Labels and the Law (UK & EU)

Posted on October 2, 2020

By Peter Gregory

What are the laws when it comes to labelling clothes in the UK? Which labels do you absolutely need to have, and does Brexit mean that the rules change if you’re selling UK-made clothes in the EU? 

At GB Labels, we have been producing labels for fashion and apparel businesses for over two decades. While we’re certainly not legal experts, we do know what labels you need to include by law, and we can give you a good steer on what you’ll need. 

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You’ll notice that we haven’t separated UK and EU laws in this guide. For the time being, UK & EU textile labelling laws are virtually identical (see footnote 1). We’ve included a section on what Brexit might mean for UK labelling laws which we will update if/when the situation changes. 

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What’s Legally Required on a Clothing Label?


Care Labels

Wash care labels are not required by law in the UK or the EU. While you’re not legally required to add a wash care label to a garment, if the consumer damages that garment by washing it in the wrong way, you could be liable for the costs of repair or replacement. 

Wash care labels are a long-established industry norm, and they help the consumer in a very important way, so we think it’s worth adding a wash care label regardless of whether you’re legally obliged to do so or not. 

Fibre Content

In the EU and the UK, manufacturers are legally required to state what textiles a garment is made out of. You must give an exact percentage of any material that comprises more than 15% of the total weight of the product, and every material must be listed on the label. 

Expressions like “100% cotton” or “pure wool” are legally-protected terms — a garment must be made completely out of one textile before the manufacturer can use the words ‘all’, ‘pure’ or ‘100%’. The law allows up to 2% of the garment to be composed of naturally-occuring wool impurities or anti-static treatments, however. The law also allows manufacturers to add embroidered badges, jacket buttons, elastic and other vital components without sacrificing a garment’s ‘all’, ‘100%’ or ‘Pure’ status.

Technically speaking, fibre content information doesn’t have to be stitched into the garment in label form. UK Government Guidance states that “swing tickets or gummed labels are adequate” and that “it is sufficient to indicate the fibre composition on the packaging.” (see footnote 2). It’s much easier to recycle garments at the end of their life when there’s a label showing precisely what that garment is made out of, so we recommend adding this information to a permanent sewn-in label wherever possible. 

Country of Origin

Unlike food products, clothing doesn’t legally have to carry any ‘country of origin’ labelling in the UK or EU. The UKFT point out that you can’t legally mislead a consumer about the country of origin, however (see footnote 3), so you have to be careful here, especially if you use a place name in your branding. 

If you’re selling fashion that’s Made in Britain, it pays to shout about it! You can find out more about what the world really thinks of British-made apparel, and the value of the Made in Britain accreditation, in our recent guide to the Made in Britain mark.

Size Labels

By law, you don’t have to add a size label to garments in either the UK or the EU. A lot of our customers are surprised by this. In fact, there’s not even a single shared standard when it comes to sizing (…which is why most of us have items in our wardrobe with identical size labels but a completely different fit).

Wash care symbols are standardised all over the world, so it seems a shame that we don’t have a similar system for clothes sizes. The EU did create a shared clothes sizing standard called ‘EN 13402’ over a decade ago, but not everybody uses it (see footnote 4). 

Flammability 

There are strict laws governing the fire safety labelling of nightwear in the UK. The UKFT have some great advice on fire safety labelling for the UK market (and the Netherlands, which has its own set of rules) on their website here. In a nutshell, all nightwear has to either…

 be made of material that passes certain flammability standards after it has been washed, or have a ‘KEEP AWAY FROM FIRE’ warning printed in red block capitals.

There’s more to it than this, of course, so we recommend you take a look at the UKFT website and read the law for yourself (see footnote 5).

Languages 

The European Union is a multi-lingual trading bloc, so you should of course print your labels in the official language(s) of the country where your products are sold (See footnote 6). 

This means that if you want to sell clothes to Belgium, for instance, you might need a label written in Dutch, French and German (the 3 official languages of Belgium). It sounds like a lot of work to add all of these languages to one label, but bear in mind that the GINETEX wash care labelling symbols help you cut down on a lot of text. Take a look at our ultimate guide to care labels for more advice.  

Will I need to buy new labels after Brexit?

Some of our customers have expressed concern that UK clothes labelling laws will change after the Brexit Transition Period ends on 1 January 2021. 

We’ve looked into this, and we just can’t see there being much diversion on the EU labelling laws in the short term. We are technically ‘due an update’ (the current law hasn’t been touched in 8 years, and on average it gets updated every 5 years – see footnote 7). The current labelling standards are all very sensible and worthwhile, and there’s no practical reason — or urgent need — to change them.

It’s more likely that the Textile Products Regulations rules will change if a number of new textile types arrive on the market, or if there’s a sudden urgent need to start labelling smaller items (at the moment, there’s no need to attach a label to shoelaces or cleaning cloths, for instance. See footnote 8). 

To get ready for the end of the Brexit Transition Period, we suggest you get to know the customs categories (HS codes) that your imports and exports will fall under next year. You can find out more about how to prepare for customs after Brexit by reading our recent article on selling to the EU in 2021.

That’s it! We hope this guide has given you a good introduction to the legal side of a clothes labelling strategy.

Just bear in mind that we’re very experienced label manufacturers, but we’re not legal experts. Please speak to a professional if you’re in any doubt as to how to proceed. If you need help finding an expert in labelling law, let us know. We’ll be happy to point you in the right direction! 

Thanks for reading!

Pete

Footnotes:

Footnote 1

The full text of the Textile Products (Labelling and Fibre Composition) Regulations 2012 is available on the UK Government website at the link below:

https://www.legislation.gov.uk/uksi/2012/1102/contents

The EU equivalent law, and a summary of what it means for clothing manufacturers, can be found at https://ec.europa.eu/growth/sectors/fashion/textiles-clothing/legislation_en  

Footnote 2

“…it is not necessary, however, to provide a sewn-in label or to print directly on to the textile product. Swing tickets or gummed labels are adequate; and if the products are offered for sale in packaging (i.e. pre- packed) it is sufficient to indicate the fibre composition on the packaging only. In addition, if a piece of cloth is being supplied from a roll, it is sufficient to indicate fibre composition on the roll only, provide the indication is easily accessible to the consumer.” – see point 40, under Methods of indicating fibre composition, at the link below:

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/513963/BIS-16-193-textile-labelling-regulations-guidance.pdf

Footnote 3

“If a garment carried the British flag on it but it was made in Hong Kong, then the garment should include a label to that effect. Fraudulent origin labelling is illegal.”

See more at https://www.ukft.org/business-advice/labelling/#countryoforigin

Footnote 4

Back in 2008, the European Parliament agreed that “the only mandatory labelling requirement for textile and footwear products placed in the EU market is the labelling of fibre composition in textiles and of materials used in footwear (Directive 96/74/EC(4) and Directive 94/11/EC(5), respectively).

As far as sizes are concerned, there is a European voluntary standard — EN 13402 — on size designation of clothes but no EN standard on footwear sizes. Manufactures and retailers can thus label their products on a voluntary basis using this or other recognised standards. Several meetings with Member States and stakeholders showed that there is no consensus on the need to harmonise shoes and clothes sizes. In addition, Member States and stakeholders consider that there are no major problems with the current scheme in the internal market. The Commission is also not aware of consumers’ or Member States’ requests to impose harmonised labelling requirements on sizes of clothing and footwear. Therefore, the Commission does not envisage to propose harmonised legislation in this area.”  You can read the full statement at the link below:

https://www.europarl.europa.eu/sides/getAllAnswers.do?reference=E-2008-2322&language=EN

Footnote 5

The full text of the The Nightwear (Safety) Regulations 1985 can be found at the link below:

https://www.legislation.gov.uk/uksi/1985/2043/made

Footnote 6

The EU Regulation states that “the labelling or marking shall be provided in the official language or languages of the Member State on the territory of which the textile products are made available to the consumer, unless the Member State concerned provides otherwise.” See point 46 of the Government’s official guidance on EU Regulation 1007/2011 at the link below: 

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/513963/BIS-16-193-textile-labelling-regulations-guidance.pdf

Footnote 7

This ‘once every five years’ calculation has been based on the Textile Products Regulations 1986, and the 6 subsequent versions of this law published since that time. A full list of the UK’s prior labelling legislation is as follows:


Textile Products (Indications of Fibre Content) Regulations 1986 SI 1986/26
Textile Products (Indications of Fibre Content) (Amendment) Regulations 1988 SI 1998/1169
Textile Products (Indications of Fibre Content) (Amendment) Regulations 1994 SI 1994/450
Textile Products (Determination of Composition) Regulations 2008 SI 2008/15
Textile Products (Indications of Fibre Content) (Amendment) Regulations 2008 SI 2008/6
Textile Products (Indications of Fibre Content) (Amendment) (No 2) Regulations 2009 SI 2009/1034

Footnote 8

A full list of which small items are exempt from labelling can be found in “ANNEX VI: Textile products for which inclusive labelling is sufficient” of the REGULATION (EU) No 1007/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL at the link below:

https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:272:0001:0064:EN:PDF

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