EU Sourcing Checklist: Verifying REACH, GRS and Labelling Compliance for Korean Recycled-Polyester Knit Fabric

Sourcing Korean recycled-polyester knit fabric for an EU activewear or athleisure brand means clearing one legal gate — REACH — and assembling one document chain before any goods ship. This checklist covers what to request from a Korean mill, what the chemical limits mean, and where suppliers most often leave a gap in the paperwork.

Does REACH Apply to Recycled Polyester? Yes — No Exemptions

A common assumption in sustainable sourcing is that recycled-content materials face lighter chemical scrutiny. Per ECHA, REACH (Regulation (EC) No 1907/2006) draws no distinction between virgin and recycled fibres. The same Substances of Very High Concern (SVHC) thresholds and Annex XVII restrictions apply. Recycled feedstock can carry restricted substances from its previous lifecycle, so it may require closer chemical inspection, not less.

No REACH exemption exists for recycled-polyester fabric

Recycled feedstock carries the same REACH obligations as virgin fibre

Per ECHA, REACH (Regulation (EC) No 1907/2006) applies identical SVHC and Annex XVII limits to recycled-polyester fabric and to virgin polyester. Recycled feedstock can carry legacy restricted substances from its previous lifecycle. When qualifying a Korean supplier, require a REACH test report dated within 12 months — not a waiver on the basis of recycled content.

When qualifying a Korean mill, your first pre-qualification step is: "Provide a REACH test report dated within 12 months." ECHA updates the Candidate List approximately twice a year, so older reports may not reflect current obligations.

The Chemical Limits to Confirm on the Supplier's Test Report

REACH Annex XVII sets hard numerical limits. Two entries are relevant to a recycled-polyester stretch knit worn against the skin.

NPE — Annex XVII entry 46a. Per Commission Regulation (EU) 2016/26, textile articles that can reasonably be expected to be washed in water may not enter the EU market from 3 February 2021 if NPE concentration equals or exceeds 0.01% by weight (100 mg/kg) in the article or any of its parts. Applies to products with at least 80% textile fibres.

Formaldehyde and CMR substances — Annex XVII entry 72. Per SATRA Technology, summarising Commission Regulation (EU) 2018/1513, entry 72 restricts 33 CMR (carcinogenic, mutagenic or reprotoxic, categories 1A/1B) substances in skin-contact textiles and clothing, in force from 1 November 2020. Formaldehyde maximum: 75 mg/kg.

REACH chemical limits to verify on the supplier's test report

	REACH rule (what the regulation requires)	What to ask your Korean supplier
NPE — Annex XVII entry 46a (Reg (EU) 2016/26)	≤ 100 mg/kg (0.01% w/w) in washable textiles with ≥80% textile fibres; in force from 3 February 2021	"Provide a REACH Annex XVII entry 46a NPE test result from an accredited lab, dated within 12 months"
Formaldehyde — Annex XVII entry 72 (Reg (EU) 2018/1513)	≤ 75 mg/kg in skin-contact textiles, clothing and accessories; in force from 1 November 2020	"Provide a REACH Annex XVII entry 72 formaldehyde test result from an accredited lab, dated within 12 months"
SVHC Candidate List — Article 33 communication duty	Above 0.1% w/w: duty to communicate substance name to supply-chain recipients; Candidate List updated approximately twice per year	"Provide a current SVHC screening report — confirm it reflects the Candidate List version from the past six months"

Also request an SVHC screening report. Per ECHA, REACH Article 33 requires suppliers to disclose Candidate List substances in articles above 0.1% w/w to supply-chain recipients, and on consumer request within 45 days. Since 5 January 2021, per ECHA, SCIP database notification is also required under the Waste Framework Directive (2008/98/EC) for articles containing a Candidate List substance above 0.1% w/w placed on the EU market.

OEKO-TEX Standard 100: Voluntary but Practically Expected

OEKO-TEX Standard 100 is not a legal requirement. REACH is the law. Most EU activewear sourcing teams request OEKO-TEX certification anyway — and the reason is practical.

Per OEKO-TEX, Standard 100 tests every component of a textile article against more than 1,000 regulated and potentially harmful substances, with limit values reviewed at least once a year covering REACH Annexes XVII and XIV and the ECHA SVHC Candidate List. One current certificate replaces a stack of substance-specific test reports and speeds your due diligence. Confirm the certificate covers the specific fabric ordered, is current, and verify the certificate number in the OEKO-TEX online database before sign-off.

GRS Documents: Exactly What to Request and When

If your brand will use the word "recycled" anywhere — a tag, a product page, a marketing deck — you need the full GRS document chain before the goods ship.

Per Textile Exchange, GRS chain of custody uses two instruments: a Scope Certificate, confirming the Korean mill is a certified GRS operation for the relevant product; and a Transaction Certificate (TC), confirming that the specific goods in a given shipment conform to GRS. At least 50% recycled content is required for consumer-facing GRS labelling; at least 20% for B2B certification. An 88% rPET knit clears both.

How an EU buyer verifies GRS chain of custody per order

1. 1

   Request the Scope Certificate

   Confirms the Korean mill holds a valid GRS Scope Certificate for the relevant product category. Verify the certificate number in the Textile Exchange certification database.

2. 2

   Confirm the recycled-content threshold

   ≥50% recycled content for consumer-facing GRS labelling; ≥20% for B2B certification. An 88% rPET knit clears both, but the TC must confirm it for each shipment.

3. 3

   Request a Transaction Certificate before each shipment

   The TC confirms that the specific goods in that order conform to GRS. One TC from the first trial order does not extend to future shipments — request a new TC each time.

4. 4

   File TCs to substantiate green claims

   Per EUR-Lex, Directive (EU) 2024/825 applies from 27 September 2026 and prohibits recycled-content claims not backed by a certified scheme. The TC per shipment is the evidence your brand needs.

Require a fresh TC for each order — one TC from your first trial shipment does not cover the next. Per EUR-Lex, Directive (EU) 2024/825, applicable from 27 September 2026, bans generic environmental claims not backed by a certification scheme and prohibits sustainability labels that are not based on such a scheme. A recycled-content claim without a current TC is exactly the type of unsubstantiated claim this Directive targets.

Fibre-Composition Labelling: Three Questions Before the Label Is Printed

A labelling error can halt a fully compliant, fully documented shipment at customs. Regulation (EU) No 1007/2011 applies whenever a textile product is made available on the EU market.

Per EUR-Lex, Article 14(1) requires fibre composition to be marked whenever the product is made available, with the label durable, legible, visible and securely attached. Article 5(1) restricts fibre names to those listed in Annex I; Article 9(1) requires all constituent fibres to appear in descending order by weight percentage. A manufacturing tolerance of up to 3% between stated and analysed composition is permitted (Article 20).

Confirm three things before label artwork is finalised: (1) fibre names use exactly the Annex I terms — not trade names; (2) composition is in descending weight order (88% recycled polyester first, then 12% elastane); (3) the label is in the official language(s) of the destination EU Member State. Per EUR-Lex, Article 15: where the manufacturer is not established in the EU, the importer assumes the legal labelling obligation — so getting accurate composition data from the Korean mill early is not optional.

EU-Korea FTA Duty: The Invoice Declaration, Not an EUR.1

If your Korean supplier mentions an EUR.1 certificate as preferential origin proof under the EU-Korea FTA, that is the wrong document — and using it can cost your company the duty preference.

Per the European Commission's Access2Markets, the EU-Korea FTA proves preferential origin through an origin declaration entered directly on the invoice or another commercial document. For consignments valued at EUR 6,000 or more, only an "approved exporter" authorised by Korean customs may make that declaration. Goods must also satisfy the FTA's product-specific rules of origin for textiles and clothing (HS Chapters 50-63).

On customs classification: per the European Commission's Taxation and Customs Union, knitted fabrics over 30 cm wide containing 5% or more of elastomeric yarn fall under HS heading 6004, and CN subheading 6004 10 00 covers fabrics with 5% or more elastomeric yarn but no rubber thread. Confirm the applicable duty and preferential rate in the live EU TARIC database for your exact code and shipment date — never assume from historical figures.

Supplier Pre-Qualification Checklist

The compliance rules for Korean recycled-polyester knit fabric entering the EU are well-defined. The risk is not the rules themselves — it is gaps in the document set when the shipment arrives at the EU border.

Supplier pre-qualification checklist before placing a trial order

• ✓ REACH test report (NPE + formaldehyde + SVHC)From an accredited lab, dated within 12 months. Must cover Annex XVII entry 46a (NPE ≤ 100 mg/kg), entry 72 (formaldehyde ≤ 75 mg/kg), and SVHC Candidate List screening at 0.1% w/w threshold.
• ✓ OEKO-TEX Standard 100 certificateVoluntary but expected by most EU activewear buyers. Confirm it covers the specific fabric ordered, is current, and verify the certificate number in the OEKO-TEX database.
• ✓ GRS Scope Certificate (mill-level)Confirms the Korean mill is a certified GRS operation for recycled-polyester fabric. Verify in the Textile Exchange certification database.
• ✓ GRS Transaction Certificate (per shipment)Must be issued for each order in which a recycled-content claim will be made. From 27 September 2026, Directive (EU) 2024/825 makes certification-backed documentation the standard for substantiating recycled claims.
• ✓ Fibre-composition data per Regulation (EU) No 1007/2011Annex I fibre names only, in descending order by weight percentage. Label in the official language(s) of the destination EU Member State. Legal obligation rests with the EU importer.
• ✓ EU-Korea FTA origin declaration readinessThe origin declaration goes on the invoice, not on an EUR.1 form. For consignments ≥ EUR 6,000 the Korean exporter must hold approved-exporter status from customs. Confirm this before the first shipment.

A supplier who cannot provide this complete set at first request needs more preparation time — or a deeper qualification review before you commit to a trial order.

Last updated: 2026-06. This checklist is for general information only. EU chemical, labelling and customs rules change. Confirm current requirements with ECHA, the European Commission, your accredited testing laboratory, and a qualified customs or regulatory professional before committing to a shipment.

Frequently Asked Questions

Does recycled-polyester knit fabric need REACH compliance in the EU?

Yes, fully. Per ECHA, REACH applies the same SVHC and Annex XVII limits to recycled-polyester fabric as to virgin polyester. Recycled feedstock can carry legacy restricted substances from its previous lifecycle — plan for the same REACH test set as virgin fabric, or a more thorough one.

Is OEKO-TEX Standard 100 a legal requirement for selling textile fabric in the EU?

No, it is voluntary. REACH is the legal requirement. OEKO-TEX Standard 100 provides consolidated documented evidence that a fabric meets or exceeds REACH chemical limits across more than 1,000 substances, reviewed annually. Per OEKO-TEX, its limits address REACH Annexes XVII and XIV and the ECHA Candidate List. Most EU activewear brands request it to simplify due diligence.

What is the difference between a GRS Scope Certificate and a Transaction Certificate?

Per Textile Exchange, a Scope Certificate confirms the Korean mill is GRS-certified for the product category — it proves the operation. A Transaction Certificate (TC) confirms that the specific goods in a particular shipment conform to GRS — it proves the order. You need both: the Scope Certificate to qualify the mill, and a fresh TC for every shipment in which you claim recycled content.

Who is legally responsible for the EU fibre-composition label when the manufacturer is in Korea?

The EU importer. Per EUR-Lex, Regulation (EU) No 1007/2011, Article 15 states that where the manufacturer is not established in the EU, the importer assumes the obligation to ensure the label is supplied and accurate. The Korean mill provides the Annex I composition data; your EU entity carries the legal labelling duty.

Why is EUR.1 the wrong document for EU-Korea FTA preferential origin?

EUR.1 is not used under the EU-Korea FTA. Per the European Commission's Access2Markets, preferential origin is declared on the invoice or another commercial document. For shipments valued at EUR 6,000 or more, only an "approved exporter" authorised by customs may make that declaration. Presenting an EUR.1 will not be accepted as valid FTA origin proof, and your importer will pay the full third-country duty rate.

References

• EUR-Lex — Regulation (EU) No 1007/2011 (Textile Labelling)
• EUR-Lex — Commission Regulation (EU) 2016/26 (REACH Annex XVII entry 46a, NPE)
• SATRA Technology — REACH Annex XVII Entry 72 (formaldehyde 75 mg/kg)
• ECHA — REACH Article 33 Communication in the Supply Chain
• ECHA — SCIP Database (Waste Framework Directive)
• OEKO-TEX — STANDARD 100
• Textile Exchange — Global Recycled Standard (GRS)
• European Commission — EU-South Korea Free Trade Agreement
• EUR-Lex — Directive (EU) 2024/825 (Empowering Consumers for the Green Transition)
• European Commission — EU Customs Tariff / TARIC (CN heading 6004)

Need help verifying your Korean recycled-polyester knit fabric supplier's compliance documents? Our trade team at exportservice.cloud/inquiry can walk you through the full pre-qualification set: REACH test reports (SVHC, NPE, formaldehyde), OEKO-TEX Standard 100 certificate, GRS Scope and Transaction Certificates, Annex I fibre-composition label data, and the EU-Korea FTA invoice origin declaration.