Revision of EU rules on textile labelling

Primark is an international fashion retailer with over 420 stores across 14 EU member states plus the UK and US and employing more than 70,000 colleagues. Founded in Ireland in 1969 under the Penneys brand, we aim to provide affordable choices for everyone, from great quality everyday essentials to stand-out style for women, men and kids, as well as beauty, homeware and accessories.

AMFEP, the Association of Manufacturers and Formulators of Enzyme Products, supports the Commissions initiative to help consumers make sustainable choices. However, we warn against the inclusion of additional labelling domains linked with the organicity/ being of bio-origin, a property not linked with sustainability and likely to cause confusion with consumers.

We from the Association Campania and Activism for Animals in Industry (CARI) welcome the revision of Regulation 1007/2011 for textiles, introducing comprehensive physical and digital labelling requirements for textile and related products to this end.

Filed in Bulgarian · English published by the European Commission

On behalf of WFTO-Europe, the European branch of the World Fair Trade Organization which gathers social enterprises fully practicing Fair Trade, we submit the feedback in the document in attachment. In sum, we urge the European Commission to ensure the highest extent of transparency through this textile labelling regulation, covering a range of information.

Avery Dennison Corporation is a global materials science and digital identification solutions company that provides branding and information labeling solutions, including pressure-sensitive materials, radio-frequency identification (RFID) inlays and tags, and a variety of converted products and solutions.The company serves an array of industries worldwide, including home and personal care, apparel, e-commerce…

I would like to raise awareness about a significant gap and weakness in the Textile Labelling regulation. The regulation has not taken into account a very sustainable and growing practice: the upcycling. In other words, reusing discarded garments/materials to produce new pieces of higher value.

Since The Sustainable Angle was founded in 2010 its Future Fabrics Expo's main goal was to broaden the fibre basket: alternatives to conventional cotton and alternatives to virgin polyesters and synthetics are the main focus. Our current global fibre demand lacks diversity and has resulted in our world suffocating in petrochemical based materials and the pollution created by them.

Consumption Research Norway SIFO welcomes the revision of the textile labelling rules. SIFO is a not-for-profit research institute at Oslo Metropolitan University (OsloMet). For over 25 years, we have contributed to the knowledge of the consumption of clothing, also including many projects about labelling and consumer behaviour.

The Swedish Textile Importers organization welcomes the revision of EU Regulation No. 1007/2011. We support the general revision and have limited our comments to the following areas in the attached file: - Fibre names - Deviation from general practice - Non-textile part, including vegan leather - Care symbols The Swedish Textile Importers and its members appreciate the possibility of contributing to further Textile…

The European Cultural and Creative Industries Alliance (ECCIA) is composed of seven European cultural and creative industries organisations - Altagamma (Italy), Circulo Fortuny (Spain), Comité Colbert (France), Gustaf III Kommitté (Sweden), Laurel (Portugal), Meisterkreis (Germany), and Walpole (UK) who between them represent over 600 brands and cultural institutions.

Call of Evidence - Revision of EU Rules on Textiles Labeling Contribution of General Chemical State laboratory of Greece, B Chemical Service of Athens, Textiles Leather and Consumer Articles Laboratory An. Tsocha 16, Athens Greece, 29 September 2023 Introducing our Laboratory: The Textiles and Leather Laboratory belongs to the Second Athens Division of General Chemical State Laboratory, General Directorate of…

The Policy Hub Circularity for Apparel and Footwear, uniting more than 700 brands, retailers, manufacturers, and other stakeholders within the industry and representing more than 50% of the apparel and footwear sector, welcomes the EU authorities' efforts to harmonise rules on labelling textile products.

Inditex welcomes the opportunity to contribute to the Call for Evidence on the revision of the Textile Labelling Regulation. Our recommendations are focused on improving the legislative framework for labelling and information provision to consumers in the context of market and policy developments since 2011. Please see our recommendations attached.

Europe India Centre for Business and Industry (EICBI) has reached out to textile companies in India who export their products to EU to get feedback on the proposed new EU rules on textile labelling. The following points offer a concise overview of the main takeaways from our discussions with leaders in the Indian textile industry.

Today, the majority of the fashion and textile sector is opaque, leaving its impacts on the environment and on the people who make our clothes largely unseen from the European consumer, and making it harder to address and remediate them.

ECOS welcomes the initiative from the Commission to revise the Textile Labelling Regulation (TLR) to introduce specifications for physical and digital labelling of textiles, including sustainability and circularity parameters. EU mandatory legislation is needed and necessary to ensure harmonised, consistent and clear rules to provide robust information on the textile labelling.

H&M Group appreciates the opportunity to contribute to the European Commissions Call for Evidence on the revision of the Textile Labelling Regulation (TLR). Our recommendations are based on the experience gathered since the regulation was adopted in 2011.

The European Branded Clothing Alliance (EBCA) welcomes the European Commissions proposal for a legislative initiative on the Textile Labelling Regulation (TLR) and is in favour of this revision, as it represents a significant step towards harmonisation. EBCA would like to present the following recommendations for the Commissions proposed revision of the TLR: 1.

The Fur Free Alliance is an international coalition of more than fifty animal protection organisations, who work together to end the exploitation and killing of animals for their fur. We welcome the opportunity to respond to this call for evidence, particularly in light of the explicit references to fur in the stated objectives of the revision of EU rules on textile labelling.

Textile product labelling must be a good, clear summary of key information for the whole supply chain. People seek products supplied with no harm to humans, non-human animals or environment: 'The Rise of Vegan Fashion 2021' https://www.vegansociety.com/sites/default/files/uploads/downloads/The%20Rise%20of%20Vegan%20Fashion%20Report.pdf Textile product impacts must go through the full supply chain, e.g.

FEAD supports the revision of EU rules on textile labelling to ensure the correct information of consumers. The waste management sector needs information on the waste received, but a label at product level will have little added value for waste managers working with big and bulky flows and applying automatic (sorting) processes.

IKEA welcomes the opportunity to contribute to the Commissions call for evidence on the revision of the Textiles Labelling Regulation. We believe that the update to the legislation is overdue, both from a perspective to increase clarity, flexibility and simplification of use, as well as to maintain consistency with ongoing and upcoming legislations.

Texfor, as a member of EURATEX, aligns with the comments and suggestions presented in EURATEX's document. This document underscores that, on the whole, Regulation 1007/2011 has effectively served its purpose and achieved its overarching goals of providing consumers with valuable information regarding textile product properties.

Respect for Animals is pleased to be given the opportunity to submit evidence to the European Commission's call for evidence on the revision of EU textile labelling rules. We campaign exclusively on the issue of fur and our response will therefore focus on how the call for evidence relates to the labelling of fur products containing real animal fur. Please see the attached document.

Confartigianato Imprese welcomes the future revision of the Regulation for the labeling of textile products as it believes it is essential to guarantee consumers correct and complete access to all relevant information regarding the origin and sustainability of textile products.

ATEVAL, as a member of EURATEX, aligns with the comments and suggestions presented in EURATEX's document. This document underscores that, on the whole, Regulation 1007/2011 has effectively served its purpose and achieved its overarching goals of providing consumers with valuable information regarding textile product properties.

CONSEJO INTERTEXTIL ESPAÑOL, as a member of EURATEX, aligns with the comments and suggestions presented in EURATEX's document. This document underscores that, on the whole, Regulation 1007/2011 has effectively served its purpose and achieved its overarching goals of providing consumers with valuable information regarding textile product properties.

There is a need for regulation to limit the overproduction of textiles. There has been a massive increase in textile production, far exceeding global population growth. According to the EU textile industry, overproduction of textiles is the overriding problem that needs to be addressed.

Filed in Danish · English published by the European Commission

GINETEX is the International Association for textile care labelling, a non-profit organisation with 22 national committees worldwide, and is an expert in textile labelling and textile care labelling on a worldwide basis.

We appreciate the opportunity to submit our feedback to the revision of the Textile Labelling Regulation (EU) 1007/2011 (TLR). In essence, we wish to touch upon following points: To help consumers, businesses and legislators to make insightful decisions, we believe that a systematic structure and coherent definitions in the TLR will help to reduce complexity and increase the relevance of the information to all…

C&A welcomes the proposal for revision of the textile labelling regulation (TLR) and appreciate that the consultation and drafting process allow for including the requirements negotiated under the Circular Economy Action Plan. We would like to draw some lessons learnt in the document attached

We welcome the EU's initiative to revise Textile Regulation 1007/2011, a step that aligns well with its broader goals for sustainability and consumer protection. The existing fur labelling system, particularly Article 12, falls short. A significant loophole allows products with more than 20% real fur by weight to avoid labelling, leaving consumers uninformed (Fur Free Alliance, 2017, p. 6).

Resortecs is the textile circularity frontrunner, founded in Belgium, that enables effective and efficient disassembly of textiles through its breakthrough ecodesign innovations - heat-dissolvable stitching threads (Smart Stitch) and thermal disassembly systems (Smart Disassembly) - which help to replace textiles designed for waste with textiles eco-designed for disassembly, which in turn enables material recovery…

The International Fur Federation welcomes the objectives of the Textile Labelling Regulation revision, which aims to harmonise labelling rules for textile products and related products. We hope that this will enhance regulatory clarity and consistency. Additionally, we expect it to improve consumers' access to relevant information and care instructions.

Decathlon welcomes the revision of EU Regulation No. 1007/2011 and would like to address certain issues regarding current textile regulations. Regulation (EU) No. 1007/2011, which governs textile fiber names, labeling, and marking of textile products, currently requires manufacturers to include permanent labeling of textile composition.

CNA welcomes the European Commission’s decision to consult stakeholders on the future proposal for the revision of the EU rules on textile labelling. As CNA, we believe that the development of a European strategy for sustainable product policy based, among other provisions, on the revision of the Textile Labelling Regulation, can significantly contribute to determining the added value and competitiveness of products…

Filed in Italian · English published by the European Commission

Lav giving this opportunity to respond to the call for evidence with regard to the revision of EU rules on textile labelling. As an animal rights organisation, our focus will be primarily on the Animal Derived Materials (ADMS) and the failure of Regulation (EU) No 1007/2011 on fibre names and related labelling and marking of the fibre composition of textile products to protected consumers.

Filed in Italian · English published by the European Commission

The Chamber of Skilled Crafts and Trade in Koblenz represents the interests of around 21,000 member companies in the northern Rhineland-Palatinate/Germany. We thank for the opportunity to comment on the planned amendment of the present regulation. In principle, we are in favour of transparency in textiles along the entire supply chains.

First of all, we would like to make clear that stricter labelling for animal fur products cannot in any way be a substitute or alternative to a European ban on the production and marketing of fur in the European Union. We therefore fully support the European Citizens’ Initiative Fur Free Europe.

Filed in Dutch · English published by the European Commission

- Material declaration on the full weight of the product and disclosure of all components without exceptions. For recycling decisions the full material declaration is necessary. For some products spectroscopy can help to detect material composition to make a recycling stream decisions (monolayer products) but for many textiles with multilayer aspects the full material composition is crucial to know.

The U.S. Cotton Trust Protocol welcomes the opportunity to contribute to the European Commissions Call for Evidence regarding the revision of the Textile Labelling Regulation. The Trust Protocols mission is to bring quantifiable and verifiable goals and measurement to the key sustainability metrics of U.S.

FER is the Spanish Federation of Recovery and Recycling, as an employers' association, brings together the interests of the waste recycling sector and defends them in the different economic, social and environmental fields at national and international level.

Human rights violations take place in the garment sector on a great scale[1]: One of the contributing factors to this is a lack of transparency. Consumers that want to make an informed choice and buy sustainable products have difficulty finding the right information. Workers that want to address problems dont know who the buyer is and cannot reach them.

We share with the European Commission the need to revise the labelling of textile products. By living in a global market, the issue is amplified not only for products produced in Europe, which are more controlled and traceable, but also for products produced outside the EU.

Filed in Italian · English published by the European Commission

Novozymes input to the revision of the EU Textiles Labelling Regulation Novozymes welcomes the opportunity to provide its response to the Commissions call for evidence on a revision of the EU Textiles Labelling Regulation.

European Wool Association (EWA) considers the labelling of wool is long overdue for revision. EWA which represents the interests of wool producers throughout Europe has a number of concerns pertaining to the current labelling used on wool products. Our first wish is for 100% traceability and that proof of origin should be guaranteed in future (e.g.

The European Environmental Bureau (EEB) welcomes the Commissions initiative to evaluate the possibility of revising the Textile Labelling Regulation (TLR). The attached document contains considerations we urge policymakers to explore in the evaluation and impact assessment.

Finnish Textile and Fashion Association takes a positive view on the revision of textiles labelling rules in the EU as initiated by European Commission. This revision should take a holistic view on labelling of textiles but also make the current regulation up to date, companied with a guiding document.

Zalando is a leading European E-Commerce destination for fashion and lifestyle. Founded in Berlin in 2008, we service 51 million active customers in 25 markets, offering clothing, footwear, accessories, and beauty. The assortment of international brands ranges from world-famous names to local labels. Zalando offers a one-stop fashion experience of inspiration, innovation, interaction and shopping.

We share the Commissions concerns about labels missing key information that helps consumers make sustainable choices. Incomplete labels confuse consumers and lead to wasteful consumption. When reviewing the Textile Labelling Regulation, the EC should align it with other laws like the Waste Framework Directive, ESPR, and the Green Claims Directive.

Animal welfare Sweden welcomes this review and wishes to influence the part dealing with related products such as bones, feathers, leather, fur, wool and exotic skin products, etc. We do not believe that any type of labelling should include welfare labelling for animal products in the context of this review. A welfare label should be introduced in consultation with experts in the field of animal welfare.

Filed in Swedish · English published by the European Commission

In anticipation of the revision of EU textile labelling rules by the European Commission, the Netherlands would like to share its views on strengthening European policy concerning all potentially relevant labelling domains for textile products. Please find our views and supporting research studies attached.

The TÜV Association welcomes the initiative of the European Commission to assess and potentially review the Textile Labelling Regulation (EU) 1007/2011. Consumers must have better access to and confidence in all relevant information on textiles, in particular with regard to social and environmental sustainability aspects. Please find our feedback attached.

Djurens Rätt welcomes this revision and the opportunity to contribute with evidence. As the oldest and largest animal protection organisation in Sweden, our focus will be primarily on the labelling of other non-textile materials, such as fur. This is to adequately protect consumers regarding animal products that are placed on the EU market. See attached PDF for our general comments.

RREUSE, the European network of social enterprises active in repair, re-use and recycling, welcomes the intention to review the Textiles Labelling Regulation as an opportunity to ease textile waste management and extend textile products lifetime. Improving rules on fibre composition determination and providing more reliable information to sorters will facilitate the sorting process.

Reform of Textile Product Labeling Current Situation: Currently, mandatory labels on textile products sold in Finland include: Fiber content in Finnish and Swedish using official fiber names Care instructions: verbally in Finnish and Swedish or using symbols Identification of the responsible party: brand, importer, manufacturer, etc.

UNIC Concerie Italiane, the trade association, a historical member of Confindustria, representing the Italian tanning industry, welcomes the opportunity to contribute to the revision of the EU Regulation on textile names and labelling (Regulation (EU) No 1007/2011).

Filed in Italian · English published by the European Commission

It must be precise and standardised without leaving room for interpretation, as is the case for certain aspects of the textile/fashion world, one of which has been confused with azo dyes. Here, apart from the REACh Regulation, which explains it very well, many NGOs that are unreliable, but with great media resonance, have always used the term azotic or azo as a synonym of a serious danger to health.

Filed in Italian · English published by the European Commission

Plastics Recyclers Europe, the association representing the plastic recycling industry at the EU level, welcomes the ECs initiative to revise the EU textile labelling rules, as an opportunity to introduce requirements on communicating on the environmental aspects of textiles, in line with the objectives of the EU Textiles Strategy. Please find attached our feedback to the public consultation.

The Société Anti Fourrure association welcomes the revision of textile regulation 1007/2011 by introducing comprehensive requirements in physical and digital labeling of textiles and related products.This revision is relevant and necessary for the Commission's ambitions towards a more circular economy, more sustainability and better consumer protection.

MovingMood welcomes this opportunity to express our concern for accessibility in textile labels. We are a consultancy and training company specialise in accessibility and inclusive fashion. In our view, textile labels need to be accessible to all consumers, including seniors and people with disabilities. Accessibility is a precondition for participation in society on equal basis with others.

As a regional market surveillance authority responsible for textile labelling, we handle numerous cases in this legal field. The equal treatment of stationary trade and online trade is of particular concern to us. Unfortunately, only limited requirements regarding labelling apply to online and wholesale trade, as Article 16 and Article 14 (3) of Regulation (EU) No.

We share the Commissions concerns about labels missing key information that helps consumers make sustainable choices. Incomplete labels confuse consumers and lead to wasteful consumption. When reviewing the Textile Labelling Regulation, the EC should align it with other laws like the Waste Framework Directive, ESPR, and the Green Claims Directive.

Comments Södra considers that there is a great deal of better fibre identification and labelling of text-titanium, partly to make it better for consumers to make more informed decisions, but above all to facilitate the management of textile waste for both reuse and recycling.

Filed in Swedish · English published by the European Commission

The European Commission strives for scaling fiber-to-fiber recycling to tackle the increasing amount of textile waste in Europe. Hence, we propose to oblige textiles producers to explicitly declare the recycled content derived from post-consumer garment waste. This would significantly increase transparency and enable consumers to make informed buying decision.

Textile Labelling Regulation (revision) MTLC response We share the Commissions concerns about labels missing key information that helps consumers make sustainable choices. Incomplete labels confuse consumers and lead to wasteful consumption. When reviewing the Textile Labelling Regulation, the EC should align it with other laws like the Waste Framework Directive, ESPR, and the Green Claims Directive.

We share the Commissions concerns about labels missing key information that helps consumers make sustainable choices. Incomplete labels confuse consumers and lead to wasteful consumption. When reviewing the Textile Labelling Regulation, the EC should align it with other laws like the Waste Framework Directive, ESPR, and the Green Claims Directive.

IFOAM Organics Europe thanks the Commission for the publication of the EU strategy for sustainable textiles. We would like to make two points: (1) the current fast fashion production of textiles has important environmental & social impacts, and (2) organic textiles production has much fewer environmental & social impacts, but current EU rules allow for greenwashing as the term organic is not protected for textiles.

We share the Commissions concerns about labels missing key information that helps consumers make sustainable choices. Incomplete labels confuse consumers and lead to wasteful consumption. When reviewing the Textile Labelling Regulation, the EC should align it with other laws like the Waste Framework Directive, ESPR, and the Green Claims Directive.

EurEau welcomes this initiative. The revision should be used to steer textile consumption patterns in a more sustainable direction by increasing transparency on environmental impacts and, hence, make sustainable practices more visible. Textile life cycles strongly affect the quality and quantity of water resources.

The European Industrial Hemp Association shares the Commissions concerns about labels missing key information that helps consumers make sustainable choices. Incomplete labels confuse consumers and lead to wasteful consumption. When reviewing the Textile Labelling Regulation, the EC should align it with other laws like the Waste Framework Directive, ESPR, and the Green Claims Directive.

Textile Labelling Regulation (revision) MTLC response We share the Commissions concerns about labels missing key information that helps consumers make sustainable choices. Incomplete labels confuse consumers and lead to wasteful consumption. When reviewing the Textile Labelling Regulation, the EC should align it with other laws like the Waste Framework Directive, ESPR, and the Green Claims Directive.

Introduction of regulatory exemptions for “recovered garments” In the best case, consumers already give up their worn clothing in separate collection devices. Part of this product is in good condition so that it can be resold (with small repairs if necessary). In this environmental best-case scenario, the collector and user does not have information on the composition and materials of the clothing.

Filed in German · English published by the European Commission

As a small sustainable fashion label, we would like to draw attention to upcycling in the sustainable fashion sector and in the context of the revision of the Textile Labelling Regulation. We process residues and end-of-life materials in our products and are affected by the lack of rules on upcycling or the non-existent exemption from the labelling of upcyling fashions in the previous Textile Labelling Regulation.

Filed in German · English published by the European Commission

Humane Society International/Europe (HSI) welcomes this opportunity to respond to the call for evidence with regard to the revision of EU rules on textile labelling. As an animal protection organisation, our focus will be primarily on the failure of Regulation (EU) No 1007/2011 on fibre names and related labelling and marking of the fibre composition of textile products to adequately protect consumers, particularly…

Include organic in the Textile Regulation Voluntary sustainability standards (VSS) play an important role in promoting and securing sustainable production. The UN Forum on Sustainability Standards defines Voluntary Sustainability Standards are rules that producers, traders, manufacturers, retailers or service providers may be asked to follow so that the things they make, grow or do dont hurt people and the…

As an upcycling fashion designer, I urge the European Commission when revising the Textile Labeling Regulation, to consider (1) clothing made through the process of upcycling and (2) exclude upcycled clothing from the current textile labelling obligations (just like second hand clothes are). WHY?

The Bavarian State Ministry for the Environment and Consumer Protection is grateful for the opportunity to play its part in the further development of a modern and forward-looking labelling of textiles in the context of the EU Textile Strategy.

Filed in German · English published by the European Commission

We believe that it should be ensured that consumers have access to all relevant information on textile products, and related products, especially information on the presence of allergenic substances, in an accurate, intelligible and comparable manner, without misleading information, including information on the products they intend to purchase and information on how to use them in an appropriate and responsible…

Filed in Spanish · English published by the European Commission

As the increasing understanding of the environmental impact of textile production and consumption has not so far been materialised in effective policy tools of the challenges, ecolabeling will therefore help consumers to select environment friendly products, while meeting high demands on occupational health, safety, and usability.