No, it's not a user guideit's the EU product label! · PDF fileit's the EU product label! ......
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No, it's not a user guide... it's the EU product label! News & developments on labelling in the EU applicable to the fashion industry February 2015 www.pwc.nl
Transcript of No, it's not a user guideit's the EU product label! · PDF fileit's the EU product label! ......
No, it's not a user guide... it's the EU product label!
News & developments on labelling in the EU applicable to the fashion industry February 2015
www.pwc.nl
PwC
Agenda
• Why this webinar
• Regulatory framework
− Amendments
− Developments
• Origin
• CITES
• Care & Size
• Environmental
• Safety
• Unfair commercial practices
• Footwear
• Textile fibers
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Why this webinar
• Updated EU legislation on labelling of textiles entered into force
−transition period recently ended
• Reviews and withdrawal of product from stores due to lack of compliance −need for recap on current legislation and summary on
changes
• Webinar also aims at facilitating relevant experience exchange on the matter amongst the participants
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Do you know where to look? EU regulatory framework
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Footwear CITES
Unfair commercial
practices
Care & Size
Safety Environ-mental
Textile fibers
Origin
Labelling requirements
Community/Union Customs Code
There is still no consensus on country of origin marking. In practice the non-preferential rules
of origin and the WTO’s harmonized origin working program are followed.
Regulation 1320/2014
The EU’s Trade Regulation follows the provisions of the Convention on International
trade in Endangered Species of Wild Fauna and Flora (CITES). There are many additional
implementing regulations related to CITES. Probably the most relevant for
importers/exporters is the implementing regulation 792/2012 on permits. Enforcement
provisions are included in national legislation.
Directive 94/11/EC
Rules on labelling of the materials used in the main components of footwear.
Regulation EU 1007/2011
This regulation consolidates and replaces three Directives:
2008/121/EC (fiber names), 96/74/EC (methods for analysis of binary textile fiber mixtures) and 73/44/EEC (methods for analysis of ternary textile fiber mixtures)
Directive 2005/29/EC
Amongst other, the Directive on Unfair Commercial Practices addresses and regulates on misleading actions in commercial practices (e.g. unclear, ambiguous descriptions or hiding information, origin is an example of this).
Directive 2001/95/EC
The Directive on General Product Safety is a framework that makes CEN standards. Products complying with such standards are presumed safe. This is a kind of “safety net” for those cases in which products are not covered by a more specific (garment/footwear/accessories) legislation.
ISO 3758/GINETEX & EN 13402
The nature of this standards is voluntary.
However, these widely applied accepted standards on care & size labelling in the fashion
industry..
Regulation EC 66/2010
This is the EU’s voluntary environmental “Ecolabel” regulation. Besides there are other
(inter)national voluntary environmental programs as Blue Angel, Öko-tex and GOTS.
No, it's not a user guide...it's the EU product label! February 2015
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Origin
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Origin
Community/Union Customs Code
There is still no consensus on country of origin marking. In practice the non-preferential rules of origin and the WTO’s harmonized origin working program are followed.
No, it's not a user guide...it's the EU product label! February 2015
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CITES
Regulation 1320 / 2014
• The EU’s Trade Regulation follows the provisions of the Convention on International trade in Endangered Species of Wild Fauna and Flora (CITES)
• There are many additional implementing regulations related to CITES
• Probably the most relevant for importers/exporters is the implementing regulation 792/2012 on permits
• Enforcement provisions are included in national legislation
CITES
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Care & Size
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Care & Size
ISO 3758/GINETEX & EN 13402
• Care & size standards of voluntary nature
• Widely accepted
• Pictograms are trademark of GINETEX, only members may use them (against payment for direct membership or through national associations)
• No major changes expected
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Environ-mental & sustain-ability
Regulation EC 66/2010
• EU’s voluntary environmental “Ecolabel” regulation.
• Scope: all products subject to distribution / consumption against payment of offered for free (exception of medicinal products)
• Concentrates on environmental impact, reduction of us hazardous materials, etc.
• There are other (inter)national voluntary environmental / sustainability programs as Blue Angel, Öko-tex and GOTS
No, it's not a user guide...it's the EU product label! February 2015
Environmental & sustainability
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Environmental & sustainability
Telegraph.co.uk
“Company X underpays workers in
Cambodia”
Swedish TV documentary program Kalla Fakta has revealed that [Company X] is not
paying its Cambodian garment workers a living wage The miminum wage for these
workers is currently $61 per month, which is 25% of what constitutes a living wage in the
country…
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Safety
Safety
Directive 2001/95/EC
The Directive on General Product Safety is a framework that makes CEN standards. Products complying with such standards are presumed safe. This is a kind of “safety net” for those cases in which products are not covered by a more specific (garment/footwear/accessories) legislation.
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Safety
REACH (Regulation 1907/2006)
• Many restrictions nowadays under REACH framework
− Substances of Very High Concern (SVHCs)
− Restricted substances
• Requirements depend on qualification (SVHC or restricted)
Azo Dyes (Directive 2002/61)
• Only limited number of products banned
− Containing aromatic amines
− Testing methods harmonized No, it's not a user guide...it's the EU product label!
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Safety
Biocidal products (Regulation 528/2012)
• Protection against harmful organisms
• Used to be governed by Directive
- Replaced by Regulation
• Background:
- Protection for humans and environment…. but also ‘functioning of the internal market’
• Use of biocidal products: authorization needed
- Product needs to be approved
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Safety
Articles treated with biocidal products
• Import restricted
−Only active substances that are approved (ECHA)!
−i.e. no longer allowed to use arsenic or DMF
• Need to provide detailed info on the treatment to consumers (when asked for)
• In some cases (i.e. when biocidal properties are claimed) −Info on label (easily understandable and visible)
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Safety
Nanomaterial
• No explicit requirements under REACH or under CLP (Classification, Labelling and Packaging)
• ‘Substance’ definition (to catch all...)
• Nanomaterial working group (within ECHA)
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Unfair commercial practices
Unfair commercial
practices
Directive 2005/29/EC
Amongst others, the Directive on Unfair Commercial Practices addresses and regulates on misleading actions in commercial practices (e.g. unclear, ambiguous descriptions or hiding information, origin is an example of this).
No, it's not a user guide...it's the EU product label! February 2015
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Do you know where to look? EU regulatory framework
Footwear
Directive 94/11/EC
Rules on labelling of the materials used in the main components of footwear.
The current directive on footwear labelling was last amended in 2007 and as such, no direct changes have been implemented ever since. However, it is important to bear in mind that the amendments on the regulation on textile fiber names & labelling might impact the footwear labelling directive. The concept of ‘textile’ to determine the textile content in footwear is linked to the regulation on textile fiber names & labelling.
No, it's not a user guide...it's the EU product label!
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Do you know where to look? EU regulatory framework
Textile fibres
Regulation EU 1007/2011
Replaces three textile Directives
• 2008/121/EC (fiber names)
• 96/74/EC (methods for analysis of binary textile fiber mixtures)
• 73/44/EEC (methods for analysis of ternary textile fiber mixtures)
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Regulation 1007/2011 on textile fibre names & labelling
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New regulation on textile labelling
Entry into force
Transition period
New rules are
Compulsory to
all stakeholders!
May 8, 2012.
Products already marketed prior to the entry into force could still use the labels according to the old legislation
November 9, 2014.
Published in the EU‘s Official Journal in October 18, 2011.
Are you compliant? If not, do you know what needs to be amended?
Today, items are being taken off shops floors in the EU due to improper labelling!
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Amended regulation on textile fibre names & labelling FAQs
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Which language should I
use?
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Amended regulation on textile fibre names & labelling FAQs
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I am not lying, it is
100% Australian pure wool, can I say it
so?
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Amended regulation on textile fibre names & labelling FAQs
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Can I state
‘Lycra’?
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Amended regulation on textile fibre names & labelling FAQs
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Do I need to label bags
made out of textiles?
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Amended regulation on textile fibre names & labelling FAQs
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What about these?
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Amended regulation on textile fibre names & labelling Key items
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What’s new?
• The previous 3 ‘textile directives’ are consolidated and replaced by this regulation • Updated list of textile fibre names • The use of fibre names for other fibres is prohibited • Additional information must be stated separately (e.g. 100% wool – Merino instead of 100% Merino wool) • A more detailed description of wool • Description of procedure to apply for a new fibre name
Are your labels ready?
• The language of the Member State in which the products will be marketed is compulsory unless such Member State requires otherwise
• Updated methods of analysis to check information on labels or markings
• Exemption applicable to customized products made by self-employed tailors
• Requirement to indicate content of non-textile parts of animal origin (e.g. feather, bone, leather, pearl, horn): “contains non-textile parts of animal origin”
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New developments Will origin marking will ever become mandatory?
Proposal
- Obligatory origin marking has been long in discussion
- A first proposal in 2010 did not make it through the Council
- A new proposal amending the consumer product safety directive was voted favorably by the Parliament in April, conclusion pending
- Until then, origin marking remains non-obligatory although many EU companies choose to use origin marking based upon the EU non-originating rules of origin and the harmonized working program of the WTO
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Do’s & Don’t Can you tell these labels are compliant?
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To consider Suggestions
• Is my product subject to textile labelling requirements?
• Which language should I use?
• How do I show the fiber content? (check wording, e.g. 100 wool merino)
• Is there any non-textile animal content?
• Does this product fall under CITES scope?
• Do I need to ask for import/export permits/registrations?
• To which Member State/entity should I address my queries?
• Can I / do I wish to use “made in” marking? What are the rules?
Overall, avoid misleading information!
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Thank you
WARNING: The following disclaimer and copyright notices must be customised for your local territory - if you need assistance with appropriate wording, contact your local Risk Management or Office of General Counsel.
Contacts: Jos Verstraten Claudia Buysing Damste Director Senior Manager Customs & International Trade Customs & International Trade +31 88 792 34 74 +31 88 792 38 11 [email protected] [email protected]
Domenick Gambardella Anthony Tennariello Maytee Pereira Partner Partner Director Customs & International Trade Customs & International Trade Customs & International Trade +1 646 471-3791 +1 646 471-4087 +1 646 471-0810 [email protected] [email protected] [email protected]
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No, it's not a user guide...it's the EU product label!
