In September 2020, Amazon issued an announcement stating that when selling products on Amazon Mall, sellers need to ensure compliance with Article 1907/Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) of the European Parliament and of the Council. Regulation 2006. When selling certain products on Amazon, sellers need to provide Amazon with a REACH compliance statement or test report. my country is a major exporter of textiles and clothing. Textile and clothing products inevitably contain chemical substances, such as dyes, additives or polymer materials. The requirement for registration and evaluation of certain chemical substances in products will have a significant impact on the export of these final products in my country, and once certain chemical substances are banned by the EU, the export of final products will be affected. Therefore, textile and apparel companies must attach great importance to the impact of REACH regulations. In terms of textiles and clothing, the technical regulations formulated by the EU mainly involve human health and safety, consumer rights protection and other aspects. Mainly including the Restriction of Hazardous Substances Directive (76/769/EEC) and its series of amendments and supplements, REACH regulations (Regulation (EC) No1907/2006), General Product Safety Requirements Directive (2001/95/EC), and Textile Name Directive (2008/121/EC) etc. In this article, we mainly introduce the product regulations, safety standards, labeling requirements and corresponding precautions applicable to children's clothing, including REACH, EN standards, GPSD directives and the listing requirements of Amazon Europe.
How do I know if my product is classified as a textile? According to the EU Textile Regulation, “A textile product is any raw, semi-finished, processed, semi-finished, manufactured, semi-finished or cosmetic product, consisting of textile fibers, regardless of mixture or the process employed in assembling it. “In addition, the following products are also considered textile products. A. Products containing at least 80% textile fibers by weight. B. Products that contain textile components and form an integral part of the product.
REACH regulation REACH is the abbreviation of the "Registration, Evaluation, Authorization and Restriction of Chemicals" regulation issued by the European Union (EU Regulation (EC) No 1907/2006). This regulation is responsible for regulating restricted chemical substances and their The potential impact on human health and the environment involves 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. Hundreds of chemicals are used in common textile manufacturing processes. For example, sulfuric acid is used in the manufacturing process of clothing. Therefore, in order to avoid causing harm to people, products must comply with REACH regulations. The main content of the REACH regulations is the registration, evaluation, licensing and restriction of chemicals. Among them, the main ones related to textiles and clothing include registration, licensing and restriction requirements, especially the restriction requirements (restrictions on hazardous substances are listed in Annex XVI of the REACH regulations), which have become the main reasons for the EU RAPEX notification and recall of Chinese textiles and clothing, and are worthy of the attention of relevant enterprises. Attention! 1. Registration: Registration requires manufacturers or importers to provide relevant information on chemical substances exceeding 1 ton per year, including submitting technical files. It should contain information on the substance and how to manage the risks associated with its use. Substances whose quantity exceeds 10 tons per year must submit a chemical safety report to characterize their safety assessment. 2. Evaluation: The evaluation process will allow the competent authority to decide whether to require further testing and evaluation, and whether the information provided by the registrant meets regulatory requirements (i.e., document evaluation); for selected substances, if they are suspected to be harmful to humans Substance assessment is required when there are risks to health and the environment. The assessment provides a mechanism to require industry to obtain more information. The assessment also makes recommendations on what actions to take under the authorization or restriction procedures. 3. Authorization and Restriction: Only substances of high concern require authorization. Substances of very high concern refer to carcinogens, mutagens, substances toxic to the reproductive system, persistent, bioaccumulative substances and toxic substances, permanent and highly bioaccumulative substances and equivalent substances. Since REACH is an EU regulation, it applies to all EU countries.
Therefore, when importing goods into the EU, you must understand which provisions of REACH must be applied to your products. Here are the main roles under the REACH regulations: 1. EU manufacturers, providing products containing any chemical substances. 2. Importers within the EU purchase products containing any chemical substances outside the EU. 3. Companies or users that handle any chemicals in industrial or professional activities in the EU. Note that companies established outside the EU are not obliged to comply with REACH, even if they export products to the EU. Responsibility will shift to the EU importer. Although REACH does not apply to other countries outside the EU, it has also become an international reference for other countries. For example, Switzerland is not part of the European Union, but they generally 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 take the time to read the restricted list and make sure your product does not contain any of the listed substances. However, reading the restricted list is not very practical. In many cases, just knowing what chemicals are in your products is difficult. Therefore, a professional testing company will help you evaluate the chemicals, heavy metals, and contaminants to be checked during testing. Therefore, as an importer or distributor, it is recommended to conduct laboratory testing to ensure that your products comply with regulations.
Hazardous Substance Requirements In the EU, although textiles and clothing are not as sensitive to consumers as food, due to the fact that many textiles and clothing are in direct long-term contact with the skin and even the mouth, coupled with the vigorous publicity of the EU government and related industries , EU consumers have paid great attention to the environmental protection requirements of textiles and clothing in recent years. On July 27, 1976, the Council of the European Community issued Directive 76/769/EEC on the restriction of the sale and use of certain hazardous substances and preparations. This directive is often called the "Limitations Directive" and is almost Involving all industries, including textile and clothing regulations. With the development of science and technology, the continuous innovation of product technology and the continuous improvement of people's awareness level, the directive has undergone 33 amendments (amendment) as of May 2009. In addition, 18 revisions have been made to the scope of restricted substances in the original directive. Adaptation to technical progress, the directive has been revised and supplemented many times to form a relatively complete regulatory system for hazardous substances. It is worth noting that from June 1, 2009, Appendix VX of the REACH regulation replaced Appendix 1 of 76/769/EEC, but the contents of the two are consistent. Therefore, although Directive 76/769/EEC has been invalidated, the content of its provisions is still valid, except that the content is consistent when it is transferred to Appendix XVll of the REACH regulation. Therefore, although Directive 76/769/EEC has been invalidated, its provisions are still valid, but have been transferred to Appendix XVll of the REACH regulations. In the field of textiles and clothing, the hazardous substances involved in the restriction directives mainly include azo dyes, nickel and cadmium content, heavy metals, polychlorinated biphenyls (PCB), polybrominated biphenyls (PBB), dichlorethylene, trichlorethylene, chloroform and tetrachloride. carbon, perfluorooctane sulfonate, etc. In addition, with the implementation of the REACH regulations, the original hazardous substances restriction directives have basically been abolished. Therefore, when actually querying the hazardous substance restriction requirements, the industry can refer to the specific requirements in Annex XV of the REACH regulations. 1. Prohibited even dendrite dyes 2. Prohibited blue dyes 3. Flame retardant finishing agents 4. Pentachlorophenol 5. Polychlorinated biphenyls 6. Organotin compounds 7. Heavy metals 1 Nickel release 2 Cadmium release 3 Hexavalent chromium 8. All Fluorooctane sulfonic acid 9. Perfluorooctanoic acid
Substances of Very High Concern (SVHC) To know which substances are controlled by REACH, you can check it on the European Chemicals Agency (ECHA) website. ECHA adds new substances to the list from time to time. However, exporters do not need to track restricted list updates for a long time because testing companies usually obtain the latest regulatory requirements and provide testing solutions faster. Before exporting to the EU, it is recommended to obtain information about the REACH regulations and book a REACH compliance test.
Fees The cost of REACH testing for children's clothing 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. Typically, substance identification, physical, chemical tests, toxicological tests and ecotoxicological tests will be carried out during testing. The fee also includes a detailed report on product certification.
Risk Certain textiles and clothing components (such as zippers and buttons) are most likely to contain excessive amounts of restricted chemicals and heavy metals. Please note that regardless of whether the lab test is successful, you must bear the cost of the test.
EU Textile Labeling Rules According to EU textile and clothing regulations, products must be labeled or marked when sold on the market. If your children's clothing product contains at least 80% textile fibers, the product must be labeled with the fiber content (e.g. 100% polyester or 100% cotton). Labels must be permanently attached to clothing to allow consumers to easily obtain relevant product information. Also, textile label stickers are not suitable. Manufacturers or traders must create their own textile label files (preferably in .ai or .eps format) and then submit them to the manufacturer before mass production.
Fiber content As mentioned above, according to EU textile regulations, fiber content must be provided on the product label. Here are some common fibers and properties found in the textile industry. · Silk (smooth fabric, high gloss) · Wool (warm) · Nylon (durable, strong, lightweight, quick drying) · Polyester (durable, strong, lightweight, quick drying) · Cotton (light weight, absorbent) · Spandex (Elastic, Strong, Lightweight)
Label Position Labels should be permanently attached to the textile. For example, for T-shirts, labels are usually affixed to the inside of the product. Generally speaking, textile products must have durable, legible, and easily visible labels on the product or packaging.
Sizing As of today, the harmonization of the sizing system is covered by the European voluntary standard EN13402, which regulates sizing regulations for clothing. However, size labels for textile products are not included and there is no obligation to apply the standard.
Care Instructions Similar to the size label, it is not mandatory under EU textile regulations. However, if you choose to include care instructions on your product, you should be aware that the trademark covers care symbols.
Country of Origin In the EU, country of origin labeling is compulsory. However, if you choose to indicate the country of origin on your label, you must not mislead consumers and state it clearly.
Language Information on the label should be written in the official language of the EU country where the textile is marketed. For example, in Germany you would use German labelling, since it is the official language of Germany.
Label information In addition to the label file, you must also provide the following information to ensure that they are properly labeled: · Label size · Material · Color · Position
Packaging information 1. In the packaging Collection, reuse and material recovery information is provided on the website to inform users. 2. Any other conformity marking or labeling requirements should also be printed on the product packaging.
Summary of the labeling section: What information should or should not be included in the label? Here is a summary: 1. The fiber content of the product must be labeled on textiles 2. Non-textile components of animal origin must be clearly labeled ( (such as fur or leather) 3. In addition to the code, the label should not contain abbreviations 4. Care labels are not required by EU law (but it is still recommended) 5. Manufacturer's marking is not required
General Product Safety Directive ( GPSD) In ??order to make up for the differences in consumer safety protection regulations among EU countries and ensure the safety of products put on the market, in 2001, the EU revised the original General Product Safety Directive (92/59/EEC) and The new General Product Safety Directive (2001/95/EC, referred to as the GPSD Directive) was adopted, and member states were required to fully implement it from January 15, 2004. The original Directive 92/59/EEC was therefore invalidated. The European Union issued Regulations (EC) in 2008 and 2009 respectively. The countries have fully implemented them from January 15, 2004, and the original Directive 92/59/EEC has therefore become invalid. The EU issued regulations (EC) No 765/2008 and (EC) No 596/2009 in 2008 and 2009 respectively to amend the GPSD.
The directive covers a wide range of consumer goods in addition to services and applies not only to new products but also to second-hand products. In addition, the directive does not apply to those products for which specific product directives have been established.
1. Scope of application of the directive The directive applies to but is not limited to the following products: clothing, medicines, personal gardening products, food and beverages, household products, baby products, chemicals and pesticides, consumer products Fireworks, motor vehicles, etc. Therefore, textiles and clothing fall within the scope of the Directive.
2. The General Product Safety Requirements Directive sets out principle requirements for the general safety of products. The main contents include: (1) Manufacturers have the responsibility to only put safe products on the market; (2) When the safety of the product involved is not stipulated in specific regulations of the same country, the product should comply with the relevant laws of the member state where it is sold; (3) When conducting a conformity assessment of a product in accordance with general safety standards, the following should be considered Factors: whether there are national voluntary standards converted from European standards; whether the member states where the product is sold have formulated standards; whether there are product safety assessment guidelines 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 states can also take relevant measures to restrict the product from being put on the market, such as requiring the withdrawal of the product or recalling the product wait.
3. Responsibilities of manufacturers and distributors The directive requires manufacturers and distributors in the product supply chain to be responsible for ensuring the safety of products put on the market and for cooperating with law enforcement agencies. When manufacturers and distributors clearly know that the products put on the market are dangerous and do not meet safety requirements based on the information and professional knowledge they possess, they should immediately notify the law enforcement agencies of member states so that appropriate measures can be taken to prevent harm to users. 1. Manufacturer’s Responsibility Certain safety aspects of the product would be difficult for consumers to discover without appropriate warnings. Therefore, the directive requires manufacturers to provide relevant information to consumers so that they can be aware of possible risks that the product may have during normal use. Assess the risk so that necessary precautions can be taken. It is also pointed out that warnings provided by the manufacturer do not relieve the manufacturer of its responsibility to comply with other requirements of this Directive. Manufacturers should take appropriate measures based on product characteristics so that they can promptly notify products of possible dangers and withdraw problematic products to avoid dangers. Measures that can be taken include marking the identity and details of the manufacturer and the batch of the product on the product or product packaging, conducting sampling tests of products on the market and investigating consumer complaints. At the same time, the manufacturer should let dealers know regulatory measures taken. 2. Responsibilities of dealers The directive requires dealers to have the responsibility to assist in meeting the safety requirements stipulated in this directive, and in particular cannot provide products that do not meet the safety requirements. Distributors should participate in the supervision of products put on the market. In particular, they should promptly communicate the hazard information of the products, maintain and provide traceability documents of the origin, and cooperate with manufacturers and law enforcement agencies to avoid the occurrence of hazards.
PS: GPSD does not require CE marking.
Children's Clothing Regulations According to the GPSD directive, the European Union has developed a number of corresponding harmonized standards. Among them, the one related to textile clothing is EN 14682:2014 "Safety of children's clothing, ropes and hem straps on children's clothing. Specification" . On December 31, 2014, the European Union released a new version of the European standard EN 14682:2014 "Safety of children's clothing. Ropes and hem straps on children's clothing. Specification." On August 4, 2015, the European Commission Decision (EU) 2015/1345 was published in the Official Journal of the European Union. This decision will use the new version of the EU standard EN14682:2014 as the harmonized standard for GPSD, replacing the previous EN14682:2007. According to relevant EU regulations, standards cited by EU regulations are mandatory requirements. Therefore, children's clothing entering the EU market must comply with the relevant safety regulations of EN14682:2014. EN 14682:2014 "Safety of children's clothing - Ropes and drawstrings on children's clothing - Specification" applies to