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Clothing, textiles and footwear

Consumer goods

In short
Responsible person established in the Union under Article 16 GPSR

Who has to appoint one

Brands, importers and online sellers outside the Union placing clothing, home textiles or footwear on the EU market. A seller who puts its own brand on a garment is the manufacturer under GPSR. Print-on-demand and dropshipping models are fully caught, and the responsible person must be established in the Union.

Thresholds and exemptions

None. The fibre composition rules apply to any textile product with at least 80% textile fibres by weight, including linings and coverings, and there is no small-business exemption.

What must appear on the label

Fibre composition in descending order by percentage, using only the official fibre names in Annex I — 'cotton', not 'cotton-rich' — durably attached and legible. Manufacturer and responsible person details with an EU address, plus the product identifier and batch number under GPSR. Care instructions, which are not harmonised at EU level but are required in practice by several member states and expected by consumers. For footwear, pictograms or text identifying the materials of the upper, lining and insole, and the outer sole. Where children's clothing has cords or drawstrings, the relevant warnings.

Marketplace fields

Marketplaces check the responsible person block and, for children's clothing, screen for drawstring and small-parts risks. Fibre composition claims are also a consumer-protection matter, and mislabelled composition is one of the most common findings in national retail inspections.

Documentation you must hold

Technical documentation and risk analysis under GPSR. Fibre composition test results or supplier declarations backed by testing. REACH compliance evidence for restricted substances, in particular azo dyes that release listed aromatic amines, formaldehyde, nickel in fasteners, and chromium VI in leather. Records of complaints and corrective actions. For children's garments, the assessment against the cord and drawstring standard.

Standards and testing

Quantitative fibre analysis to verify composition. REACH Annex XVII screening for azo dyes, formaldehyde, chromium VI, cadmium, lead and nickel release from metal components in contact with skin. EN 14682 for cords and drawstrings on children's clothing. Flammability testing where nightwear or costumes are involved, which several member states regulate nationally.

Language requirements

Fibre composition must be given in the language of the member state where the product is made available, using the official fibre names in that language. Care and safety information likewise. Symbols alone are not sufficient for composition.

When it applies

Before the product is made available, including in the online listing where GPSR Article 19 requires the manufacturer and responsible person details to appear before purchase.

How long records are kept

Technical documentation for ten years from placing on the market, together with traceability records identifying suppliers and business customers.

What happens if you do not comply

Listing suppression, withdrawal, and fines for mislabelled fibre composition, which is treated as both a product and a consumer-protection infringement. Children's clothing with hazardous cords is regularly recalled and generates Safety Gate alerts naming the brand.

Who enforces it

National market surveillance and consumer protection authorities, customs at import, and in several member states dedicated textile labelling inspectorates.

Where the boundary lies

Children's fancy dress can be a toy rather than a textile, which changes the regime entirely and brings CE marking and EN 71 flammability testing. Protective clothing — high-visibility, cut-resistant, flame-retardant workwear — is PPE and needs type examination. Bedding and upholstery face national fire regulations that differ sharply, with the United Kingdom and Ireland historically the strictest and several member states now tightening.

Questions we are asked

Is 'Made in' mandatory?
Origin marking is not mandatory for textiles under EU-wide rules, but if you state an origin it must be accurate. Fibre composition, by contrast, is always mandatory.
Can we label in English only?
Only for Ireland and Malta. Every other member state requires the composition in its own official language, and this is checked in ordinary retail inspections.
Do we need testing or is a supplier declaration enough?
A declaration is acceptable evidence only if you can stand behind it. Authorities test the garment, and where the result differs from the label the seller is liable regardless of what the supplier said.
RP16 · from €190 / year

Who signs for you
EU representative Europe Services, SE — Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic
UK representative REP27 LTD — Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom

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