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Analyses ·
Textiles never had one standard to begin with
Apparel is the category where asking whether a product has passed the standard and getting a blank look is normal, because textiles have no single standard. Fibre declaration, flammability, care instructions and substance restrictions sit under different regulations with different bases.
Four duties inside one category
When buying textiles, the question has to be split, because at least four things need answering: how the fibre composition is declared, which substances are restricted, whether flammability applies, and how care instructions are written.
In each market these sit under different regulations, and some markets split one of them further. They do not substitute for each other. Correct composition does not mean flammability is covered, and covered flammability does not mean the care label is right.
EU: composition and substances are two regimes
The basis for composition and labelling is the Textile Fibre Names Regulation (EU) No 1007/2011, which sets how fibres are named, how composition is declared and what the label must carry. It is a labelling regulation: it governs what is written and how.
Substance restrictions sit in Annex XVII of REACH. Annex XVII is the restriction list itself, and it is amended continuously - additions and changed limits are routine. So a question about what limit the EU puts on a given substance cannot be answered with a standard number; it is answered by a specific entry at a specific date. That matters most when negotiating long-term contracts.
The EU is also moving on sustainability requirements, with textiles among the first priority categories under its ecodesign work, and the digital product passport in preparation. We only hold the regime at that level, so no dates are written into this page.
US: four pieces, split by adult and child
The US slices textile duties finer than the EU. Clothing textiles have a flammability standard (16 CFR 1610); children's sleepwear has a stricter one of its own (16 CFR 1615 for sizes 0 to 6X, with 1616 parallel in structure); care labelling has a separate rule (16 CFR 423); and fibre content declaration sits under the FTC's textile fibre products identification law.
The practical difference is this: adult clothing has no general flammability requirement, while children's sleepwear has a hard one. A factory taking both kinds of order is clearing different gates, and the quote does not always show it.
China: GB 18401 and GB 31701
China's baseline is GB 18401, the basic safety specification for textile products, which grades products by how they contact the skin: products for infants, products in direct skin contact, and products not in direct contact, each with different limits. Textiles for infants and children have a stricter standard of their own, GB 31701.
Both are mandatory standards, and the structure differs from the EU's labelling regulation plus restriction list: China writes the safety indicators into the standard itself and grades them by product category.
Japan, Korea, Canada, Australia-NZ
Japan's mandatory pieces sit in the household goods quality labelling act for composition and care, and in the household products harmful substances act for limits. Korea works through its product safety and quality management legislation, with mandatory quality labelling for textiles and stricter treatment of children's textiles. Canada has a textile labelling act with regulations underneath, plus a separate textile flammability regulation. Australia and New Zealand have a mandatory care labelling standard, with a separate mandatory standard for children's sleepwear.
For these four markets we currently hold the regime described but no primary text, so the page states the regime and no document numbers.
Ten markets side by side
Putting the four duties side by side shows how finely each market slices them:
| Market | Composition and care | Flammability | Substances | Note |
|---|---|---|---|---|
| EU | (EU) No 1007/2011 | No general adult requirement | REACH Annex XVII, amended continuously | Sustainability work in progress |
| UK | Retained fibre composition labelling rules | No general requirement | Retained REACH restrictions | - |
| US | 16 CFR 423 plus the FTC fibre identification law | 16 CFR 1610; sleepwear 16 CFR 1615 / 1616 | Split federally; state law in California | Much stricter for children |
| Canada | Textile Labelling Act and regulations | Textile flammability regulation | Phthalates and others covered separately | - |
| Japan | Household goods quality labelling act | By product | Household products harmful substances act | - |
| Korea | Mandatory quality labelling | By product | Product safety and quality legislation | Stricter for children |
| China | GB 5296.4 and labelling rules | By product | GB 18401 (graded) plus GB 31701 | Safety indicators inside the standard |
| Gulf | GSO textile regulation and labelling | By product | GSO technical regulations | - |
| Brazil | Mercosur textile labelling scheme | By product | Ministry regulations | - |
| Australia / NZ | Mandatory care labelling standard | Separate standard for sleepwear | By product | - |
What is worth reading off this table is the structural difference. The EU splits labelling from substances, the US splits flammability by adult and child, and China grades safety indicators by contact level. All three are legitimate ways to cut it, which is why the question has to name which duty is being asked about.
What to ask before you order
Ask for textile evidence in four parts. On composition, whether the tested fibre content matches what actually goes into the goods, since a wrong composition declaration is among the most common reasons for a shipment being turned back. On substances, which tests were run for the target market and on what date the report was issued, because the restriction list moves and a two-year-old report may not cover the current entries. On flammability, whether testing was done to the target market's requirement and which fabrics and weights it covers. On care labelling, which system the wash symbols follow.
The second is the one most often skipped. A substance test report is a document with a shelf life, and restriction lists change every year, so "we have a test report" carries far less weight here than "issued on this date, covering these entries". To work through this in order, start with the free verification checklist. The previous article in this series is batteries; the next, food contact materials and kitchenware, covers a different way of splitting the problem, by material rather than by duty. To see how test reports and certifications are recorded, look at a report sample, or get in touch.
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