A Cut Ahead: Trending Textiles & Labeling Regulations In March 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) Fiber Labels in Mexico
Are branded fibers permitted for use on fiber labels in Mexico?
Mary Liddane, Global Compliance Project Manager, answers:
Per Article 4.3.1 of NOM-004-SE-2021, the name of the fibers must be indicated with the generic names in accordance with the provisions of the Mexican Standards NMX-A-2076-INNTEX-2013 Textile industry-Chemical fibers-Generic names and NMX-A-6938-INNTEX-2013 Textile industry-Natural fibers-Generic names and definitions, as for those fibers not included in said Mexican Standards, the technical name must be indicated.
Per Article 4.3.2, any fiber that is present in a percentage equal to or greater than 5% of the total mass must be expressed by its generic name.
The trade name or registered trademark of any fiber may be used if you have the authorization of the owner, as long as it is used in conjunction with the generic name of the fiber in characters of equal size within parentheses or quotation marks, for example: 100% elastane (spandex).
Per Article 4.3.3 the fibers present in a percentage of less than 5% of the total can be designated as “other” or “other fibers”, the use of capital letters, lowercase letters or capital initial letter being indistinct and the rest in lowercase letters, in this case in particular.
When these fibers or inputs are present in more than two fibers less than 5%, they can be added to the “other” or “other fibers” category.
Q2) Azo and Formaldehyde Limits in Indonesia
I would like to know the applicability for textile component in footwear, and the limit for SNI 7617:2013 for Azo and formaldehyde. Is it possible to download the SNI 7617:2013?
Maria Marecki, Market Access Manager, answers:
To view SNI 7617 it can be purchased here.
SNI 7617:2013 was made mandatory by Regulation of the Minister of Industry No. 7/M-IND/PER/2/2014 as amended by Regulation of the Minister of Industry No. 97/M-IND/PER/11/2015 which sets the limits for baby clothing.
The limits as per the Regulation:
- Carcinogenic Azo dyes: Not used
- Formaldehyde: Not detected
- Extracted metal content:
- Cd (cadmium): 0.1 mg/kg Maximum
- Cu (copper): 25.0 mg/kg Maximum
- Pb (lead): 0.2 mg/kg Maximum
- Ni (nickel) 1.0 mg/kg Maximum
The Regulation does not specifically mention the textile parts of shoes. The regulation contains a list of applicable HS codes:
- 6111.20.00.00
- 6111.30.00.00
- 6111.90.00.00
- 6209.20.30.00
- 6209.20.90.10
- 6209.20.90.90
- 6209.30.10.00
- 6209.30.30.00
- 6209.30.40.00
- 6209.30.90.00
- 6209.90.00.00
- ex. 9619.00.91.10
- ex. 9619.00.91.90
- ex. 9619.00.99.10
- ex. 9619.00.99.90
Q3) Recycled Fiber Content Labeling in the EU
If one of the contents of a garment is recycled polyester, can you confirm that fiber content will be polyester only and the brand has to display the info about recycled content separately?
Mary Liddane, Global Compliance Project Manager, answers:
The current Textile Labeling Regulation (EU) No 1007/2011 does not address recycled content. However, there is an FAQ about Regulation (EU) No. 1007/2011 (last updated 27-03-2015) that addresses recycled content which may be of help to you (available here).
“2.7 According to Annex V item 17, travel goods made of textile materials are not subject to mandatory labeling. This would include travel bags. If the manufacturer uses recycled polyester to make the bag, can the product be labeled as ‘100% recycled polyester’? Is there any specific labeling requirement for products made with recycled fibers?
Labeling or marking is not mandatory on bags made of textile materials (items 16 and 17 of Annex V). If a textile product needs to have a fiber composition label or marking, its composition must be stated using one or more of the fiber names listed in Annex I (e.g. ‘polyester’). There is no requirement to use the term ‘recycled’, but the Textile Regulation allows manufacturers to give that information to the consumer if they wish, provided it is not misleading or deceptive for the consumer. If the manufacturer wants to give such information, it must be displayed separately (Article 16.2), e.g. polyester – recycled fibers.”
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.
Mary Liddane, Global Compliance Project Manager, Compliance & Risks
Mary Liddane is a qualified Solicitor and holds LL.B and LL.M Degrees in Law from the University of Limerick.
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