Planning to import clothing or textile products in the EU? In this guide, we introduce regulations and standards that importers or manufacturers placing clothing and textile products in the EU market should know. This includes REACH, the General Product Safety Directive, the Personal Protective Equipment Directive, and more.
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REACH: Chemicals & Heavy Metals
REACH regulates dangerous chemical substances in consumer products, including apparel and textiles. Hundreds of chemicals are used during the process of textile manufacturing, including substances that are deemed toxic and, as such, are restricted.
For example, phthalates might be used to improve the product’s brightness, and it is restricted by REACH. Therefore, it is essential to ensure that your products don’t contain substances above the prescribed limitations under REACH.
Does REACH apply to textiles?
Yes, REACH applies to consumer products in the European Union, including clothing and textile products.
What are the obligations of REACH regulation?
Here we listed the main sectors that are subjected to the REACH regulation:
a. A manufacturer in the EU that produces chemical substances, or products that contain any chemical substances
b. An importer based in the EU who buys chemical substances, or products from outside the EU that contain any chemical substances
c. A company or user who handles any chemicals in industrial or professional activity in the EU
Manufacturers and importers need to ensure that their products comply with REACH substances restrictions (e.g. substances listed on Annex XVII) and notification obligations (e.g. substances listed on the SVHC Candidate List).
Although REACH does not apply to countries outside the EU, it has become an international reference for other countries as well. For example, Switzerland is not part of the EU but they generally accept some EU regulations, including REACH.
How do I know which chemicals and heavy metals are restricted?
As already mentioned, Annex XVII and the SVHC Candidate List provided a list of restricted substances. In theory, you could take the time to read through these lists and make sure that your products do not contain any of the listed substances.
However, this is not practical. In many cases, it could be difficult even to know what chemical substances are contained in your products. A lab testing company can help to assess which chemicals, heavy metals, and pollutants to test for, and perform the relevant tests.
Hence, if you work with a lab, as an importer you don’t need to keep track of all substances that might be restricted.
What restricted substances are mostly commonly found in clothing and textiles products?
These are examples of restricted substances that are found in clothing and textile products:
a. Aromatic amines (from azo dyes, used to provide vibrant colors to textiles)
b. Formaldehyde (used to increase colorfastness and anti-wrinkle of the textiles)
c. Phthalates (might be found in plastic parts of the clothing or textiles, used to improve brightness)
d. Pentachlorophenol (PCP) (used as preservatives in the textiles)
e. Organotin compounds (used for anti-microbial function and to prevent unpleasant odors caused by sweat)
f. Alkylphenol ethoxylates (APEOs) (used as surfactant)
Is lab testing mandatory?
A REACH lab testing might not be mandatory for your products. However, failing to comply with its obligations can result in heavy penalties such as imprisonment, fines, or withdrawal of your products from the market.
In addition, regulatory compliance requirements could be difficult to follow as they might require knowledge and experience. For example, four new substances were added to the REACH SVHC Candidate List list in January 2021. Since regulations are updated on a non-regular basis, it’s not always easy to keep track of all the updates, including new substance restrictions.
Hence, it is recommended to get your products lab-tested, and obtain a valid test report for your products.
General Product Safety Directive (GPSD)
The General Product Safety Directive (GPSD) aims to ensure the general safety of consumer products before they can be placed in the EU market. The GPSD covers consumer products, including clothing and textile products. It includes safety, labeling, and documentation requirements.
By complying with harmonized standards, your clothing or textile products obtain a presumption of conformity with the technical requirements of the GPSD, for the aspects covered by the standard. Currently, there is only one harmonized standard for clothing under the GPSD:
EN 14682 Safety of children’s clothing — Cords and drawstrings on children’s clothing
When harmonized standards don’t exist, importers or manufacturers of clothing or textiles can still use other international or national standards such as:
a. EN 17394 Safety of children’s clothing – Security of attachment of buttons – Test method
b. EN 14878 Textiles – Burning behavior of children’s nightwear – Specification
The GPSD outlines several requirements for importers, manufacturers, or distributors selling their products in the EU, including the following:
- Creation and backup of the Risk Assessment Report
- Creation of the Technical File
- Provide traceability label
- Obtain test reports (if applicable)
- Creation of the user manual for the products (if applicable)
Clothing and Textiles EN Standards
In this section, we list EN standards that are relevant for clothing and textiles.
Children’s Clothing EN Standards
EN standards that are for children’s clothing include the following:
a. EN 14878 – Burning Behavior of Children’s Nightwear
b. EN 14682 – Safety of Children’s Clothing
c. EN 17394-1 – Textiles and Textile Products: Part 1 – Safety of children’s clothing – Security of attachment of attached components to infants’ clothing – Specification
d. EN 17394-2 – Textiles and Textile Products: Part 2 – Safety of children’s clothing – Security of attachment of buttons – Test method
e. EN 17394-3 – Textiles and Textile Products: Part 3: Safety of children’s clothing – Security of attachment of metal mechanically applied press fasteners – Test method
f. EN 17394-4 – Textiles and Textile Products: Part 4: Safety of children’s clothing – Security of attachment of components except buttons and metal mechanically applied press fasteners – Test method
Protective Clothing EN Standards
Protective clothing such as high visibility vests might be subjected to the Personal Protective Equipment (PPE) Regulation. Here are some examples of EN standards relevant for personal protective clothing:
a. EN ISO 20471: High Visibility Clothing Test Methods and Requirements
b. EN 1150: Protective Clothing. Visibility Clothing for Non-Professional Use
c. EN 342: Protective clothing – Ensembles and Garments for Protection Against Cold
d. EN 343: Waterproof and Breathable Protective Clothing
e. EN 531: Protective clothing for industrial workers exposed to heat (excluding firefighters’ and welders’ clothing)
f. EN 13034: Protective Clothing Against Liquid Chemicals
EN ISO 12952-1 – Textiles. Assessment of the ignitability of bedding items. Ignition source. Smoldering cigarette
EN ISO 12952-1 specifies test methods to assess the ignitability of bedding items when subjected to a smoldering cigarette. EN ISO 12952 covers the following bedding items:
- Mattress covers
- Incontinence sheets and pads
- Electric blankets
- Quilts (duvets)
- Pillows (whatever the filling)
EN ISO 12952 excludes mattresses, bed bases, and mattress pads.
EN ISO 12952-2 – Textiles. Assessment of the ignitability of bedding items. Part 2: Ignition source: match-flame equivalent
EN ISO 12952 specifies the test methods to assess the ignitability of all bedding items when subjected to match-flame equivalent. This part of the standard covers the same product scope as part one.
EN 13772 – Textiles and textile products. Burning behavior. Curtains and drapes. Measurement of the flame spread of vertically oriented specimens with large ignition source
EN 13772 specifies a test method to measure the spread of vertically oriented textile fabrics that are intended for curtains and drapes under the large ignition flame. These types of curtains and drapes are in the form of single or multi-component such as coated, quilted, multilayered, or other similar constructions.
Personal Protective Equipment Regulation
The Personal Protective Equipment (PPE) Regulation covers protective clothing used in work or residential environments to protect the users from chemical erosion, heat, electricity, or other types of hazards.
This regulation covers protective clothing or textile wear such as the following:
- Water-proof trousers
- Fire-proof clothing
- High visibility clothing
- Protective gloves
The PPE Regulation classifies personal protective equipment into three categories, according to the severity of the risk they are designed to protect from.
These are some requirements that importers or manufacturers of PPE products should follow before placing their products in the EU:
- Create a User Manual
- Create a Technical File
- Obtain Test Report
- Prepare a Declaration of Conformity (DoC)
- Affix CE marking label
- Provide product traceability label
PPE that is classified as either Category II or III requires the involvement of a Notified Body.
Textile Labeling and Fiber Composition Regulation
According to the Textile Labeling and Fiber Composition Regulation, products have to be labeled or marked whenever they are made available on the market. Here we summarize the required labeling information:
a. Fiber composition (e.g. 100% Polyester)
b. Non-textile parts of animal origin must be clearly specified (such as fur or leather)
c. The label should not contain abbreviations with the exception of mechanized processing codes
How do I know if my product is classified as a textile product
According to the regulation, “All products containing at least 80% by weight of textile fibres, including raw, semi-worked, worked, semi-manufactured, semi-made, and made-up products are covered by the Regulation”
As mentioned above, fiber content must be provided under the textile regulation. Here we listed some common fibers and attributes in the textile industry:
- Silk (smooth fabric finish with high shine)
- Wool (Warmth)
- Nylon (Durable, Strong, lightweight, dries quickly)
- Polyester (Durable, Strong, lightweight, dries quickly)
- Cotton (Lightweight, absorbent)
- Spandex (Elastic, strong, lightweight)
In general, textile products must carry a durable, legible, easily visible, and accessible label, either on the product or on its packaging. Take an example as a T-shirt. It is recommended to affix the label on the inner side of the product, towards the neck.
Sizes and Care Instructions
Harmonization of the size system is covered by the voluntary standard EN 13402 on the size designation of clothes. Even though sizes are not required by the regulation, it is still recommended to add them to the label.
Similar to sizes, care instructions are not mandatory under the textile regulation.
Country of Origin
In the European Union, there is no such obligation for providing the Country of Origin on the label. However, if you choose to state the Country of Origin on the label, it must not be misleading to consumers.
The information on the label should be written in the official languages of the EU country where the textile is marketed. For example, you should translate the label into the German language, if you plan to place your textiles products in Germany.
Clothing Lab Testing
Lab testing is often the only way to make sure that your clothing or textile products do not contain restricted or prohibited chemicals by the applicable regulations, such as formaldehyde, phthalates, and aromatic amines.
Lab testing is also necessary to ensure that your clothing or textile products comply with relevant standards such as EN 14682 – Safety of Children’s Clothing and EN 14878 – Burning Behavior of Children’s Nightwear.