Shoes, footwear, insoles and shoe care

• Directive 94/11/EC — footwear labelling
• Regulation (EU) 2023/988 — GPSR
• Regulation (EC) No 1907/2006 — REACH
• Regulation (EU) 2016/425 for safety footwear

Who has to appoint one

Brands and sellers outside the Union placing footwear on the EU market. Safety and occupational footwear is PPE requiring type examination, while fashion footwear follows the labelling Directive and GPSR.

Thresholds and exemptions

None. The labelling Directive applies to all footwear intended for consumer sale.

What must appear on the label

Pictograms or written indications identifying the material of the upper, the lining and insole, and the outer sole, covering at least 80% of the surface. Manufacturer and responsible person details and batch identification under GPSR. Safety footwear carries CE marking, the notified body number, the protection category and the standard reference.

Marketplace fields

Marketplaces enforce the responsible person and, for safety footwear, the notified body number. Children's shoes with small decorative parts are checked for choking hazards.

Documentation you must hold

Technical documentation, risk analysis, REACH evidence for chromium VI, azo dyes and dimethylfumarate, and for safety footwear the EU type-examination certificate and the technical documentation.

Standards and testing

Chromium VI testing under REACH entry 47, azo dye testing, slip resistance where claimed, and for safety footwear EN ISO 20345 including toe cap impact, penetration resistance and antistatic properties.

Language requirements

Material information may be pictographic, but written indications and any warnings must be in the language of the member state of sale.

When it applies

Before the product is made available.

How long records are kept

Ten years.

What happens if you do not comply

Withdrawal for chromium VI, which produces Safety Gate alerts regularly, and fines for missing material labelling, which is a routine retail inspection item.

Who enforces it

Market surveillance authorities, notified bodies for safety footwear, and customs.

Where the boundary lies

Safety footwear is PPE with a notified body; fashion trainers marketed with protective claims can be reclassified. Children's shoes with attached decorations can fall under toy rules if the decoration has play value.

Questions we are asked

Is the material pictogram mandatory?

Yes, the footwear labelling Directive requires the upper, lining and insole, and outsole materials to be identified by pictogram or written indication.

Are safety shoes different?

Yes, they are Category II PPE requiring EU type-examination by a notified body under EN ISO 20345.