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What to Expect from the EU’s efforts to Revise the Textile Labelling Regulation

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Illustration image - Garment Labelling Requirements Credits: FashionUnited

Brussels - Selected for their practical qualities and their visual appeal, textiles play a vital role in the daily lives of every citizen. Enhancing the efficiency, comfort, and appeal of various objects, textiles are essential components to various products such as furniture, clothing, or others, such as cars, and protective and medical gear.

However, this widespread use of textiles bears an important toll. Within the EU, it places considerable strain on resources such as land and water by, ultimately, significantly increasing greenhouse gas emissions and raw material consumption. Despite these tremendous obstacles, the textile industry continues to be a pillar of the European economy, employing more than 1.5 million individuals and playing a crucial role in the EU Single Market.

The legislative framework regulating this field is a key factor in driving forward the Union’s circular economy efforts. Due to these reasons, the European Commission is contemplating reviewing the current European legislation regarding the textile labelling. Based on the Union’s agenda on textiles, all textile products which are placed on the EU market must aim for durability, recyclability, and repairability.

Written by

Lucas Falco (Counsel) and Annea Bunjaku (Paralegal), EDSON LEGAL

The EU Strategy for Sustainable and Circular Textiles

Considering the significance the textile items have for the population in the Union, the Strategy for Sustainable and Circular textiles was published on 30 March 2022. In addition to the legislation already proposed, this green strategy aspires to secure a green and digital transition by touching also on social challenges. Adopting legally binding measures would facilitate the reduction of the environmental footprint of textiles throughout their life cycle. Moreover, it would also enhance the sector’s competitiveness in the internal and global market by ensuring higher binding standards. A crucial element of this strategy is the revision of existing legislation regulating textile labelling.

Anticipated Changes in the Textile Labelling Regulation

In the EU, textile products are currently regulated by Regulation 1007/2011 on Textile Labelling.3 Each textile product carries a label which clearly identifies the fibre composition, as well as the non-textile elements of animal origin. The current Regulation establishes minimum requirements for the labels, ensuring they meet standards for durability, visibility, and accessibility. The existing legislation is applicable to products containing at least 80 per cent by weight of textile fibres as well as certain textile components incorporated into other products.

In light of the continuous difficulties facing the textile industry and considering that the existing legislation has entered into force more than ten years ago, the European Commission is analysing whether the Regulation needs to be amended. In the textile industry, the Commission has identified (i) the fragmentation of the European Single Market, (ii) the information deficiency to consumers, and (iii) the sustainability of the sector as the three primary concerns.

The limited scope of the existing textile labelling legislation does not encompass information on the size and maintenance of products. The revision of the textile labelling rules is intended not only towards textile products but also other related products, such as leather and fur products of apparel, clothing accessories and interior household products. The revision excludes footwear in its scope of review since the footwear labelling is governed by a separate EU Directive.5 Due to the discrepancies throughout Member States, the Commission aims to provide for harmonised rules to decrease the compliance costs for companies and enhance information exchange to consumers.

Upon assessment, the European Commission may introduce additional compulsory disclosure information under the label regime. With the intention of increasing the circularity in the industry, it wants to create an expanded cradle-to-cradle information infrastructure, which surpasses the existing cradle-to-gate infrastructure. The Commission is exploring possibilities of including information such as sustainability or circularity parameters, the size of products, and where applicable, the country where manufacturing processes take place (“made in”). Further, the addition of allergenic substances present, leather and fur authenticity, and care labelling will be evaluated.

The introduction of digital labels is another obligation that the Commission is considering. Anchoring other EU legal rules such as the Digital Product Passport, the review will evaluate potential opportunities for introducing language-independent symbols or codes and a sustainability and circularity label. As the European Economic and Social Committee also states, digital labels are a vital solution for providing information to consumers in transmitting a clear text in different languages. On the other hand, as this Committee notes, the physical labels should be more difficult to be cut off from the product, this without compromising neither the information durability nor the functionality of the products.

The status of the revision

For the review to proceed, the European Commission will be supported by extensive evaluations and impact assessments. Stakeholders and citizens of the European Union will be actively involved in the public consultation process to address pre-identified issues, compliance costs and advantages.

The Commission opened a public consultation on 19 December 2023 to gather the views of industry and citizens on the need to change the EU Regulation on Textile Labelling. The consultation will end on 15 April 2024. Industry stakeholders are invited to provide their feedback and comments.

See consultation on the European Commission website 'Textile labelling rules (revision)', https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13872-Textile-labelling-rules-revision-/F_en

Depending on the input it receives from the consultation, the Commission will likely introduce a legislative proposal to amend the existing Regulation. By participating in the consultation, the fashion industry can play a crucial role in influencing the review and ultimately, the scope of the possible future rules.

Related reads:

Done in Brussels, 28 March 2024

Sources:
- European Commission, ‘Factsheet on Textiles’, 30 March 2022
- Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, ‘EU Strategy for Sustainable and Circular Textiles’, COM (2022), 30.03.2022 141 final.
- Regulation (EU) No 1007/2011 of the European Parliament and of the Council of 27 September 2011 on textile fibre names and related labelling and marking of the fibre composition of textile products and repealing Council Directive 73/44/EEC and Directives 96/73/EC and 2008/121/EC of the European Parliament and of the Council Text with EEA relevance (OJ L 272, 18.10.2011)
- Directive 94/11/EC of European Parliament and Council of 23 March 1994 on the approximation of the laws, regulations and administrative provisions of the Member States relating to the labelling of the materials used in the main components of footwear for sale to consumer, OJ L 100, 19.4.1994.
- European Economic and Social Committee website, EESC opinion: Revision of textile labelling Regulation

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