is built

Each restriction is paired with a test method, and the method determines the result as much as the chemistry does. Nickel release is measured on a simulated-skin exposure over a defined period, and there is a separate procedure that simulates wear before the release test, so a report that omits the pre-treatment is not comparable with one that includes it. Azo dye testing uses a reductive extraction followed by chromatographic determination of the amines. Chromium VI in leather uses a specific extraction and colorimetric or chromatographic determination. Phthalates and PAHs use solvent extraction and chromatographic analysis.

A practical evidence package for a zipper contains:

  1. A full material declaration by component: chain, slider body, puller, top and bottom stops, tape yarn, tape coating, any print or transfer, and any leather trim.
  2. Restriction test reports for the parameters that the declaration identifies as relevant, with the method named.
  3. A candidate list statement dated and signed, listing the substances screened and the threshold applied.
  4. SCIP reference numbers where a candidate list substance is present above the threshold.

The declaration is the part that most suppliers skip, and it is the part that makes the reports useful. Without it, a buyer cannot tell whether the nickel report covers the slider that is actually being shipped or the one that was sampled three seasons ago.

4. Common non-conformities

The recurring failures in zipper supply chains are predictable.

  • A "REACH compliant" statement with no substance list, no limits and no test data.
  • Nickel release tested on a new slider with no wear simulation, giving an optimistic result that does not reflect use.
  • Lead above the threshold in die-cast sliders made from uncontrolled scrap alloy, discovered only when a customer runs its own screening.
  • Azo dye failures in deep shades of dyed tape, where the dyehouse has changed a recipe without telling the zipper maker.
  • Chromium VI in leather pull tabs bought as finished trim and never tested.
  • Candidate list statements dated before the most recent update, so a newly listed substance has never been screened.
  • No SCIP notification despite an SVHC above the threshold, which is an obligation on the article supplier.

5. Practical sourcing advice

Build the requirement into the technical file rather than into a purchase order note. Ask for a component-level material declaration with the quotation, and make the declaration a condition of approval. Specify the finish explicitly, including passivation type, and prefer trivalent chromium passivation or a nickel-free finish where skin contact is prolonged.

Ask the laboratory report to name the method and the pre-treatment. For nickel, that means the wear simulation procedure; for azo dyes, the extraction method; for coated tape, the polymer identification that justifies which plasticiser tests were run.

Keep a candidate list watch process. The list changes, and a statement that was accurate last year may not be accurate today. A simple routine, reviewing the list at each update and re-screening the components that contain the relevant material families, is enough for most zipper ranges.

Finally, align the REACH file with the customer's restricted substances list. Most brands layer their own limits on top of the legal ones, and the zipper supplier who can map its declarations to a customer RSL saves everyone a round of testing. When a limit is unclear, the correct answer is to refer to the standard text and the consolidated Annex, not to quote a number from a previous report.