Substances of Concern: What New EU Rules Mean for the Textile Industry

Why Substances of Concern Are Becoming a Global Priority

ESPR Article 2(27) defines a Substance of Concern as any substance that meets at least one of four criteria: 

• Identified as a Substance of Very High Concern (SVHC) under REACH.
• Classified for chronic human or environmental hazards under the EU CLP Regulation.
• Regulated under the Persistent Organic Pollutants (POP) Regulation.
• Known to negatively affect the reuse or recycling of materials in the product 

Today, more than 4600 substances fall within the ESPR definition. The number will rise further once new hazard classes for endocrine disruption, persistence, mobility, and bioaccumulation expand in 2026. 

Some PFAS substances already meet one or more of these criteria, which has increased regulatory attention on their use in textiles. You can learn more in our article on PFAS in clothing. 

These rules make chemical data foundational to sustainability and compliance. They shift the industry from voluntary best practice to mandatory transparency at both the company and product level. They also set a new global benchmark that other regions are likely to follow. 

How ESPR and CSRD Change Sustainability Requirements

Two EU frameworks further define what SOC related information must be disclosed and where:

ESPR: Product-level transformation

ESPR introduces mandatory sustainability requirements for almost all goods sold in the EU. For textiles, it requires:

• Identification and disclosure of all SoCs above relevant thresholds
• Integration of verified SoC data into Digital Product Passports
• The delegated act for textile apparel is expected to be published mid-2027

ESPR will also set requirements for durability, repairability, environmental performance, and recyclability, in addition to the management of Substances of Concern.

This places chemicals, design, and circularity at the center of product development.

CSRD: Company-level accountability

Under CSRD and ESRS E2 Pollution (based on the November 2025 version), companies must disclose information pertaining to SoCs or SVHCs. Entities active in the chemical sector shall report on the weight of SOCs and SVHCs procured, manufactured, placed on the market or emitted (into air, water and soil). Entities that manufacture, import or use articles containing SVHCs, mainly manufacturers and brands, must report on the names of such substances for those that are beyond the 0.1% concentration in articles or components that are procured or placed on the market. This is in line with the REACH regulation.

Examples of required disclosures for chemical producers include:

• Total amounts of SoCs or SVHCs manufactured
• Total amounts emitted to air, water, or soil

Together, ESPR and CSRD create a complete chain of accountability: from upstream chemical suppliers through manufacturers to finished products entering the EU market.

Why Traditional Chemical Data Is No Longer Enough

Most companies rely on Safety Data Sheets (SDS) that provide incomplete composition information. They rarely reveal full formulations, impurities, or detailed hazard profiles. As a result, many organizations may notcannot meet ESPR or CSRD expectations without a verified, standardized approach to chemical input management.

Meeting ESPR and CSRD requirements is non-negotiable for companies operating in the EU. The bluesign solution is designed to go further by supporting safer chemistry and responsible production beyond minimum compliance expectations.

How bluesign Supports Partners in Meeting SoC Requirements

bluesign enables companies to identify, manage, and report SoCs through verified chemical data, digital tools, and value chain collaboration.

Verified chemical input management

Every bluesign approved chemical product undergoes assessment for:

• Full composition transparency
• Hazard assessment
• Consumer safety risk assessment
• Worker Safety risk assessment
• Assessment of environmental fate
• SVHC assessment
• Assessment against regulatory requirements (e.g. REACh, POPs)

This ensures SoC identification is based on verified primary data, not assumptions. Chemical suppliers maintain ownership of their data and submit it through bluesign tools for independent verification.

Digital tools purpose-built for SoC traceability

bluesign provides a suite of tools that prepare partners for ESPR and CSRD reporting. 

Substance Navigator (bluesign Finder)
Helps users identify and flag SoCs within verified formulations. 

Chemical Inventory List (CIL)
Captures site-level chemical usage and SoC presence and can be aggregated for brand-level reporting. 

Impact Dashboard
Integrates SoC content, mass balance, and emissions data to support compliance and impact reporting. 

Example: Dimethylformamide (DMF) in footwear

Dimethylformamide (DMF) is a solvent commonly used in PU coatings for footwear materials. It is classified as toxic to reproduction and is therefore a Substance of Very High Concern. bluesign traces DMF from chemical suppliers through manufacturing to finished articles. This includes quantifying amounts present in materials and associated emissions. This type of verified primary data is essential for CSRD E2-5 disclosure and future Digital Product Passport entries.

Value Chain Collaboration Is Essential

Because SoCs must be tracked from chemical production to finished goods, collaboration across the supply chain is critical.

Chemical suppliers must provide full composition data and robust product stewardship.
Manufacturers and mills must maintain accurate CIL data and implement mass balance systems.
Brands and retailers must aggregate SoC information and disclose it in Digital Product Passports and corporate disclosures.

Many brands face additional challenges due to fragmented global supply chains and limited data access. Capacity building and harmonized digital systems help address these gaps.

Opportunities Ahead for the Textile Industry

Although the new regulations increase administrative and technical requirements, they also create opportunities. Companies that adopt verified data and clean input design early can: 

• Reduce risk and improve compliance readiness.
• Strengthen worker and consumer safety.
• Improve circularity by understanding chemical impacts on recyclability.
• Build trust through transparency.
• Gain a competitive advantage as regulatory expectations rise. 

With the multiplication of new regulations with unclear timelines, early action becomes a strategic priority. 

How bluesign Positions Partners for Long-Term Compliance and Innovation

The bluesign system provides a scalable, science-based infrastructure that supports both immediate reporting needs and long-term product transformation. Verified input data, digital tools, and value chain engagement prepare partners for a global future defined by transparency, clean chemistry, and circular product design.