Navigating REACH, OEKO-TEX and GOTS: A Buyer's Guide

REACH, OEKO-TEX STANDARD 100 and GOTS answer different questions. REACH is chemical legislation with duties that depend on the product and the party placing it on the market. OEKO-TEX STANDARD 100 is voluntary certification for the products named in a certificate. GOTS is a textile standard with certification and transaction records for an organic-textile supply chain.

Treating the three names as a single compliance badge creates gaps. A chemical test report does not establish an organic claim. A GOTS scope certificate does not prove that a particular finished garment is within the certified chain. An OEKO-TEX certificate does not transfer automatically from one product, material or production run to another. The useful question is: what claim is being made, and which evidence supports that claim?

How do REACH, OEKO-TEX and GOTS differ?

They differ in status, scope and output. Start by separating a legal duty from a certification document. That prevents a supplier PDF from carrying more weight than its scope allows.

Framework	What it is	Main evidence to examine	What it does not establish on its own
REACH	EU chemicals legislation that can impose duties on actors handling substances, mixtures and articles	Applicable restriction, declaration, material information and any testing specified by the programme	A universal certificate for every garment or supplier
OEKO-TEX STANDARD 100	Voluntary product certification against the scheme's harmful-substances criteria	Current certificate number, named items, product class and certificate scope	Organic fibre content or a legal finding on every REACH duty
GOTS	A standard for organic fibres and defined environmental and social criteria in the textile supply chain	Scope certificates, transaction certificates and product records	A general chemical certificate for every non-GOTS product

The names can appear on the same style file. Their evidence still needs to be read separately. A buyer may need a chemical assurance file for the intended market, a STANDARD 100 certificate for a selected fabric or garment, and GOTS records for a product carrying an organic-textile claim.

What does REACH require for a garment programme?

REACH requires the relevant duty to be identified before evidence is collected. Clothing is an example of an article in ECHA guidance, and obligations connected with Candidate List substances can apply to producers, importers and suppliers of articles. The responsible party and exact duty depend on the article, its contents and the role it has in the supply chain.

Candidate List obligations are a clear example of why role matters. Where an article contains a Candidate List substance above the stated threshold, Article 33 communication duties apply to suppliers of articles. ECHA also describes notification conditions for article producers and importers. Neither rule says that every finished garment needs the same laboratory test or that a supplier certificate is a substitute for assessing the applicable requirement.

Compliance question	Working evidence	Why it belongs in the style file
Which requirement applies?	Market, product, material and buyer compliance specification	It defines the restriction or disclosure question to be checked
What materials were used?	Fabric and trim specifications, supplier declarations and chemical information	A garment result cannot be interpreted without knowing its components
Has the agreed check been completed?	Test report or assessment matched to the material, method, limit and date	A report on a different fabric, colour or lot may not support the delivered goods
What happens if the requirement changes?	Current requirement review and a controlled update to the specification	The legal list and product programme should not drift apart

REACH work is therefore a product-control exercise, not a logo exercise. Start with the buyer's market and restricted-substance specification, then make sure the material route, declarations and test plan answer that specification. A test report is useful only when its sample description, method and result can be matched to the bulk material being approved.

What does OEKO-TEX STANDARD 100 certify?

OEKO-TEX STANDARD 100 certifies the articles and components described within the certificate scope. It is voluntary, and it is product certification, not a blanket endorsement of a company or all of a facility's output. The scope is the document that tells a buyer what has been certified.

The scheme's standard describes the certificate scope as the product description that identifies the certified articles and components. It can specify product category, material composition, processed state and further details such as dyeing or printing. A certificate for a named fabric construction does not automatically cover another composition, finish or finished garment.

Product class	Typical use described by the scheme	Check alongside the certificate
I	Articles for babies and children up to 36 months	That the product belongs in the stated class and scope
II	Articles with direct contact to skin	Composition, finish and colour route
III	Articles without direct skin contact	Product type and certificate validity
IV	Decoration materials	Whether the component is the certified item

The product classes establish different testing conditions, with Product Class I carrying the strictest requirements. They do not make the class number a shorthand for suitability. Verify the certificate number through OEKO-TEX, read the scope, and compare it with the actual article, components and processes proposed for the order. Where a bulk material or colour route changes, check whether the existing certificate continues to describe it before using the certificate in the approval file.

What does GOTS evidence in a textile supply chain?

GOTS evidence is a chain of custody for GOTS Goods, supported by certificates with defined jobs. A scope certificate identifies the certified entity's approved activities and product categories. A transaction certificate identifies certified goods in a specific movement through the supply chain. Both matter when the finished product will carry a GOTS claim.

GOTS Version 8 states that processors, manufacturers, traders and retailers that demonstrate compliance with the relevant criteria receive a scope certificate from an Approved Certifier. It also states that scope certificates list the product categories and processing, manufacturing and trading activities covered. Read the certificate as a defined permission, including the legal entity, address, product category and activity, not as a general statement about every product handled by that business.

GOTS record	What to match	What it answers
Scope certificate	Entity, site, activity, product category, issuer and validity	Is this organisation certified for the stated activity and product category?
Transaction certificate	Seller, buyer, product description, quantity and shipment details	Does this movement of GOTS Goods have a traceability record?
Product and commercial records	Purchase order, invoice, delivery note and style reference	Do the certificate records describe the goods being bought?
Label approval record	Proposed claim, label grade and final product composition	Is the claim used on the product supported by the programme evidence?

The GOTS standard calls transaction certificates key enablers of traceability and transparency. It also requires certified entities purchasing GOTS Goods to receive and maintain scope and transaction certificates for the relevant goods, with invoices and delivery notes. This is why a single scope certificate at the garment stage cannot show the history of every material entering a GOTS order.

GOTS label grades also have defined fibre-content rules. The scheme describes the "Made with Organic materials" label grade as using at least 70% and up to 95% certified organic fibres. Do not rely on a fibre description in a quotation to decide the label. Check the current GOTS requirements and certificate trail against the proposed claim before artwork, labels and packing are approved.

Can one certificate cover REACH, OEKO-TEX and GOTS?

No. Each framework has its own scope and evidence. A current OEKO-TEX STANDARD 100 certificate may support the chemical assurance of the specific item it covers. It does not provide GOTS chain-of-custody evidence. GOTS records support a GOTS claim for the documented goods; they do not establish every market-specific chemical obligation. REACH compliance is assessed against the duty that applies to the product and actor.

This distinction matters when a style changes during development. A new print, coating, recycled-content claim, trim or fabric supplier can affect which document needs review. The working file should record the approved bill of materials, the claim being made, each evidence document, its scope and the person responsible for confirming any change.

A supplier's certificate can be a strong part of that file. It should not be the whole file. Combine it with the actual specification, material approvals and documents that identify the goods in the order. This follows the same discipline used to compare garment quotes: a document only has meaning when its assumptions are visible.

How should a buyer check the evidence pack?

Check identity, scope, time and product match before treating a document as evidence. The process is practical. Put the certificate or report beside the purchase order, bill of materials and approved sample. Then compare the named entity, address, product description, date, material and claim. A mismatch should be resolved while a material or label can still be changed.

Check	Questions to ask	Common mismatch
Identity	Does the legal entity and relevant site match the supplier and activity in the programme?	A valid document for a different site or business
Scope	Does it name the product, material, process or activity being relied on?	A certificate for a neighbouring product group or an earlier construction
Validity	Was it current at the relevant approval or supply point?	An expired certificate included as a PDF without review
Traceability	Do transaction and commercial records identify the supplied goods?	A chain record that cannot be connected to the order
Change control	Has a new fabric, colour, print, trim or claim triggered a review?	Bulk proceeding on evidence for the original sample only

Keep the record with the style, not only in a central certificate folder. During sampling, a lab dip, print strike-off, fabric substitution or revised composition can move the product outside the evidence already checked. A controlled comment sheet and versioned bill of materials make it easier to see which document needs to be re-read. The same approach supports a fuller sourcing programme, where material, sample and bulk approvals need to stay connected.

The check should also distinguish a required document from a useful supporting document. A buyer's compliance team may request declarations, test reports, scope certificates, transaction certificates or label approvals for different reasons. Give each record one job. That makes missing evidence visible before the shipment file is assembled.

When should certificates and tests be reviewed?

Review them at the point a decision changes the product or claim. A certificate copied into a folder at enquiry is an initial check, not the last check. Revisit the file when a material is approved, when a new component or process is introduced, when an organic claim is added, and before the final product is released.

For REACH, recheck the applicable requirement and the product information that supports it. For OEKO-TEX STANDARD 100, confirm the certificate remains current and within scope for the supplied article. For GOTS, follow the certificates and transaction records through the transfers that make up the certified supply chain. The work is controlled document review, not a request for a larger collection of logos.

An approval calendar helps. Build the evidence review into material booking, sample approval, labelling approval and final release. If an issue appears, record whether the solution is a material change, a new test, a corrected certificate, a revised claim or a decision not to use the claim. That is much easier to manage before bulk than after packaging has been printed.

Short FAQ

Does an OEKO-TEX STANDARD 100 certificate prove a garment is GOTS certified?

No. STANDARD 100 and GOTS are separate schemes with different scopes and records. Check GOTS scope and transaction certificates for a GOTS product claim.

Does a GOTS scope certificate cover every garment from the named business?

No. Check the entity, site, activities and product categories listed in the scope certificate, then match transaction and commercial records to the supplied goods.

Does REACH require the same test for every textile product?

No. The applicable duty and evidence depend on the product, its materials, the market requirement and the economic operator's role. Set the check against the actual product specification.

Should a buyer accept a certificate PDF without verification?

No. Verify the issuer, certificate number, validity and scope, then match the document to the product and supplier records for the order.

The evidence judgement

REACH, OEKO-TEX STANDARD 100 and GOTS should be used together only when the product and claim call for each one. REACH asks whether the applicable legal chemical duties have been met. OEKO-TEX STANDARD 100 supplies voluntary product certification within its defined scope. GOTS supports an organic-textile claim through certified entities and transaction records.

The strongest compliance file is not the one with the most certificates. It is the one where every document has a stated purpose, describes the goods being bought and remains current through the final approval. For the current certification groups used in our programmes, see our certifications.