Textile and Apparel Market Report - European Union
European Union
Market Report
Textiles, Apparel, Footwear, and Travel Goods
The following information is provided only as a guide and should be confirmed with the appropriate overseas market authorities before embarking on any export activities.
OFFICE OF TEXTILES AND APPAREL (OTEXA)
Import Tariff and Customs Requirements
The European Union (EU) is a customs union that provides for free trade among its 27 member states—Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Croatia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, The Netherlands, Poland, Portugal, Romania, Slovak Republic, Slovenia, Spain, and Sweden. The United Kingdom (UK) formally left the EU on January 31, 2020.
EU members apply a common customs tariff (CCT) to goods imported from non-EU countries, such as the United States. The Tarif Intégré de la Communauté (TARIC) provides CCT rates, as well as the various rules applying to specific products imported into the EU.
Value added tax (VAT) rates vary by individual EU member country. In general, standard VAT rates are charged on clothing, household linens, and footwear. Reduced rates may be applicable in certain member countries for children’s clothing. For more details, see the Europa-Taxation and Customs Union website.
Additional Duties on Imports from the United States
- Effective May 1, 2022, the EU will apply an additional duty of 0.001% on imports from the United States of women’s or girls’ cotton denim trousers and breeches (excl. industrial & occupational, bib and brace overalls), classified in EU CN code 6204.62.31 (Regulation (EU) 2022/682). The current additional EU duty is effective until April 30, 2023.
For more information on the EU’s tariff rates, see OTEXA’s Foreign Market Reports page.
Import Bans and Restrictions
The use of endangered species of animals and plants or parts products is restricted by the EU wildlife regulatory measures EC 338/97, which is based on the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). The use of some species of animals and plants is prohibited in apparel, others are subject to import restrictions.
The EU Ban on Fur from Animals Caught in Leghold Traps includes imports of fur and fur products of certain species from countries that either do not ban leghold traps or do not conform their trapping practices to internationally agreed humane trapping standards. The United States agreement with the EU on humane trapping standards permits access of authorized U.S.-sourced fur and fur-products to the European market.
Regulation 1523/2007 bans trade in cat and dog fur, making it illegal to import, export, and/or place on the EU market, fur from cats and dogs and articles containing fur from such animals.
See additional customs and import regulation information in the Country Commercial Guide for the EU, or for information relevant to a member state, see the EU Member States’ Country Commercial Guides.
Standards
The EU will be putting forward several pieces of legislation in 2022 to achieve its circular economy transition. One initiative, the Sustainable Products Initiative (SPI) will focus on “key product value chains” (including textiles) that the Commission sees as requiring “urgent, comprehensive and coordinated action” to jumpstart the transition to circularity. The EU Strategy for Sustainable and Circular Textiles was published on March 30, 2022. For more information, see the EU Strategy for Sustainable Textiles webpage. For information on how U.S. businesses can engage with the EU on circular economy, U.S. Commercial Service-EU market intelligence article.
Products tested and certified in the United States are likely to have to be retested and re-certified to EU requirements due to the EU’s different approach to the protection of the health and safety of consumers and the environment. Where products are not regulated by specific EU technical legislation, they are subject to the EU’s General Product Safety Directive (GPSD), as well as to possible additional national (i.e., specific EU member country) requirements.
Chemical Restrictions
Registration, Evaluation and Authorization and Restriction of Chemicals (REACH) is the EU regulation governing the manufacture and import of chemical substances. It also applies in Iceland, Lichtenstein, and Norway. The U.S. Commercial Service REACH webpage is designed to assist U.S. exporters in identifying their obligations under REACH so they can take the necessary steps to ensure compliance with this regulation.
Restricted chemicals & dangerous substances under Annex XVll of REACH, affecting textile, apparel, and footwear products include:
- Lead
- Cadmium
- Azo Colourants (Dyes & Pigments)
- Dimethyl Fumarate (DMF)
- Nickel
- Polycyclic Aromatic Hydrocarbons (PAHs)
- Pentachlorophenol (PCP)
- Chromium VI
- Phthalates (in toy and childcare products)
The European Committee for Standardization (CEN-Comite Européen de Normalisation) has published technical report, PD CEN/TR 16417:2016-Footwear industry guidelines for substances of very high concern (Annex XIV of REACH) that may help footwear manufacturers collect mandatory information from suppliers regarding the content of these chemicals and assist manufacturers in providing accurate information to their customers.
Regulation (EU) 2018/1513 covers restrictions on certain carcinogenic, mutagenic, or toxic for reproduction (CMR) substances in certain apparel, footwear, and other textile consumer products. An Explanatory Guide on the Restriction on CMRs 1a and 1b in Textiles and Clothing provides lists of products covered and not covered by the restriction, as well as available analytical methods for determining CMR substance levels. Note that Regulation (EU) 2018/1513 contains a less stringent limit of 300 mg/kg for formaldehyde in jackets, coats, or upholstery for the period of November 1, 2020 to November 1, 2023. After this period, the more stringent limit of 75mg/kg will apply for formaldehyde content.
Some EU member countries may have additional national regulations on specific chemicals as follows: Austria, Finland, Germany, Norway and the Netherlands - formaldehyde; Austria, Denmark, Germany, and the Netherlands - PCP; and Germany - disperse dyes.
Children’s Clothing
Cen TR 16792:2014-Safety of Children’s Clothing – Recommendations for the Design and Manufacture of Children’s Clothing – Mechanical Hazards recommends methods of making children’s garments avoiding certain hazards that may pose a risk to the wearer’s safety. Also see CEN/TS 17394:2020 related to the security of attached components, such as buttons and other small parts. Spain’s national standard, UNE 40902:2020-Safety of baby clothing (physical and mechanical properties) should also be considered.
EN 14682:2014-Safety of Children’s Clothing – Cords & Drawstrings on Children’s Clothing - Specifications specifies requirements for cords and drawstrings on children’s clothing, including costumes and skiwear, up to the age of 14. As EN 14682:2014 is a harmonized standard that is directly referenced by the GSPD, it is mandatory in all EU member states. See CEN/TR 17376:2019 - Guidance on the Use of EN 14682:2014-Cords and Drawstrings on Children’s Clothing, to assist in ensuring that children’s garments put on the market are safe and compliant. For more information, see the European Commission webpage on European standard EN 14682.
Noncompliance to EN 14682:2014 is a major reason for product notifications/recalls in the EU Safety Gate - Rapid Alert System for dangerous non-food products. It should be noted that there are differences between the EU and U.S. cord and drawstring requirements, such as the clothing sizes and the length of cords regulated.
EN 16732:2014-Specification for Slide Fasteners (Zips) include specific requirements for zippers on children’s clothing and other textile products, such as sleeping bags, mattresses, and pillows.
Flammability
Nightwear and Other Apparel
There are no specific textile/apparel flammability requirements at the EU level. However, the use of voluntary European standard, EN 14878:2007-Burning Behaviour of Children’s Nightwear - Specification helps in complying with the GPSD. EN 1103-Fabric for Apparel-Detailed Procedure for Determination of the Burning Behaviour contains test requirements that enable various categories of nightwear to be classified, as well as information about garment design.
In the Netherlands, technical and labeling requirements on the flammability of clothing are provided in the Covenant Fire Safety of Nightwear and referred to in the Enforcement Agreements regarding the fire safety of clothing. The Dutch requirements apply to two types of clothing: nightwear and clothing other than nightwear.
Other EU member countries (e.g., Ireland and Sweden) also may have national flammability regulations. Care should be taken to ensure that products meet the EU, as well as applicable national requirements. Although the requirements may be similar, there may be differences in product coverage, e.g., some national laws include clothing other that nightwear. Also, test methods and labeling requirements/instructions may differ. In Portugal and Lithuania, national flammability regulations apply to workwear in professions at risk, such as fire-fighters.
Note: The use of flame-retardant chemicals in apparel and other textile products must conform with the REACH regulations.
Upholstered Furniture and Home Furnishings
Upholstered furniture—including mattresses—are not subject to harmonized European legislation. Most EU member states have no regulations imposing fire safety requirements for the production or sale of residential furniture. Some member states apply EN 1021:2014-Furniture-Assessment of the ignitability of upholstered furniture. Ireland has national regulations for specific requirements and test methods—S.I. No. 316:1995-Industrial Research and Standards (Fire Safety) (Domestic Furniture) Order, 1995. Office furniture and furniture for commercial/contract markets are often subject to different standards and fire safety regulations.
Some European standards for mattress flammability include:
- EN 597-1:2015-Furniture-Assessment of the ignitability of mattresses and upholstered bed bases - Part 1: Ignition source: Smoldering cigarette
- EN 597-2:2015-Furniture-Assessment of the ignitability of mattresses and upholstered bed bases - Part 2: Ignition source: Match flame equivalent
France has the following mandatory testing and labeling for bedding:
- EN ISO 12952-1:2010-Textiles – Assessment of the ignitability of bedding
- French Decree No 2000-164 of the 23 February 2000 on the safety of bedding articles.
Note that children’s bedding is also subject to child safety requirements.
CE Mark
Many products require the CE Mark indicating that they have been assessed by the manufacturer and meet the essential health and safety requirements covered in the CE Mark Directives and Regulations. Unfortunately, there is no comprehensive list of the products requiring CE marking. It is the manufacturer’s responsibility to determine if a product requires a CE mark from various directives issued by the European Commission. Certain textile, apparel, and footwear products are subject to CE marking and certification under the following EU directives: Safety of Toys, Medical Devices, Construction Products, and Personal Protective Equipment (see the European Commission’s Sector webpages). For more information, see the EU Legislation and CE Marking section in the Country Commercial Guide for the EU.
Personal Protective Equipment
Regulation (EU) 2016/425 - Personal Protective Equipment (PPE) Directive covers clothing and footwear designed to be worn by individuals for protection against health and safety hazards and is intended to ensure that any personal protective equipment placed on the EU market meets its intended purpose. The attachment of the CE Mark to PPE is required as a visible indication that the product conforms with the PPE health and safety requirements. For more information, see the European Commission’s Mechanical Engineering-Personal Protective Equipment webpage.
Note that UV Protective clothing is considered as Category 1 PPE under the scope of the EU Regulation 2016/425. Any clothing including hats, gloves, and swimwear that includes a claim to protect the wearer’s skin from the sun must be CE marked as PPE. Reportedly, manufacturers and retailers in Europe test and classify these items according to BS EN 13758-Textile – Solar UV Protective Properties. The designated pictogram of a sun with the CEN reference number and the number “40+” can be attached to the garment if it complies with the Ultraviolet Protection Factor (UPF), which must be at least 40, and fulfill certain design requirements as specified in the standard.
Under the PPE, footwear is divided into three classes, depending on the intended use, and the associated performance specifications are provided in the following standards:
- EN ISO 20345 for safety footwear
- EN ISO 20346 for protective footwear
- EN ISO 20347 for occupational footwear
Additional standards exist for footwear used in other high-risk activities, such as those of chainsaw operators and motorcyclists.
Note that oven mitts and potholders are considered PPE and must be CE marked.
Residential and Commercial/Contract Furnishings
Floor Covering
Carpeting sold in the EU must be CE marked, as required under the Construction Products Directive (89/106/EEC). Under the directive, materials intended for construction must comply with health, safety, and environmental requirements as follows: mechanical strength and stability; fire safety; hygiene, health, and environment; safety of use; sound nuisance; and energy savings and heat retention. A construction product is defined as any product that is produced for incorporation in a permanent manner in a construction project. Thus, various other textile products could be covered. For more information, see the European Commission’s Construction Products webpage.
Internal Blinds and Corded Window Coverings
Under Commission implementing Decision 2014/531/EU, compliance with the European standards listed below meet the GPSD regarding risks posed to children by internal blinds and corded window coverings:
- EN 16433:2014-Internal blinds-Protection from strangulation hazards – Test methods
- EN 16434:2014-Internal blinds-Protection from strangulation hazards – Requirements and test methods for safety devices
- EN 13120:2009+A1:2014-Internal blinds – performance requirements including safety. Clause 8.2 Protection from strangulation and clause 15 Information for installation, use and maintenance
Cosmetotextile Regulations
Cosmetotextiles, which include textile products that release a cosmetic substance from a microcapsule on to the human body, represent a growing field for smart textiles in the beauty and fashion industries. Technical report, PD CEN/TR 15917:2009-Textiles, Cosmetotextiles addresses the product safety of this technology in Europe. Cosmetotextiles must conform to the requirements of the Cosmetics Regulation (EC) No 1223/2009, which is the main regulatory framework for finished cosmetic products when placed on the EU market, as well as the governing textile regulations to guarantee safety and efficacy to the consumer. For more information, see the European Commission’s Cosmetics webpage.
Examples of cosmetotextile products include:
- Slimming preparations: pantyhose, underwear, trousers
- Moisturizing preparations: pantyhose, underwear, T-shirts
- Refreshing preparations: house linen (bedsheets)
Biocidal Regulations
Whenever biocidal products are added to textiles, apparel, or footwear to give them specific properties (e.g., repel insects or avoid allergens) the provisions of the Biocidal Products Regulation (BPR) – EU 528/2012 must be followed and the products may need to be labeled. As under REACH, the BPR permits consumers to request that suppliers of treated articles provide information on the biocidal treatment. For more information, see the European Commission’s Biocides webpage.
For up-to-date information on dangerous products found in the EU/EEA member states and the UK markets, see the Safety Gate - Rapid Alert System for dangerous non-food products.
See the European Commission’s webpage on Standards and risks for specific products for more information related to various textile, apparel, and footwear products.
For more information on national standards, accreditation bodies, national testing organizations, and conformity assessment bodies, see the section on Standards for Trade in the Country Commercial Guide for the EU, or for information relevant to a member state, see the EU Member States’ Country Commercial Guides.
Labeling
EU member countries have varying regulations pertaining to the marking, labeling, and packaging of products. There is no one EU-wide law covering all of the various labeling requirements. Also, EU member states generally specify that the national language be used on the label.
Textile and apparel products
Textile and apparel products placed on the EU market must have a label clearly identifying the fiber content. In addition, individual country labeling requirements may also apply. See the OTEXA Labeling Requirements table for a summary of possible requirements applied by individual EU member countries.
EU regulations require that textile products be labeled to show fiber content as specified in Regulation No 1007/2011. For more information on this labeling regulation, see the European Commission’s website - Textiles and clothing legislation.
Under the fur and leather content labeling regulations, any use of animal-derived materials (i.e., real fur and leather) must be clearly stated on apparel labels.
Care labeling provides information on recommended methods for cleaning textile and apparel products. There is no harmonized EU legislation on care labeling, and not all EU member countries require care labels on products sold in their markets. Nevertheless, care labeling is recommended as manufacturers can be held liable for damage caused to a products if the consumer has undertaken a reasonable cleaning process.
Care symbols generally used in the EU comply with ISO 3758:2012-Textiles - Care labelling code using symbols standard, which is based on the care symbols developed by GINETEX. These symbols are registered as international trademarks by GINETEX and there may be a fee to use them in certain markets.
There is no EU-wide legislation on country of origin labeling for textile and apparel products, although some member countries may require the origin to be listed on the label.
See the Standards section above for information regarding flammability labeling.
Standard EN 13402:2017- Size designation of clothes - Size labelling based on body measurements and intervals was developed to replace many older national sizing systems in Europe. Reportedly, the standard has not been fully accepted throughout Europe.
Footwear
Footwear must be labeled with information relating to material content of the main component parts, i.e., the upper, the lining/sock, and the outer-sole. The information must be conveyed by means of approved pictograms or text, as defined by the European Labelling Directive for Footwear - 94/11/EC. For more information on the directive, see the EU Footwear legislation webpage.
Protective occupational shoes are exempt from this labeling obligation as they are subject to conformity labeling under Directive 89/686/EEC on Personal Protective Equipment (PPE).
Leather Products
Except for footwear, there is no current EU regulation for the labeling of leather products. Some member countries have mandatory national labeling requirements for leather and leather products and others have voluntary standards and labelling systems. It is generally recommended to include the material content on the label, to avoid confusion among consumers. Several EU countries—such as Belgium, France, Italy, Portugal, and Spain—have laws that establish the definition and use of the term ‘leather,’ and its derivatives or synonyms, in the name and composition of products manufactured and placed on the domestic market. Such laws prohibit the use of the word ‘leather’ with prefixes, suffixes, or qualifying adjectives in marketing messages or labeling if the material is not leather (e.g., vegan leather or synthetic leather). The use of such terms is considered deceptive and misleading to consumers and may be subject to fines and criminal proceedings.
Travel Goods
Travel goods are not subject to mandatory EU-wide labeling, except those considered protective equipment, which may be subject to CE marking.
Sustainability Labeling
The ecolabel is officially endorsed by the EU and can be placed on a range of products (including textile, apparel, and footwear products) that meet high standards of environmental awareness, which are sold across the EU, as well as Norway, Iceland, and Liechtenstein. Participation in the eco-label scheme is voluntary. While not required, companies may consider this label to improve consumer perception of their product. For more information, see the European Ecolabel website.
Some EU member countries may have local sustainability labeling requirements. For example, France published Decree 2022-748 regarding the environmental labeling of waste-generating consumer products. Effective May 1, 2022, the environmental labeling requirements will come into force progressively, mostly depending on the size of a company. The decree obligates producers, importers, dealers, and other marketers of certain consumer products—including textile products, apparel, household linen, and footwear (except leather)—to provide information regarding the incorporation of recycled materials in products, the traceability of textile products, the recyclability of products, the presence of dangerous chemicals, and the presence of plastic microfibers.
For an overview of the different labeling and marking requirements, including any restrictive advertising or labeling practices and where to get more information, see the section on Labeling/Marking Requirements in the EU Country Commercial Guide, or for information relevant to a member state, see the EU Member States’ Country Commercial Guides.
Market Resources
See the European Commission’s Textiles, Fashion and Creative Industries webpage for information on the following sectors: Fashion and high-end industries; Textiles and clothing industries; Footwear industry; and Leather industry.
See the EUROSTAT website for trade statistics.
Check out Your Europe - Practical guide to doing business in Europe website.
Contact the EU Trade Helpdesk
To explore key resources and events, contact the U.S. Commercial Service at the U.S. Mission to the European Union or find a U.S. Commercial Service office location in an EU member state.
Visit OTEXA’s Grow America webpage.
For more information on exporting textiles, apparel, footwear, and travel goods, go to the Additional Market Information Page on the OTEXA Website.