REFERENCES TO THE GCN RFID APP 

This register is organised in two parts: substances legally restricted or required to be disclosed under EU REACH, and substances GCN tracks on a voluntary basis because of emerging regulatory attention or recognised sensitisation concerns — brands can use both to inform their own disclosure choices, and sorters/recyclers can use this register to understand what a flagged item may contain.

The DPP Issuer uploads Upstream data that includes fibre-level certifications, dye and finishing details, and a tiered substances disclosure covering EU SVHC (REACH) compliance, restricted substances, and GCN's voluntary Substances of Concern register (a disclosed SVHC without linked evidence is flagged on the B2B record and in CSV exports for regulator review) — information that later helps sorters and recyclers divert items correctly. 

MANDATORY VS VOLUNTARY DISCLOSURE AVAILABLE ON GCN APP — how to read this register

Mandatory (EU REACH legal requirement): Substances of Very High Concern (SVHCs) on the ECHA Candidate List, when present above 0.1% weight-by-weight, must be disclosed by law under REACH Article 33. GCN's app reflects this as a mandatory compliance tick for any product entering the EU market.

PMT/vPvM (Persistent, Mobile, Toxic / very Persistent, very Mobile) become mandatory for all substances placed on the EU market from 1 November 2026. https://www.echa.europa.eu/substances-of-potential-concern

Voluntary (GCN-tracked, not currently legally mandated): everything else on this page — including the dye allergens below, PFAS, flame retardants, and finishing chemicals not yet subject to an EU-wide restriction — is tracked because it's either under active regulatory review, or recognised by dermatological/scientific bodies as worth disclosing, even though EU law doesn't yet require it. 

Brands can choose to disclose these voluntarily to consumers, sorters, and recyclers via the GCN platform.These substances are not currently SVHC-listed or restricted under EU REACH — they are legally usable in textiles. 

GCN lists them for voluntary self-disclosure because they are recognised by international dermatology bodies (e.g. Australia's AICIS evaluation EVA00166 (December 2025), as textile contact allergens warranting caution. Disclosure helps downstream sorters and recyclers make informed diversion decisions, and helps brands designing for sensitive-skin markets evidence their claims.

PFAS
Per- and polyfluoroalkyl substances (PFAS) — a large class of synthetic chemicals used in water-repellent and stain-resistant textile finishes, commonly based on C6/C8 fluorocarbon chemistry.

Regulatory status (as of mid-2026): PFAS in textiles is not yet subject to an EU-wide REACH restriction, but this is actively advancing. A broad PFAS restriction proposal — covering textiles among 22+ use sectors — has been under review by ECHA's scientific committees since 2023. ECHA's Risk Assessment Committee adopted its opinion in March 2026, and the Socio-Economic Analysis Committee opened a public consultation on its draft opinion shortly after. Final committee opinions are expected to reach the European Commission by the end of 2026, with any resulting Annex XVII restriction unlikely to take legal effect before 2029. A narrower, separate PFAS restriction (firefighting foams only) is already in force under a 2025 REACH Annex XVII amendment, but does not apply to general textile products.

GCN's approach: we track PFAS as a voluntary disclosure category now, ahead of the anticipated restriction, so brands already moving away from PFAS-based finishes can evidence this claim early.

Reference: ECHA PFAS restriction proposal

Flame retardants

What it covers: Brominated and other flame-retardant chemical classes sometimes applied to textile finishes, particularly in workwear, upholstery textiles, and children's sleepwear.

Regulatory status: certain flame retardants (including specific brominated compounds) are already restricted under REACH Annex XVII and the EU POPs Regulation, depending on the specific substance and use. Requirements vary by exact chemical and application — brands should confirm the current restriction status of any specific flame retardant against ECHA's published Annex XVII list before relying on this register alone.

GCN's approach: flame retardant use (and whether a flame-retardant-free alternative was used) is tracked as a voluntary disclosure field, supporting brands who want to evidence a flame-retardant-free claim or disclose usage transparently for downstream handling.

Finishing chemicals

What it covers: the broader category of chemistry applied during textile finishing — including azo dyes, formaldehyde-based finishing agents, and general coating/finishing chemistry not otherwise captured above.

Regulatory status: azo dyes capable of releasing certain restricted aromatic amines are already restricted under REACH Annex XVII. Formaldehyde use and emissions in textile articles are subject to existing REACH restrictions above defined thresholds. Beyond these specific, already-restricted substances, general finishing/coating chemistry is not currently subject to a unified EU disclosure requirement.

GCN's approach: consistent with the dye-allergen tiers below, we invite brands to voluntarily disclose finishing chemistry details — this supports sorters and recyclers making informed diversion decisions, and helps brands evidence low-impact or restricted-chemical-free claims.

SoC Tier 1 — most frequently documented contact allergens:
Disperse Blue 106 · Disperse Blue 124 · Disperse Orange 3 · Disperse Yellow 3

SoC Tier 2 — recognised, lower-frequency sensitisation concern:
Disperse Blue 82 · Disperse Blue 96 · Disperse Blue 102 · Disperse Blue 360

The register is reviewed as regulatory and dermatological evidence develops — substances that become SVHC-listed or restricted move up into GCN's mandatory disclosure tiers. New EU hazard classes for persistent, mobile and toxic substances (PMT/vPvM, mandatory from 1 November 2026) will be incorporated as classifications are published.