Current product duties need attention before future passport fields

Every textile product marketed in the European Union must be labelled or marked to show its fibre composition, and the indication of fibre composition is mandatory at all stages of industrial processing and commercial distribution.[S17][S0701] Under Regulation (EU) No 1007/2011, which has applied since 8 May 2012, mandatory composition rules cover all products containing at least 80 percent by weight of textile fibres, including raw, semi-worked, worked, semi-manufactured, semi-made and made-up products, as well as furniture, umbrella and sunshade coverings and textile components of multilayer floor coverings, mattress coverings and camping goods reaching at least 80 percent by weight.[S17][S28][S0701] A factory cannot treat composition labelling as a late packing detail; the label text is a regulated metrological statement about the mass fraction of every constituent fibre in the finished garment.[S17][S28]

Before printing a label, the supplier and the European Union buyer must verify whether the article falls inside the general rule, a multi-component rule or a statutory exemption under Regulation (EU) No 1007/2011.[S17][S28] Fibre names on the label are restricted to the harmonised generic names in Annex I, such as cotton, wool, polyester, viscose, lyocell or polyacrylate (added by Commission Delegated Regulation (EU) 2018/122 of 20 October 2017, after Commission Delegated Regulation (EU) No 286/2012 of 27 January 2012 added polypropylene/polyamide bicomponent).[S17][S28][S0701] Brand names or breed descriptions cannot substitute for an Annex I name: describing a knitted jumper solely as Merino violates the regulation unless the Annex I word wool appears, with any additional breed detail displayed separately under Article 16(2).[S28] Fibres must be listed in decreasing percentage order by weight under Article 9(1), meaning that a garment containing 60 percent cotton and 40 percent polyester cannot share a label with a style containing 40 percent cotton and 60 percent polyester.[S17][S28]

Purity claims, tolerances and multi-component assemblies directly constrain factory quality control.[S17][S28] A product may be described as 100 percent, pure or all of a single fibre under Article 7(1) only when composed exclusively of that fibre, subject to narrow statutory allowances.[S17][S28] For multi-fibre blends, Article 20(3) permits a 3 percent manufacturing tolerance between the stated composition and the weight percentages obtained during official inspection under Article 19 (for example, 70 plus or minus 3 percent and 30 plus or minus 3 percent on a 70/30 blend).[S28] Under Article 11(1), textile components with different fibre contents that represent 30 percent or more of total product weight (and main linings) require separate disclosure, whereas smaller components below 30 percent need not be labelled separately (save for certain corsetry items under Annex IV where a 10 percent threshold applies) but still enter the overall calculation, excluding only reinforcement and trim items listed in Annex VII.[S28] Under Article 12, any textile product containing even small quantities of down, feather, bone, leather, pearl or horn must carry the exact sentence "Contains non-textile parts of animal origin" on the label or marking.[S17][S28]

As shown in Exhibit 29, each product rule answers a different regulatory question and demands a distinct primary artifact.[S11][S16][S17][S28][S33][S34] What Exhibit 29 cannot establish is the binding classification of a specific style without reviewing its tariff code, construction and sales route.[S28][S33] Regulation (EU) No 1007/2011 does not harmonise wash-care symbols, sizing or country-of-origin marking, and Annex V exempts specific categories (such as textile parts of footwear under item 23, travel goods under item 17, toys, and device covers up to 160 square centimetres on one side under item 30), while Annex VI permits inclusive labelling for specified items.[S28][S0701]

For textiles intended for sale to an end consumer, labels or markings must be durable, easily legible, visible, accessible and firmly attached (such as sewn in), using uniform lettering in the official language or languages of every Member State where the product is made available under Article 14(1) and Article 16(3), with composition also shown before purchase in catalogues and online offers under Article 16(1).[S17][S28] Under Article 14(2), when products are supplied in business-to-business transactions within the supply chain or in public procurement, physical labels may be replaced or supplemented by accompanying commercial documents.[S17][S28]

Mandatory composition must also remain separate from voluntary recycled-content statements.[S28] Under the Commission's FAQ on Regulation (EU) No 1007/2011, there is no requirement under the Textile Regulation to use the term recycled, and if a manufacturer wishes to give that information, the mandatory Annex I fibre name must appear first and the voluntary phrase must be displayed separately under Article 16(2) (for example, "polyester" followed separately by "recycled fibres"), provided it is not misleading.[S17][S28] Since 27 September 2026, when Directive (EU) 2024/825 amending Directives 2005/29/EC and 2011/83/EU entered into application, any voluntary consumer environmental claim must also avoid generic unverified wording or presenting a component claim as covering the whole product.[S18][S19][S36]

The illustrative sequence in Exhibit 30 links the engineering bill of materials to label approval so a print proof cannot be released until component weights, Annex I fibre names, the 3 percent laboratory check, Article 12 animal-origin screening and Member State languages are verified.[S17][S28] What Exhibit 30 cannot validate is the chain-of-custody authenticity of a recycled fibre lot, which belongs to the provenance model in wp05.[S28]