China is a big exporter of textiles and clothing, and textile and clothing products will inevitably contain chemical substances, such as dyes, additives or polymer materials. The registration and evaluation requirements of some chemicals in products will have a great impact on the export of these final products in China, and once some chemicals are banned by the European Union, the export of final products will be affected. Therefore, textile and garment enterprises must attach great importance to the influence of REACH regulations.
In terms of textiles and clothing, the technical regulations formulated by the European Union mainly involve human health and safety, consumer rights protection and so on. It mainly includes the Directive on the Restriction of Hazardous Substances (76/769/EEC) and a series of amendments and supplementary clauses, the REACH Regulation (EC) No1907/2006) and the Directive on General Safety Requirements of Products (2006/5438+0/95/EC).
This paper mainly introduces the product regulations, safety standards, label requirements and corresponding precautions applicable to children's wear, including REACH, en standards, GPSD instructions and shelf requirements of Amazon Europe Station.
How do I know if my products are classified as textiles?
According to EU textile regulations, "textile products refer to any raw materials, semi-finished products, processed products, semi-finished products, manufactured products, semi-finished products or cosmetics made of textile fibers, regardless of their mixing or assembly process." In addition, the following products are also regarded as textiles.
A. products containing at least 80% by weight of textile fibers.
B. products that contain textile ingredients and form part of the product.
River regulation
REACH is the abbreviation of the Regulation on Registration, Evaluation, Licensing and Restriction of Chemicals (EU Regulation (EC)No.1907/2006) issued by the European Union, which is responsible for supervising restricted chemicals and their potential impacts on human health and the environment, involving the production, trade and use safety of chemicals.
Generally speaking, REACH covers all consumer goods sold in the EU, including children's clothing, adult clothing and textiles. In the ordinary manufacturing process of textiles, hundreds of chemicals need to be used. For example, sulfuric acid used in the process of making clothes. Therefore, in order to avoid harm to people, products must comply with REACH regulations.
The main contents of REACH regulations are the registration, evaluation, licensing and restriction of chemicals. Among them, there are mainly requirements for the registration, licensing and restriction of textiles and clothing, especially the restrictions (the restrictions of harmful substances are listed in Annex XVI of REACH regulations) have become the main reason for EU RAPEX to notify and recall China's textiles and clothing, which deserves the attention of relevant enterprises!
1. Registration: Registration requires the manufacturer or importer to provide relevant information about chemicals exceeding 1 ton per year, including the submission of technical files. Among them, there should be information about the substance and how to manage its use risk. For substances whose annual quantity exceeds 10 tons, a chemical safety report shall be submitted to illustrate the characteristics of its safety assessment.
2. Evaluation: The evaluation process will allow the competent authorities to decide whether further testing and evaluation are needed and whether the information provided by the registrant meets the regulatory requirements (i.e. document evaluation); For the selected substances, if it is suspected that there is a risk to human health and the environment, it is necessary to carry out material evaluation. Evaluation provides a mechanism to ask the business community for more information. The evaluation will also make recommendations on actions to be taken under the authorization or restriction procedures.
3. Authorization and restriction: Only those substances that are highly concerned need authorization. Substances of very high concern refers to carcinogens, mutagens, substances toxic to reproductive system, persistent, bioaccumulative and toxic substances, permanent and highly bioaccumulative substances and equivalent substances.
Since REACH is an EU regulation, it is applicable to all EU countries. Therefore, when importing goods into the EU, you must know which regulations of REACH must apply to your products. The main roles under REACH regulations are as follows:
1. EU manufacturer, providing products containing any chemical substances.
2. Importers in the EU buy products containing any chemical substances outside the EU.
3. Companies or users who handle any chemicals in industrial or professional activities in the EU.
Please note that companies established outside the EU are not obliged to comply with REACH, even if they export their products to the EU. The responsibility will shift to the importers in the EU.
Although REACH is not applicable to other countries outside the EU, it has also become an international reference for other countries. For example, Switzerland is not a part of the EU, but they usually accept EU regulations.
How do I know which chemicals and heavy metals are restricted?
The REACH regulation provides a list of restricted substances for reference.
You can spend some time reading the restricted list to make sure that your product does not contain any listed substances.
However, the reading restriction list is not very practical. In many cases, it is difficult to know what chemicals are contained in your products. Therefore, there will be a professional testing company to help you evaluate the chemicals, heavy metals and pollutants to be tested. Therefore, as an importer or distributor, it is recommended to carry out laboratory tests to ensure that your products meet the requirements.
Hazardous substance requirements
In the European Union, although textiles and clothing are not as sensitive to consumers as food, in recent years, European consumers have attached great importance to the environmental protection requirements of textiles and clothing because many textiles and clothing have been in direct contact with the skin and even the mouth for a long time, coupled with the strong publicity of the EU government and related industries.
1On July 27th, 976, the Council of the European Community issued the directive 76/769/EEC on restricting the sale and use of certain dangerous substances and preparations, which is usually called the "restriction directive" and involves almost all industries, including the regulations on textiles and clothing. With the development of science and technology, the continuous innovation of product technology and the continuous improvement of people's understanding level, the directive has been revised 33 times as of May 2009, and the categories of restricted substances in the original directive have been adapted 18 times. The directive has been revised and supplemented many times, forming a relatively complete legal system of dangerous substances. It is worth noting that since June 2009 1, the appendix VX of REACH has replaced the appendix 1 of 76/769/EEC, but both contents are consistent. Therefore, although the directive 76/769/EEC has become invalid, its contents are still valid, but the contents are consistent when it is transferred to Appendix XVll of REACH. Therefore, although Directive 76/769/EEC has become invalid, its provisions are still valid, and it has only been transferred to Appendix XVll of REACH.
In the field of textiles and clothing, the harmful substances involved in the restriction directive mainly include azo dyes, nickel and cadmium contents, heavy metals, polychlorinated biphenyls (PCB), polybrominated biphenyls (PBB), dichloroethylene, trichloroethylene, chloroform and carbon tetrachloride, perfluorooctane sulfonic acid and so on. In addition, with the implementation of REACH regulations, the original harmful substance restriction directive has been basically abolished. Therefore, the industry can only refer to the specific requirements in Appendix XV of REACH regulations when actually inquiring about the requirements for limiting hazardous substances.
1. Disable uniform dyeing.
2. Banlan dye
3. Flame retardant finishing agent
4. Pentachlorophenol
5. polychlorinated biphenyls (PCBs)
6. Organotin compounds
7. Heavy metals
1 nickel release
2 cadmium release
hexavalent chrome
8. Perfluorooctane sulfonic acid
9. Perfluorooctanoic acid
Substances of very high concern (SVHC)
To know which substances are under control, you can check them on ECHA's website.
ECHA occasionally adds new substances to the list. However, exporters don't need to track the update of the restricted list for a long time, because testing companies usually get the latest regulatory requirements faster and provide testing solutions. Before exporting to the EU, it is recommended to obtain information about REACH regulations and book a REACH compliance test.
expense
The cost of children's REACH test depends on the material and color of the product. The test is divided into color and fabric tests. The more colors and fabrics, the higher the cost. Usually, material identification, physical and chemical tests, toxicological tests and ecotoxicological tests will be carried out during the test. The fee also includes a detailed report on product certification.
risk
Some textiles and clothing parts (such as zippers and buttons) are most likely to contain excessive restricted chemicals and heavy metals. Please note that whether the laboratory test is successful or not, you must bear the cost of the test.
EU textile labelling rules
According to EU textile and clothing regulations, products must be labeled or marked when they are sold in the market. If your children's clothing product contains at least 80% textile fiber, the product must indicate the fiber composition (for example, 100% polyester fiber or 100% cotton).
Labels must be permanently attached to clothes so that consumers can easily obtain relevant product information. Moreover, textile label paper is not suitable. Manufacturers or traders must create their own textile label files (preferably in. Ai or. Eps format) and then hand it over to the manufacturer before mass production.
Fiber composition
As mentioned above, according to the EU textile regulations, the fiber content must be provided on the product label. Some common fibers in textile industry and their characteristics are listed here.
Silk (smooth fabric, high gloss)
Wool (warm)
Nylon (durable, strong, light and fast drying)
Polyester fiber (durable, strong, light and quick-drying)
Cotton (light weight, good water absorption)
Spandex (elastic, strong and light)
Label position
Labels should be permanently affixed to textiles. For example, a T-shirt, the label is usually attached to the inside of the product. Generally speaking, textile products must have durable, readable and easy-to-see labels on the products or packaging.
measure
So far, the coordination of the size system is covered by the European voluntary standard EN 13402, which stipulates the size of clothes. However, it does not include the size label of textile products, and there is no obligation to apply this standard.
maintenance instruction
Similar to the size label, it is not mandatory according to the EU textile regulations. However, if you choose to include maintenance instructions on the product, you should pay attention to the fact that the trademark contains maintenance symbols.
country of origin
In the EU, the country of origin label is mandatory. However, if you choose to indicate the country of origin on the label, you must not mislead consumers and clearly indicate it.
language
The information on the label should be written in the official language of the EU country where the textiles are located. For example, in Germany, you should take German as the official language of Germany.
Label information
In addition to the label files, you must provide the following information to ensure that these files are labeled correctly:
Label size
Materials used
colour
location
Packaging information
1. Provide information about collection, reuse and material recovery on the packaging to inform users.
2. Any other conformity marks or label requirements shall also be printed on the product packaging.
Label parts summary:
What information should be included or not included in the label?
Summarized as follows:
1. The fiber components in the products must be marked on the textiles.
2. Non-woven parts of animal origin must be clearly marked (such as fur or leather)
3. Except code, labels should not contain abbreviations.
4. EU law does not require nursing labels (but it is still recommended to add them)
5. No manufacturer's logo is required
General product safety directive (GPSD)
In order to make up for the differences in laws and regulations on consumer safety protection among EU countries and ensure the safety of products on the market, in 200 1 year, the EU revised the original General Directive on Product Safety (92/59/EEC) and adopted a new General Directive on Product Safety (200 1/95/EC, abbreviated as GPSD). The European Union issued the Regulation (EC) in 2008 and 2009 respectively, which has been fully implemented since June 65438+1October 65438+May 2004, and the original Directive 92/59/EEC has also become invalid. In 2008 and 2009, the EU promulgated RegulationNo. 765/2008 and RegulationNo. 596/2009 respectively, which revised the GPSD. The directive covers many consumer goods except the service field, not only for new products, but also for second-hand products. In addition, the directive does not apply to products for which specific product directives have been formulated.
First, the scope of application of the directive.
The directive applies to but is not limited to the following products: clothing, medicines, personal gardening supplies, food and beverages, household items, baby products, chemicals and pesticides, consumer fireworks, motor vehicles, etc. Therefore, textiles and clothing fall under the jurisdiction of the directive.
Second, the product general safety requirements
This directive has made principle requirements for the general safety of products, and its main contents include:
(1) The manufacturer is responsible for putting only safe products on the market;
(2) When the specific laws and regulations of * * * * do not stipulate the safety of the product involved, the product shall comply with the relevant laws of the Member State where it is sold;
(3) When evaluating product conformity according to general safety standards, the following factors should be considered: whether there are national voluntary standards transformed from European standards; Whether the member countries of the place of sale have formulated standards; Whether there are guidelines for product safety assessment recommended by the Committee; Technical status; Consumers' reasonable expectations for product safety.
(4) The formulation of the directive also stipulates that even if the product meets the basic safety requirements of the directive, once there is evidence that the product is dangerous, the law enforcement agencies of member countries can take relevant measures to restrict the product from being put on the market, such as requesting to withdraw the product or recall the product.
Three. Responsibility of manufacturers and distributors
The directive requires manufacturers and distributors in the product supply chain to ensure the safety of products put on the market and cooperate with law enforcement agencies. When manufacturers and distributors clearly know that the products put on the market are dangerous and do not meet the safety requirements based on the information and professional knowledge they have, they should immediately notify the law enforcement agencies of member States so as to take corresponding measures to prevent users from being hurt.
1, manufacturer's responsibility
Without proper warning, it is difficult for consumers to find some safety of products, so the directive requires manufacturers to provide relevant information to consumers so that they can evaluate the possible dangers of products in normal use and take necessary preventive measures. At the same time, it is pointed out that the warning provided by the manufacturer cannot exempt the responsibility of meeting other requirements of this directive.
Production enterprises should take corresponding measures according to the characteristics of products, inform the possible dangers of products in time, and withdraw the products with problems to avoid causing dangers. Measures that can be taken include labeling the identity and detailed information of the manufacturer and the batch of the product on the product or product package, sampling and testing the products on the market, and investigating the complaints of consumers. At the same time, the manufacturer shall inform the distributor of the regulatory measures taken.
2, the dealer's responsibility
This directive requires the distributor to help meet the safety requirements specified in this directive, especially not to provide products that do not meet the safety requirements. Distributors should participate in the supervision of products put on the market, especially convey the dangerous information of products in time, maintain and provide traceability documents, and cooperate with manufacturers and law enforcement departments to avoid dangers.
PS:GPSD does not need CE mark.
Children's clothing ordinance
According to the GPSD directive, the European Union has formulated a number of corresponding coordination standards, among which EN 14682:20 14 "Children's wear, the safety of ropes and lower straps on children's wear. Specifications are related to textiles and clothing.
20 14 12 3 1, the European union issued a new version of the European standard EN 14682:20 14 "children's wear safety. Ropes and hem straps on children's clothes. Specifications ". 20 15 On August 4th, the European Commission decided that (EU)20 15/ 1345 was published in the Official Gazette of the European Union. This decision adopts the new EU standard EN 14682:20 14 as the harmonized standard of GPSD, replacing the previous EN 14682:2007. According to relevant EU regulations, the standards cited in EU regulations are mandatory. Therefore, children's wear entering the EU market must comply with the relevant safety regulations of EN 14682:20 14.
Jie 14682:20 14 Safety of Children's Wear-Ropes and Pulling Ropes on Children's Wear-Specifications are applicable to