Two regulations decide whether a heated jacket can be sold in Europe, and they are routinely confused with each other. REACH governs the chemical substances inside the materials. RoHS governs hazardous substances inside the electrical parts. A heated garment contains both, so one product can need two separate sets of declarations, two different testing scopes, and two different answers when a retail buyer or a customs officer asks for proof.
This guide explains what each regulation actually covers, why the 0.1% threshold is misread more often than any other number in a compliance file, and which documents a brand should request before placing a bulk order.
Two Regulations, One Garment
A heated jacket is not one object in regulatory terms. It is an assembly of articles and electrical components, and each part answers to a different rule.
The shell fabric, lining, zips, labels and thread are articles in the REACH sense: objects whose function is determined by their shape rather than by their chemical composition. The battery pack, the controller board, the wiring and the charging port are electrical and electronic equipment, which puts them inside RoHS.
This split is the most useful thing to understand before opening a compliance file. A supplier that sends one certificate for the whole jacket is usually describing only half of it.
What REACH Actually Covers
REACH is the European framework for chemical substances. For apparel it matters at three levels.
The candidate list
Substances of Very High Concern are published on the ECHA candidate list, which is updated roughly twice a year, typically in January and June. A substance that was absent from your last test report may be on the list today, so a compliance file carries a date and an old report proves very little.
Communication down the supply chain
If an article contains a candidate-list substance above 0.1% by weight, the supplier has a duty to tell the recipient, and a consumer can ask and must be answered within 45 days. In practice the fabric mill or trim supplier has to pass that information down, and the brand has to be ready to pass it on.
Restrictions on specific uses
Separately from the candidate list, REACH restricts or bans named substances in named uses: certain azo dyes, nickel release from metal parts, and polycyclic aromatic hydrocarbons in rubber or plastic that touches skin. For heated apparel the contact points are what matter, meaning cuffs, collars, waistbands and anything held against the skin for hours.
What RoHS Actually Covers
RoHS restricts ten substances in electrical and electronic equipment: lead, mercury, cadmium, hexavalent chromium, two brominated flame retardants and four phthalates. The RoHS Directive sets the limit at 0.1% by weight for nine of them, and 0.01% for cadmium.
The regulation does not judge the finished jacket. It judges each homogeneous material, meaning a material of uniform composition that cannot be mechanically separated into different materials. A solder joint, a wire insulation, a plated connector pin and a plastic housing are four separate materials, and each is assessed on its own.
This is where heated apparel gets complicated. The battery pack may carry its own evidence from the cell or pack maker, the controller board carries another, and the wiring harness carries a third. If any supplier in that chain has switched to cheaper solder or recycled plastic, the finished jacket fails even when every other part is clean.
REACH vs RoHS: Side-by-Side
| Dimension | REACH | RoHS |
|---|---|---|
| What it regulates | Chemical substances in articles and mixtures | Ten restricted substances in electrical and electronic equipment |
| Which part of a heated jacket | Shell, lining, trims, thread, labels, coatings | Battery pack, controller, wiring, connectors, charging port |
| How the 0.1% is calculated | Against the weight of the article | Against the weight of each homogeneous material |
| Who supplies the evidence | Fabric mill, trim supplier, dyehouse | Cell maker, PCBA supplier, cable supplier |
| Where it usually fails | Azo dyes, nickel release, PAHs at skin contact | Solder, PVC insulation, plated pins, recycled plastics |
The 0.1% Threshold and Why It Is Misread
The same number means two different things in the two regulations, and mixing them up is the most common error we see in buyer questionnaires.
Under RoHS, 0.1% is measured against each homogeneous material. A brass zip pull weighing two grams is assessed on its own, not against the eight hundred grams of the finished jacket.
Under REACH, the 0.1% for candidate-list substances is measured against the weight of the article. For an assembled product the assessment is normally made per article as supplied, which is why a supplier may legitimately report that a substance is present but below the threshold in the component where it sits.
Neither calculation can be replaced by the sentence “we tested the whole garment and it passed”. A whole-garment test dilutes everything, and a restricted substance concentrated in a five-gram zip can vanish into a result expressed against the entire product.
What Documents a Buyer Should Request
- A dated SVHC declaration per material, naming the candidate-list version it was checked against
- A RoHS declaration per electrical component, not per finished product
- Full material declarations for the parts most likely to change: solder, wire insulation, plated hardware
- The laboratory report behind each declaration, with the lab name and the sample description
- A clear statement of who holds the obligation, whether mill, component maker or assembler
Ask for every document in the name of the company that actually made the part. A declaration issued by a trading company for fabric it buys in is worth far less than one from the dyehouse itself.
Where Heated Apparel Usually Fails
Across heated garments, the same five points cause most problems.
- Dyed and printed shell fabrics. Certain azo dyes remain restricted, and recycled polyester brings in a supply chain the brand often cannot trace.
- PVC instead of TPU. PVC insulation and PVC trim can carry phthalate restrictions that TPU does not.
- Solder on the controller board. Lead-free is standard now, but repair and rework stations are where non-compliant solder quietly reappears.
- Plated hardware. Nickel release from zips, snaps and eyelets matters because these parts sit against skin.
- Recycled or regrind plastics. The cost saving is real, and so is the variability in what went into the regrind.
None of these are exotic failures. They are the ordinary result of a supply chain that optimises cost at every step while nobody owns the compliance question across the whole product.
How We Handle Material Compliance
We build heating elements, control systems and battery packs in-house, which removes most of the hand-offs where declarations go missing. Materials are specified with the compliance requirement attached rather than checked afterwards: a fabric is approved with its SVHC declaration, a wire is approved with its RoHS evidence, and a component without either does not enter production.
Where a customer needs market-specific documentation, the file is assembled against the target market instead of being compiled once and reused. Europe and North America ask different questions, and our guide to certifications for the US and EU market covers that split in more detail.
For the wider picture of how material rules sit alongside electrical, battery and labelling requirements, start with the full certification overview and our certifications page. We have been manufacturing electrically heated products since 2013.
Frequently Asked Questions
Is heated clothing covered by RoHS?
Yes, in most cases. A heated garment with a battery, a controller and wiring is treated as electrical and electronic equipment, so its electrical parts fall under RoHS. The fabric and trims do not, because those are covered by REACH instead. That is why a single certificate for the whole jacket is normally incomplete.
What is the difference between the 0.1% limits in REACH and RoHS?
They are measured against different things. RoHS applies 0.1% to each homogeneous material, so a small plated pin is judged on its own. REACH applies 0.1% to the weight of the article for candidate-list substances. Using one calculation to answer the other question is the most common mistake in compliance files.
How often does the REACH candidate list change?
Roughly twice a year, typically in January and June. A test report is only a snapshot of the list at the date it was issued, which is why every declaration should carry a date and the list version it was checked against.
What should a brand ask a heated apparel factory for?
A dated SVHC declaration per material, a RoHS declaration per electrical component, full material declarations for solder, insulation and plated hardware, and the laboratory report behind each declaration. Ask for them in the name of the company that made the part.
Preparing a compliance file? See how our OEM/ODM process handles material and electrical documentation, or send us your target market and we will tell you exactly which documents your product needs.
