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Textile and Apparel Market Report - United Kingdom

United Kingdom

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 United Kingdom (UK) formally left the European Union (EU) on January 31, 2020. Under the UK–EU Trade and Cooperation Agreement (TCA), the UK and the EU continue tariff-free and quota-free access to each other’s markets. U.S. exports shipped directly to the UK faced essentially the same customs and border requirements as when the UK was an EU Member State. Compliance with UK law and procedures is necessary in order to place goods for sale in Great Britain (i.e., England, Wales, and Scotland), whereas compliance with EU law and procedures will continue to apply to goods placed for sale in Northern Ireland consistent with the Protocol on Ireland/Northern Ireland. Tariffs on U.S. goods exported to the UK market are listed in the UK Global Tariff (UKGT) and to the Northern Ireland market in the Northern Ireland Online Tariff.

For more information on UK’s tariff rates, see OTEXA’s Foreign Market Reports page.

Most imports are subject to a value added tax (VAT). Some exceptions include:

Import Bans and Restrictions

Importation of cat or dog fur, as well as any products made from such fur, is banned. See Notice to Importers 2936 dated December 31, 2020.

A valid permit is required to import the fur or skin of endangered animals or fish, or goods made from them (e.g., jewelry, shoes, bags, and belts). Fur of animals caught in leg-hold traps are prohibited for import into the UK unless accompanied by either certification that confirms origination in an approved-source country, or a valid import permit issued for endangered species. See Guidance: Importing animal furs and skins-export of fish for more information. Note that it is illegal to market seal fur in the UK.

For information about prohibitions and restrictions that apply to imports, see UK Trade Tariff: Import Prohibitions and Restrictions.

See additional customs and import regulation information in the United Kingdom Country Commercial Guide. Relevant information may also be found in the Country Commercial Guide for the EU.

Standards

Upon withdrawal from the EU, the UK transposed existing EU technical regulations and requirements into UK law, thus ensuring close alignment between UK and EU technical regulations and requirements during the transition. The UK’s General Product Safety Regulations 2005 (GPSR) requires all products to be safe in their normal or reasonably foreseeable usage. The GPSR covers consumer goods such as, clothing, children’s articles, and furniture and soft furnishings. In product sectors where there are specific regulations, the product-specific legislation usually takes precedence. Note that various regulations may be applied differently in Great Britain and Northern Ireland. For more information on the GPSR, see the UK’s Business Companion – General Product Safety: Producers and the UK’s Business Companion - General product safety: Distributors.

Chemical Restrictions

UK REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a system analogous to the EU’s REACH regime. Products sold or distributed in the UK that incorporate chemical substances must comply with the UK and EU REACH rules. However, differences may develop between the two regimes, as future changes to EU REACH will not automatically be reflected in the UK REACH regime and vice versa. For more information, see UK guidance on How to Comply with REACH Chemical Regulations.

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 Europeen 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, and upholstery for the period of November 1, 2020 to November 1, 2023. After this period, the more stringent limit of 75mg/kg will apply.

Consumer products made of leather (e.g., clothing, gloves, hats, shoes, bags, belts, furniture, and soft furnishings) are subject to controls on the chemicals that may be present as a result of the tanning process. Chemicals such as azo dyes, chromium VI, and dimethyl fumarate (DMF) are restricted due to the health hazards they pose to consumers. See the UK Business Companion – Leather Goods for more information on these chemical restrictions.

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 for 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.

BS 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.

Noncompliance to BS EN 14682:2014 is a major reason for product notifications/recalls in the Safety Gate - Rapid Alert System for dangerous non-food products. It should be noted that there are differences between the European and U.S. cord and drawstring requirements, such as the clothing sizes and the length of cords regulated.

BS 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

Children’s and Adult Nightwear

Technical and labeling requirements on the flammability of nightwear are provided in the Nightwear (Safety) Regulations-1985. Baby garments, children’s pajamas, and adult nightwear must carry a permanent label indicating whether or not they meet the flammability standard.

The European Standard BS EN 14878:2007-Textiles - Burning behaviour of children’s nightwear - Specification covers all nightwear for children aged under 14*, including pyjamas, all dressing gowns, and babies’ garments, and introduces specific flammability requirements for these garments. [*This is different from the age of 13 specified in the Nightwear (Safety) Regulations 1985.]

To ensure compliance with both the UK regulations and the GPSR, it is recommended that the more rigorous of the requirements of both the GPSD/BS EN 14878:2007 and the UK Regulations be applied to children’s nightwear to be sold in the UK market. Further information on the labeling of nightwear is contained in A Guide to the Nightwear (Safety) Regulations. Also see the UK Business Companion – New Nightwear.

In addition to the specific flammability requirements, nightwear must be safe in all other aspects, such as to avoid strangulation, entrapment, and choking hazards caused by cords and fasteners, as well as chemical hazards. For example, the use of flame-retardant chemicals in apparel and other textile products must conform with the REACH regulations.

Home Furnishings

The British Furniture and Furnishings (Fire Safety) Regulations No. 1324:1988 (as amended in 1989, 1993, and 2010) are designed to ensure that upholstered furniture, furnishings, and other products containing upholstery meet specified ignition resistance levels and are appropriately labeled.

See BS EN 1102:2016 Burning Behavior-Curtains and Drapes for detailed procedures to determine the flame spread of vertically oriented specimens.

See the UK Business Companion - New Upholstered Furniture for more information on safety and labeling requirements with regard to flammability. Also see the British Furniture Industry Research Association (FIRA) Guides to the UK Regulations:

These regulations do not apply to sleeping bags, bed linens (including duvets), loose covers for mattresses (i.e., mattress protectors), pillowcases, curtains, and carpets, all of which are covered under GPSR.

Some European standards for furniture flammability follow:

  • BS EN 1021-1:2014-Furniture-Assessment of the ignitability of upholstered furniture: Smouldering cigarette
  • BS EN 597-1:2015-Furniture-Assessment of the ignitability of mattresses and upholstered bed bases - Part 1: Ignition source: Smoldering cigarette
  • BS EN 597-2:2015-Furniture-Assessment of the ignitability of mattresses and upholstered bed bases - Part 2: Ignition source: Match flame equivalent

UKCA / CE Marking

The UK Conformity Assessed (UKCA) marking is used for goods placed on the market in Great Britain (i.e., England, Wales, and Scotland) and covers most goods that previously required the EU CE marking. Goods placed on the Northern Ireland market, require the CE marking or the United Kingdom Northern Ireland (UKNI) marking. For more information, see the UK Guidance on Using the UKCA Marking (which includes a link to information on the UKNI Marking) and the UK Guidance on CE Marking.

Personal Protective Equipment (PPE)

The UK Personal Protective Equipment (PPE) (Enforcement) Regulations 2018 implements and provides for the enforcement of the EU Regulation 2016/425 - Personal Protective Equipment (PPE) Directive. Products falling under the scope of the PPE Directive and placed on the UK market must be marked to indicate conformity assessment. For more information see UK Guidance on Personal Protective Equipment (Enforcement) Regulations 2018 and UK Guidance on Technical specifications for personal protective equipment (PPE).

The PPE Regulations cover clothing and footwear designed to be worn by individuals for protection against health and safety hazards and includes products such as gloves, aprons, high viz clothing and devices for the face (e.g., visors and respirators). There are three categories of PPE (1, 2, and 3), which indicate the severity of the hazard from which the PPE is intended to protect the wearer.

  • Category 1 - Lowest level of risk (e.g., sunglasses and washing up gloves)
  • Category 2 - (e.g., high viz jackets and protective gloves)
  • Category 3 - Highest level of risk (e.g., respirator face masks to protect against the risk of COVID-19)

Any clothing including hats, gloves, and swimwear that includes a claim to protect the wearer’s skin from the sun must be marked as PPE. Reportedly, manufacturers and retailers in the UK and 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. British Standard, BS 8466:2006 is supplementary to EN 13758-1 and provides requirements for the UPF for fabrics used in hats.

Note that oven mitts and potholders are considered PPE and must be CE marked.

Construction Products

Construction products (including carpets, wall covering, and thermal insulation products) are subject to the Construction Products Regulations 2013, which implement Regulation (EU) No 305/2011 laying down harmonized conditions for the marketing of construction products. Manufacturers must draw up a declaration of performance and apply the UKCA mark to any of their construction products that are covered by a designated UK standard, or conform to a UK technical assessment (UKTA) that has been issued for them. For more information, see the UK Business Companion – Construction Products and UK Guidance - Construction Products Regulation in Great Britain.

Internal Blinds and Corded Window Coverings

Safety standards for internal windows are applicable to all homes, public buildings, and any other premises where babies and young children aged 0 - 42 months are likely to have access or be present. Compliance with the European standards listed below meet the GPSR regarding risks posed to children by internal blinds and corded window coverings:

  • BS EN 16433:2014-Internal blinds-Protection from strangulation hazards – Test methods
  • BS EN 16434:2014-Internal blinds-Protection from strangulation hazards – Requirements and test methods for safety devices
  • BS 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

Toy Safety

The Toys (Safety) Regulations 2011 set out the legal requirements for the safety of new toys placed on the market. Toys are defined as “products designed or intended (whether or not exclusively) for use in play by children under 14 years old.” There are a number of labeling requirements for toys, including the name and address of the manufacturer/importer, the type, batch, model, or serial number, the UKCA mark, and warnings and instructions. The UK Business Companion – Toys provides more information on these labeling and safety requirements.

UK retailers likely follow and apply the British Retail Consortium (BRC) voluntary guides for children’s costumes: Code of Practice – Flammability Safety of Children’s Dress-up and Code of Practice for the Flammability of Labelling of Children’s Toy Dress-up.

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. Note that in the EU, 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 market, as well as the governing textile regulations to guarantee safety and efficacy to the consumer. Examples of cosmetotextile products include:

  • Slimming preparations: pantyhose, underwear, trousers
  • Moisturizing preparations: pantyhose, underwear, T-shirts
  • Refreshing preparations: bed linens (bedsheets)

Biocidal Products

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 (GB BPR) must be followed. For more information, see the UK Health and Safety Executive website on Biocides.

 

For up-to-date information on dangerous products found in the UK and EU/EEA member state markets, see the Safety Gate - Rapid Alert System for dangerous non-food 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 United Kingdom Country Commercial Guide. Certain information in the Standards for Trade in the Country Commercial Guide for the EU may also be relevant.

Labeling

Textile and Apparel Products

It is the responsibility of the manufacturer or importer into the UK to ensure that textile products carry a label indicating the fiber content, either on the item or the packaging. The label must be in English. The label should be durable, easily legible, visible, and accessible. Refer to the EU Regulation No 1007/2011 on textile fibre names and related labelling and marking of textile products for information on acceptable fiber names and on textile product components that are not considered in determining fiber compositions.

Care labeling provides information on recommended methods for cleaning textile and apparel products. The UK does not require that care instructions be included on the label, however, care labeling is recommended as the manufacturer can be held liable for damage caused to products if the consumer has undertaken a reasonable cleaning process.

Care symbols generally used in Europe comply with ISO 3758:2012-Textiles - Care labelling code using symbols standard, which is based on the care symbols developed by GINETEX. The five GINETEX care symbols are trademarked and may not be reproduced, issued, or used without a special license agreement with GINETEX, co-owner of the trademarks together with COFREET. There also may be a fee to use the GINETEX care symbols.

It has been reported that as of January 2, 2021, the company’s name and a contact address in the UK must be provided for products put on the UK market. Until December 31, 2022, this information can be on accompanying documentation. However, effective January 1, 2023, the information must be permanently fixed to the product. Although there is no compulsory origin labeling requirement in the UK, in order to ensure the consumer is not mislead, it may be necessary to include the country of origin on the label as well.

See the Standards section above for information regarding flammability labeling.

Standard BS 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.

For more information on labeling, see the Department for Business, Energy & Industrial Strategy’s Textile Labelling Guidance and the UK Business Companion Labelling of Textiles guide.

Fur and other animal parts

Consumers must be made aware when textile products contain parts of animal origin, such as fur, leather, bone, etc. The use of fur and other animal parts must be clearly labeled or marked using the phrase “contains non-textile parts of animal origin.” The label can contain additional information, such as “mink fur” or “lambskin,” but the mandatory phrase must always be used. Any mislabeling (e.g., labeling real fur as faux fur) is not permitted.

Footwear

Under the Footwear (Indication of Composition) Labelling Regulations - 1995, footwear must be labeled with an indication of the main material from which the upper, lining and sock, and outer sole are made in the form of either pictograms (symbols) or words. Where written indications are used, the language must be English. For more details, see the Department for Business, Energy & Industrial Strategy’s Footwear Labelling Guidance and the UK Business Companion Labelling of Footwear guide.

 

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 Labeling/Marking Requirements in the United Kingdom Country Commercial Guide. Certain information in the Labeling/Marking Requirements in the EU Country Commercial Guide may also be relevant.

Market Resources

UK Fashion & Textile Association

See HMRC guidance on classifying products for import:  

To explore key resources and events, contact the U.S. Commercial Service in the United Kingdom.

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.