REACH Annex XVII: The Restricted Substances List

Customs holds a container of children's textiles. The note gives one reason: azo dyes.

The importer has a test report, but it covers the wrong dye. Nobody checked which entry actually applied before the goods shipped.

That entry is a line in REACH Annex XVII. It is where REACH stops describing chemicals and starts drawing hard limits.

This guide covers what Annex XVII is, how a restriction is built, the entries importers hit most, and how it differs from the Candidate List.

What is REACH Annex XVII?

Annex XVII is the restriction list of REACH. It names substances that may not be made, sold, or used in the EU beyond set conditions.

The Candidate List is about disclosure. Annex XVII is about limits. This is the part of REACH with real teeth for finished goods.

It holds more than 70 entries, and it grows as the EU adds new restrictions. Each entry is its own small rule.

How a restriction is built

An Annex XVII entry is not just a banned chemical. It is a substance tied to a use and a limit.

Read any entry and you find three parts:

• The substance, or a group of them.
• The condition of use: which products or situations the rule covers.
• The limit: a concentration cap, a specific ban, or a labelling duty.

So the same substance can be fine in one product and banned in another. The use is half the rule.

That is why a blanket "is it restricted?" rarely has a yes or no answer until you name the product and the part.

The entries importers hit most

A handful of entries account for a large share of everyday restriction checks. If you import consumer goods, you will meet these.

• Entry 27, nickel. Limits nickel release from items in prolonged skin contact, such as jewellery, zips, and buttons.
• Entry 43, azo dyes. Bans certain azo colourants in textiles and leather that touch the skin.
• Entry 47, chromium VI. Caps chromium VI in leather articles that contact the skin.
• Entry 51, phthalates. Restricts certain phthalate plasticisers in toys and childcare articles, and in wider articles.
• Entry 77, formaldehyde. Limits formaldehyde released from a range of consumer articles, with the limits applying from 6 August 2026 under Regulation (EU) 2023/1464.

New entries keep arriving. A recent example is entry 79 on PFHxA, added by Regulation (EU) 2024/2462 as part of the wider EU move on PFAS chemicals.

Annex XVII vs the Candidate List

These two lists get mixed up constantly. They do different jobs.

The Candidate List flags substances of very high concern and triggers disclosure: tell your customers, answer consumers, notify SCIP. It does not ban anything.

Annex XVII sets a hard rule: a limit or a ban you cannot exceed. A substance can be on the Candidate List, restricted under Annex XVII, or both at once.

For an importer, that means two questions per part, not one. What must I disclose, and what am I not allowed to place on the market at all.

Where the code comes in

Annex XVII lines up with what you are actually shipping. Most entries are written around product types, textiles, leather, toys, jewellery, and those map to how goods are classified for customs.

That is the useful link. The HS or CN code you already assign for the tariff is a strong signal for which Annex XVII entries are worth checking for that product.

So classification is not only a duty question. It is also the fastest route to the restriction shortlist for a given part.

How Bindu handles Annex XVII

The work in Annex XVII is matching, the substance, the use, and the entry, for every part in a bill of materials.

Bindu screens each part against the Annex XVII limits that apply to it, alongside the Candidate List version of the day, and pins the result to a dated declaration that carries the entry and the statement a customs entry needs. Start with what is REACH for the full picture. See the REACH breakdown.

FAQ

What is REACH Annex XVII? Annex XVII is the restriction list of REACH. It sets limits and bans on specific substances in specific uses, covering substances on their own, in mixtures, and in finished articles placed on the EU market.

Source: ECHA: Substances restricted under REACH (Annex XVII)

How is Annex XVII different from the Candidate List? The Candidate List flags substances of very high concern and triggers disclosure duties, but does not ban them. Annex XVII sets a hard limit or ban. A substance can appear on both.

Source: ECHA: Candidate List of substances of very high concern

How many entries are in Annex XVII? There are more than 70 entries, and the list grows as the EU adopts new restrictions. Each entry ties a substance, or group of substances, to a condition of use and a limit.

Source: ECHA: Substances restricted under REACH (Annex XVII)

Which Annex XVII restrictions affect consumer goods most? Common ones include entry 27 on nickel release, entry 43 on azo dyes in textiles and leather, entry 47 on chromium VI in leather, entry 51 on phthalates in toys and articles, and entry 77 on formaldehyde.

Source: EUR-Lex: Regulation (EU) 2023/1464 (formaldehyde, Annex XVII entry 77)

How do I know which Annex XVII entries apply to my product? Start from what the product is and what it is made of. The product type and its HS or CN code point to the likely entries, then each part is checked against the substance limits in those entries.

Source: ECHA: Substances restricted under REACH (Annex XVII)