Requirements for Textile Products

EU Requirements: EU Regulation 1007/2011 (the "EU Textiles Regulation") regulates the sale of textiles in the EU. The requirements relate to textile fibre names, labelling of textile products, and methods of analysis to check information indicated on labels and marking.

If you sell textile products, you must comply with the requirements of the Textiles Regulation. You must also comply with any applicable national laws and regulations in Member States, which complement the EU Textiles Regulation.

Please see below for further information about EU requirements.

UK Requirements: Until the end of the Brexit transition period (31 December 2020), the EU Textiles Regulation regulates the sale of textiles in the UK. The requirements relate to textile fibre names, labelling of textile products, and methods of analysis to check information indicated on labels and marking.

After the end of the Brexit transition period (31 December 2020), an amended version of the EU Textiles Regulation will apply to the sale of textiles in the UK as a result of The Textile Products (Amendment) (EU Exit) Regulations 2018) (the "UK Regulation on Textiles"). Different rules apply to goods you sell in: (1) Great Britain (England, Scotland and Wales); and (2) Northern Ireland. We have noted below where there will be relevant changes in the UK requirements following the Brexit transition period.

It is your responsibility to comply with the UK requirements if you sell textile products. If you also sell textiles on Amazon EU website(s), then you must also comply with the EU Textiles Regulation and any other national requirements in the countries in which you sell these products.

Please see below for further information about UK requirements.

This material is for informational purposes. It is not intended as legal advice. We encourage you to consult your legal counsel for any concerns about the laws and regulations related to your product. This material only reflects the position at the date of writing and requirements in the EU and the UK may change – particularly in light of the developing position with Brexit. You should refer to current UK Brexit guidance about your products (see below) to learn more about changes that may affect you following the end of the transition period.

I. EU Requirements

What products do the EU requirements for textiles apply to?

The EU Textiles Regulation applies to products exclusively composed of textile fibres and listed products treated in the same way as textile products. Examples of textile products range from clothing to table mats, to belts, to ribbon, to artificial flowers.

Products to be treated the same way as textile products are:

• textiles incorporated into other products and forming an integral part of such products, where their composition is specified;
• products (or textile components as applicable) containing at least 80 % by weight of textile fibres;
• furniture, umbrellas and sunshade coverings containing at least 80% by weight of textile components; and
• textile components of mattress coverings, coverings of camping goods, and the upper layer of multi-floor coverings.

Who has obligations under the EU requirements for textiles?

The EU Textiles Regulation applies to the manufacturer of textile products. You are the manufacturer if you manufacture a product or have it designed or manufactured, or you sell it under your name or trademark.

If there is not an EU based manufacturer, importers will have obligations under the Textiles Regulation. You are an importer if you are established in the EU and you offer a product for sale or supply into the EU from a third country.

You are a distributor if you are not a manufacturer or importer, and you offer products for sale or supply in the EU. Distributors are treated as manufacturers for the purposes of the Textiles Regulation if they offer a product for sale under their name or trademark, attach the label themselves, or modify the content of the label.

What are the key obligations under the EU requirements for textiles?

Textile products must be labelled, marked, or accompanied with the required commercial documents in accordance with the EU Textiles Regulation. Some key examples of the requirements are outlined below.

Labelling and information

Manufacturers must ensure that textile products are accurately labelled or marked with an indication of their fibre composition in a durable, easily legible, visible, and accessible way. Any label must be securely attached. If the manufacturer is not established in the EU, this is the importer’s responsibility. Distributors must ensure that textile products bear the appropriate labelling, as required by the EU Textiles Regulation.

Certain products must follow specific labelling provisions that are set out in Annex IV of the EU Textiles Regulation. This includes particular corsetry products, etch-printed textiles, yarns, velvet and plush textiles (or textiles resembling velvet or plush), and floor coverings and carpets (where the backing and the use-surface are composed of different fibres).

Labelling must not be misleading and must be done in a way that a consumer can easily understand.

Labelling and markings must be in the official language(s) in which the product is sold. The exception to the language requirement is bobbins, reels, skeins, balls or other small quantities of sewing, mending, and embroidery yarns. Whenever these particular products are individually sold, they may be labelled or marked in any of the official languages of the institutions of the Union, provided they are also "inclusively labelled".

There are some exceptions to the labelling and marking requirements:

• Certain product types listed in Annex VI of the EU Textiles Regulation can use inclusive labelling (the use of a single label for several products or components) when they are of the same type and fibre composition. Examples include belts, shoe and bootlaces, ties and bow ties for children and handkerchiefs.
• Other product types listed in Annex V of the EU Textiles Regulation are not subject to mandatory labelling or marking requirments. Examples of such products include artificial flowers, gaiters, make-up cases, sleeve-supporting armbands, labels and badges, pin cushions and egg-cosy covers.

Further points to note regarding composition:

• The description of fibre composition of textile products must use the textile fibres listed in Annex I of the EU Textiles Regulation. For example, cotton is to be described as "fibre obtained from the bolls of the cotton plant (Gossypium)".

  Manufacturers, or someone acting on their behalf, can apply to the Commission to add a new textile fibre name to the list in Annex I of the EU Textiles Regulation. That application must be accompanied by a technical file (in accordance with the requirements of Annex II of the EU Textiles Regulation.

• The description ‘100%’, ‘pure’, or ‘all’ can be used only if a textile product is exclusively composed of the same fibre.
• The description 'fleece wool' or 'virgin wool' (and translations into equivalent Member State languages, per Annex III) can only be used if: (1) the product is composed exclusively of a wool fibre or (2) in respect of wool contained in a textile fibre mixture where such wool accounts for 25% of the total weight (and in the case of a scribbled mixture, where the wool is only mixed with one other fibre); provided in both (1) and (2) that the wool fibre:
  • has not previously been incorporated in a finished product,
  • has not been subjected to any spinning and/or felting processes other than those required in the manufacture of that product, and
  • has not been damaged by treatment or use.
• Textile products made of several fibres must be labelled or marked with the name and percentage by weight of all constituent fibres in descending order.
• The presence of non-textile parts of animal origin (for example, a leather strap on a bag made of fabric) in textile products must be indicated by the phrase ‘Contains non-textile parts of animal origin’.

Any other obligations?

Producers and distributors of textile products also have obligations under the General Product Safety Directive. Please refer to the information on the GPSD available on this page.

Additonal Information

We strongly encourage you to visit the European Commission’s website for more information on the requirements for textile products in the EU, including the following website:

• https://ec.europa.eu/growth/sectors/fashion/textiles-clothing_it
• https://ec.europa.eu/growth/sectors/fashion/textiles-clothing/legislation_it

II. UK Requirements

Where do the UK requirements for textiles apply?

The UK requirements for textiles apply to all products sold in the UK, but the provisions apply differently to Great Britain (England, Scotland and Wales, "GB") and Northern Ireland. You can read more about the position in Northern Ireland ("NI") below.

What products do the UK requirements for textiles apply to?

The UK requirements for textiles apply to products exclusively composed of textile fibres and listed products treated in the same way as textile products. Examples of textile products range from clothing to table mats, to belts, to ribbon, to artificial flowers.

Products to be treated the same way as textile products are:

• textiles incorporated into other products and forming an integral part of such products, where their composition is specified; and
• products (or textile components as applicable) containing at least 80% by weight of textile fibres, including:
  • furniture;
  • Umbrella;
  • sunshade coverings; and
  • textile components of mattress coverings, coverings of camping goods, and the upper layer of multi-floor coverings.

Products contracted out to persons working at home, to independent firms, or to self-employed tailors are excluded from the scope of the UK requirements for textile products.

Who has obligations under the UK requirements for textiles?

The UK requirements for textiles apply to the manufacturer of textile products. You are the manufacturer if you manufacture a product or have it designed or manufactured, or you sell it under your name or trademark.

Importers will have obligations under the UK requirements if:

• until the end of the Brexit transition period (31 December 2020), there is not an EU based manufacturer; or
• after the end of the Brexit transition period, there is not a UK based manufacturer.

You are an importer if:

• until the end of the Brexit transition period (31 December 2020), you are established in the EU and you offer a product for sale or supply into the EU from a third country; or
• after the end of the Brexit transition period, you are established in the UK and you offer a product for sale or supply into GB from a country outside the UK.

For details of importing into NI, see the "Northern Ireland" section below.

You are a distributor if you are not a manufacturer or importer, and you offer products for sale or supply in the UK (or EU, until the end of the Brexit transition period). Distributors are treated as manufacturers for the purposes of the UK requirements if they offer a product for sale under their name or trademark, attach the label themselves, or modify the content of the label.

What are the key obligations under the UK requirements for textiles?

Textile products must be labelled, marked, or accompanied with the required commercial documents in accordance with the UK requirements for textiles. Some key examples of the requirements are as follows:

Labelling and Information

Manufacturers must ensure that textile products are accurately labelled or marked with an indication of their fibre composition in a durable, easily legible, visible, and accessible way. Any label must be securely attached. If the manufacturer is not established in the EU (until the end of the Brexit transition period) or UK (after the end of the Brexit transition period), this is the importer’s responsibility. Distributors must ensure that textile products bear the appropriate labelling, as required by the relevant UK requirements for textiles. Labelling or marking must be in English.

Certain products must follow specific labelling provisions that are set out in Annex IV of the EU Textiles Regulation and UK Regulation on Textiles. This includes particular corsetry products, etch-printed textiles, yarns, velvet and plush textiles (or textiles resembling velvet or plush), and floor coverings and carpets (where the backing and the use-surface are composed of different fibres).

There are some exceptions to the labelling and marking requirements:

• Certain product types listed in Annex VI of the EU Textiles Regulation and UK Regulation on Textiles can use inclusive labelling (the use of a single label for several products or components) when they are of the same type and fibre composition. Examples include belts, shoe and bootlaces, ties and bow ties for children and handkerchiefs.
• Other product types listed in Annex V of the EU Textiles Regulation and UK Regulation on Textiles are not required to indicate the textile fibre names or fibre composition in labels and marking. Examples of such products include artificial flowers, gaiters, make-up cases, sleeve-supporting armbands, labels and badges, pin cushions and egg-cosy covers.

Further points to note regarding composition:

• The description of fibre composition of textile products must use the textile fibres listed in Annex I of the EU Textiles Regulation and the UK Regulation on Textiles. For example, cotton is to be described as "fibre obtained from the bolls of the cotton plant (Gossypium)".
• Manufacturers, or someone acting on their behalf, can apply to:
  • the Commission (until the end of the Brexit transition period), to add a new textile fibre name to the list in Annex I of the EU Textiles Regulation; or
  • the Secretary of State for the Department of Business, Energy and Industrial Strategy (after the end of the Brexit transition period), to add a new textile fibre name to the list in Annex 1 of the UK Regulation on Textiles.

  That application must be accompanied by a technical file (in accordance with the requirements of Annex II of the EU Textiles Regulation and UK Regulation on Textiles).

• The description '100%', 'pure', or 'all' can be used only if a textile product is exclusively composed of the same fibre.
• The description 'fleece wool' or 'virgin wool' can only be used if (1) the product is composed exclusively of a wool fibre or (2) in respect of wool contained in a textile fibre mixture where such wool accounts for 25% of the total weight (and in the case of a scribbled mixture, where the wool is only mixed with one other fibre); provided in both (1) and (2) that the wool fibre:
  • has not previously been incorporated in a finished product,
  • has not been subjected to any spinning and/or felting processes other than those required in the manufacture of that product, and
  • has not been damaged by treatment or use.
• Textile products made of several fibres must be labelled or marked with the name and percentage by weight of all constituent fibres in descending order.
• The presence of non-textile parts of animal origin (for example, a leather strap on a bag made of fabric) in textile products must be indicated by the phrase 'Contains non-textile parts of animal origin'.

Any other obligations?

Producers and distributors of textile products also have obligations under the UK’s General Product Safety Regulations 2005/1803 (GPSR). Please refer to the information on the GPSR available on this page.

Northern Ireland

Please note that different rules will apply in NI from 1 January 2021 as a result of the Northern Ireland Protocol. In particular:

• You should ensure that products meet EU requirements.
• You are an importer if you are established in the EU or NI and you sell products from a country outside of the EU and Northern Ireland (including from GB) into NI.

BREXIT: UK Government guidance

The UK Government has released guidance on UK requirements for textile labelling after 1 January 2021. This guidance provides information on the upcoming the changes that will affect businesses, namely:

• the responsibility of manufacturers and retailers for complying with labelling requirements; and
• the development of guidance for applications to register a new textile name of manufacturing tolerance.

We encourage you to review this guidance (linked below), alongside any other specific UK Government guidance that applies to your product. You should consult your legal counsel if you have questions about how the laws and regulations apply to your products from 1 January 2021.

Additional information

We strongly encourage you to review UK Government guidance for more information on the requirements for textile products in the UK, including the following website:

• https://www.gov.uk/government/publications/textile-products-labelling-and-fibre-composition-regulations-2012-guidance

The 14 August 2020 Brexit guidance referred to above can be found here:

• https://www.gov.uk/guidance/textile-labelling-from-1-january-2021

We also encourage you to visit the Business Companion website, which contains further guidance on UK product compliance rules:

• https://www.businesscompanion.info/en/get-started
• https://www.businesscompanion.info/en/quick-guides/goods/labelling-of-textiles