A Cut Ahead: Trending Textiles & Labeling Regulations In August 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 of textiles regulations, we gather some of the most interesting recent inquiries from Compliance & Risks customers around trending textile labeling regulations across the world.

Q1) I have learned that changes have been made to the labeling requirements for footwear and textiles in Argentina. Would you be able to provide me with the text and a summary of the changes that have been made?

The revision of the Argentinian Labeling requirements for textiles and footwear referred to in this query has been adopted as part of Resolution No. 49/2024. The text of the resolution and a summary can be found in C2P under the following title: ‘Argentina: Sworn Declaration of Product Composition (DJCP), Resolution No. 49/2024’ (OFFICIAL GAZETTE OF THE REPUBLIC OF ARGENTINA – MINISTRY OF ECONOMY – Resolution 49/2024)

Resolution No. 49/2024 makes the following changes to the labeling requirements in Argentina:

• The information on the label must be presented in Spanish;
• The identification of the exporter on the label is now optional;
• Instead of stating the name of the importer, the label can refer to the importer’s Unique Tax Identification Code (CUIT);
• The requirement to submit a Declaration of Composition of Products (DJCP) before marketing the product has been removed;
• The resolution has been harmonized with the Mercosur requirements for labeling regarding fiber composition, country of origin, care instructions, and details of the domestic producer or importer.

Q2) Is there a law in the US that allows the use of ISO symbols to satisfy the care instruction labeling requirement for goods sold within the US, or would the producer need to use the ASTM symbols where the producer does not want to use written care instructions?

When using care symbols only and no written instructions, it is necessary to use the ASTM symbols as per Standard D5489-96c. This is prescribed in 16 CFR Part 423, see §423.8(g).

At the moment ASTM symbols are the only allowed. There was a proposal back in September 2012 to allow the use of ISO symbols, but it was never finalized.

You can find the USA rules in C2P by searching for: USA: Care Labeling of Textile Wearing Apparel and Certain Piece Goods, Rules, 16 CFR 423, 1983.

We also have the proposed amendment in C2P, but as I said this proposal has been abandoned: USA: Care Labeling of Textile Wearing Apparel and Certain Piece Goods, Rules, 16 CFR 423, 1983 – Proposed Amendment – (on care instructions) Notice of Proposed Rulemaking, 77 FR 58338, September 2012.

Q3) Could you provide me with information on Extended Producer Responsibility schemes for textiles in Europe? Could you point out which ones are currently enforceable and if they include any labeling obligations?

EU: The EU Waste Framework Directive is currently under revision to introduce a new EU-wide EPR scheme for textiles. The revision is however still at the proposal stage, and after the entry into force of the EU Directive, Member States will have to implement the Directive into national law, so these changes won’t be enforceable within the next year.

France: France has introduced EPR for a broad range of products including textiles and footwear as part of the AGEC law. This also entails the obligation to affix the Triman logo.

The following sources in C2P entail further explanations on this:

• France: Anti-waste and Promotion of Circular Economy, Law 2020-105
• France: Consumer Information Symbol on Sorting Rule for Waste Resulting from Household Products Subject to Extended Producer Responsibility (EPR), Decree No. 2021-835
• France: Triman and Sorting Info for Clothing, Household Linens and Footwear, Guidance Document, February 2022

Netherlands: The Netherlands have introduced EPR for a range of products in 2020, and EPR has been made mandatory for textiles through an implementing decree in July 2023. This Decree however does not entail any labeling obligations.

• Netherlands: Scheme for Extended Producer Responsibility (EPR), Decree, 18 September 2020
• Netherlands: Extended Producer Responsibility for Textiles, Decree, April 2023

Similarly, Latvia and Hungary introduced EPR for textiles, but none of these schemes contain labeling obligations for manufacturers:

• Hungary: Rules for the Operation of the Extended Producer Responsibility System, Decree 80/2023
• Latvia: Waste Management Law, 2010 – Amendment – (on regional waste management centres, retail packaging waste, textile EPR, etc.) Law No. 62, 2023

In addition to these, there are a number of proposed EPR schemes across Europe, including in Sweden and Bulgaria.

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