Planning to import and sell shoes and footwear in the European Union? In this article, we cover the basics of footwear compliance, including REACH, general safety requirements, EN standards, packaging regulations and more.
- Leather shoes
- Working shoes
- Casual shoes
- Hiking shoes
Personal Protective Equipment (PPE) Directive
If you are importing protective work footwear to the EU, then your products may fall under the scope of the PPE (Personal Protective Equipment) Directive.
According to the definition of the European Commission, Personal protective equipment (PPE) refers to “all equipment which is intended to be worn or otherwise used by a person at work and which protects the person against one or more hazards to his/her safety or health”.
PPE Lab Testing
To check whether the footwear products are compliant with the PPE directive, importers can contact an accredited third-party lab-testing company to perform a product assessment. Lab-testing companies can also help you access evaluate applicable EN standards.
PPE Testing Companies
A list of reputable third-party testing companies offering PPE compliance test can be found here:
- Bureau Veritas
Protective and work footwear manufactured outside the European Union are not made to comply with the requirements outlined in the PPE directive by default. Importers must, therefore, assess if the product is compliant before placing an order, and should also book lab testing for the sake of verifying compliance.
The PPE Directive requires that any personal protective equipment product carries CE marking. Importers should also self-issue a (DoC) Declaration of Conformity, user manual, and technical file.
Footwear Labeling Requirements
Directive 94/11/EC specifies that the labeling in footwear shall include information about the material contained in the upper part, the lining and socks and the outer sole of the footwear.
For the outer sole, only materials that account for 80% of the surface or the volume shall be mentioned. If no single material accounts for such a percentage, then the two main materials shall be mentioned.
The information can be communicated either in writing, for specific materials such as leather, textiles or others, or using the pictograms that can be found in the above-linked Directive.
If you are importing leather shoes to a member state of the EU, you should be concerned about the EU legislation for the leather products.
Even though currently there isn’t any unified EU legislation specific to the leather products industry, generally speaking, you are not allowed to make false claims about the quality or origin of the leather.
We recommend that you create a label file according to the current footwear labeling requirements and submit directly to your manufacturer. Don’t assume that even the most experienced footwear manufacturer in China or Vietnam stays up to date with EU footwear labeling rules.
The EU’s Regulation, Evaluation, Authorisation, and Restriction of Chemicals (REACH) regulation limits the levels of chemicals, particularly heavy metals and other pollutants, in consumer products of any type for the EU market, including footwear and packaging.
Footwear importers should pay attention to the materials used for the manufacturing of shoe products and the potentially hazardous materials they may contain.
It is illegal to sell any product with a concentration of any restricted substance above its allowed level.
These are some restricted substances that might commonly be found in shoes and footwear:
- Azo dyes
- Chromium VI
- Organostannic compounds (especially parts made of polyvinyl chloride, or PVC)
- Perfluorooctane sulfonate (PFOS)
Substances of Very High Concern (SVHC)
The EU updates the list of chemicals restricted by REACH, called SVHC (Substances of Very High Concern), annually. The third-party testing company you hire for product lab tests will refer to this list to decide which tests it needs to be performed so that you will not need to order the tests individually.
importers need to send their footwear product samples to third-party lab-testing companies for a complete REACH-compliance lab test.
In order to demonstrate the REACH-compliance of the footwear product, importers need to reach out to an internationally recognized third-party testing firm to conduct a comprehensive lab-tests on the products, such as SGS, Bureau Veritas, QIMA, or TUV.
Before you order the products, you must inform the manufacturer that the product will need to be REACH-compliant.
To avoid delays, the best strategy is to arrange for third-party testing in advance so that you can have the shipment tested as soon as it arrives in the EU.
Importers can order REACH compliance testing from either one of the firms below:
- Bureau Veritas
You can find more companies in this guide.
REACH compliance testing typically costs $500 per sample, the price can be much higher based on the materials, the number of items, colors and the components to be tested. It’s therefore rather costly to test shoes, sandals and other footwear, as they are normally made of numerous components and materials.
This guide provides additional details concerning REACH lab testing.
Materials used to manufacture shoes, sandals and other footwear are not necessarily REACH compliant by default. Synthetic fabrics, leather parts, zippers, buttons, and other parts may contain excessive amounts of chemicals and heavy metals. Most footwear manufacturers in China and Vietnam don’t have access to test reports for every single material and component used. As such, third-party lab testing is the only way to verify if your product is REACH compliant.
General Product Safety Directive (GPSD)
The General Product Safety Directive (GPSD) was first enacted for the purpose of regulating the safety of the products manufactured, imported, sold in the EU market, even those that are not covered by specific or mandatory EN standards or regulations. GPSD also covers footwear products sold in the EU.
Either the importer or the manufacturer (if it’s based in EU) is responsible for vouching for the GPSD compliance of the product after assessing its safety, considering all possible design flaws or risks to the consumer, including any young children or infants.
The above process should be fully documented in a risk assessment document.
Importers may also choose to hire a third-party safety inspection company to perform an assessment on footwear product safety.
Directive 94/62/EC: Packaging Regulations
European Parliament and Council executed directive 94/62/EC with the intent of regulating the use of chemicals in product packaging materials and the disposal of packaging waste. Directive 94/62/EC is also applicable to the footwear packaging sold in the EU market.
Click here to read the full content of the directive.
Heavy Metals Restrictions
Directive 94/62/EC requires that hazardous substances in the packaging, most notably heavy metals such as lead, mercury, and cadmium, must not exceed the required limit.
You will be required to contact a third-party lab to test for compliance. Labs that perform packaging materials testing include Intertek, SGS, TUV, and QIMA.
Additional Packaging Information
1. The structure of the packaging and choice of materials should readily lend themselves to the collection, reuse, and recycling.
2. Compliance marks and other required labels should be distinctively shown upon the packaging.