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A Cut Ahead: Trending Textiles & Labeling Regulations In April 2024

The textiles regulatory environment is ever-changing, especially considering chemical, labeling, and extended producer responsibility (EPR) issues that the industry faces today. With a 26% growth in textile regulations since 2020, its more important than ever to stay ahead of changing regulatory requirements.

To help you stay a cut ahead, we gather some of the most interesting recent inquiries from Compliance & Risks customers around trending textile labeling regulations across the world.

Q1) EU Footwear Labeling Exemptions

I have a question regarding the scope of EU Directive 94/11/EC. According to the Article 1 of Directive 94/11/EC, footwear covered by Directive 76/769/EEC is excluded from this directive. Directive 76/769/EEC is for restrictions on use of hazardous substances and mixtures. Could you please advise what type of footwear is covered by 76/769/EEC and excluded from Directive 94/11/EC?

Maria Marecki, Market Access Manager, answers:

This UK guidance notes that the exemption refers to footwear containing asbestos.

Directive 76/769/EEC regulated products containing asbestos. Directive 76/769/EEC was repealed and replaced by REACH.

Q2) Proposed US CPSC e-filing Requirements

HOW DOES E-FILING AFFECT iTEMS THAT ARE EXEMPT FROM REQUIREMENTS TO MANDATORY STANDARDS? ARE THE DOCUMENTS STILL REQUIRED TO BE SUBMITTED?

FOR EXAMPLE, FOR GENERAL FLAMMABILITY CFR 1610, IF AN ITEM FALLS OUT OF THE TESTING REQUIREMENTS FOR HAVING A PLAIN SURFACE FABRIC THAT HAS BEEN MADE FROM NYLON, DO WE STILL HAVE TO E-FILE?

Maria Marecki, Market Access Manager, answers:

As per the text of the Proposed Rule, “Importers will use CBP’s ‘‘disclaim’’ feature for non-regulated products within CPSC’s jurisdiction and for products that are regulated but do not require certification. CPSC’s CATAIR explains how to file a ‘‘disclaim’’ in a PGA Message Set for products such as adult wearing apparel and refrigerators that are not required to issue a certificate based on the Commission’s enforcement discretion.”

This FAQ document addresses the disclaim feature.

“What is the difference between a testing exclusion and a disclaim?

Use a testing exclusion code when a certificate is required for the product, but the product is not required to be tested to a specific performance requirement in a rule based on an exemption, exception, or determination in the underlying rule. Use a disclaim when no certificate is required for the product because the product is not within CPSC’s jurisdiction; is not subject to a rule, ban, standard, or regulation that requires certification; or because the Commission has issued an enforcement discretion for the product (i.e., certain refrigerators and adult wearing apparel). Instead of filing a Full or Reference Message Set, a Disclaim Message Set is filed.”

Additional information can be found in this document: Citations, Exemptions, and Disclaims.

Please note that the CPSC is currently conducting the Beta Pilot with industry participants. The outcomes and feedback received will inform final rulemaking for full implementation.

Q3) Country of Origin Labeling for Textiles in Japan

I’m wondering if you have any information about Japan and if they require the country of origin to be labeled on textiles. I’m not seeing this information in either of the regulations I’ve found (Textile Goods Quality Labeling Regulation, Notice No. 4, 2017 & Household Goods Quality Labeling, Act No. 104, 1962), but I wanted to double check.

Maria Marecki, Market Access Manager, answers:

You are correct. Japan does not specify country of origin labeling for textiles under the requirements of Textile Product Quality Labeling Regulations.

Meet Our Experts

Maria Marecki, Market Access Manager, Compliance & Risks

Maria Marecki is the Market Access Manager at Compliance & Risks.

She has over a decade of experience as a research consultant compiling customized products to address strategic business needs for retailers and manufacturers, including entering new geographic markets and development of global best practices around regulatory compliance.

Her experience in product safety and labeling spans a wide range of products including children’s products, apparel, footwear, electronics, and cosmetics.