Softlines & Leather regulatory updates November 2022
Forum enforcement projects 2023-2025 on imported products
On 16 November 2022, ECHA announced the next REACH enforcement project. The new REACH-EN-Force will aim to control imports of substances, mixtures and articles. It will investigate how companies fulfil the registration, authorisation and restriction obligations for products and chemicals they import from outside the EU. It will be implemented in 2023-2025 with the cooperation of national customs authorities and REACH inspectors.
This project arose as a result of the 2019 pilot project where the results indicated that 23% of inspected products were non-compliant with requirements set by EU law and further controls are necessary.
For more information, consult the ECHA’s website here.
The following table summarises the most recent standard updates and upcoming dates of withdrawal (non-exhaustive):
(*) Date of withdrawal: the latest date by which national standards conflicting with an EN (and HD for CENELEC) have to be withdrawn.
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CEN |
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Reference |
Title |
Date of withdrawal |
Supersedes |
|
Clothing - Physiological effects - Measurement of water vapour resistance by means of a sweating manikin |
30-04-2023 |
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|
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Textiles - Determination of the phthalate content - Tetrahydrofuran method (ISO 14389:2022) |
30-04-2023 |
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Leather - Test for adhesion of finish (ISO 11644:2022) |
31-05-2023 |
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Leather - Tests for colourfastness - General principles of testing (ISO 7906:2022) |
31-05-2023 |
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Leather - Terminology - Key definitions for the leather trade |
30-04-2023 |
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Leather - Physical and mechanical tests - Determination of bending force (ISO 14087:2022) |
30-04-2023 |
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Mandatory environmental information in consumer products
A product’s environment and characteristics are relevant information to make available for consumers. It will be mandatory to do so for all consumer products placed on the French market from 2023.
According to Decree 2022-748 of 29 April 2022 relating to consumer information on the environmental qualities and characteristics of waste-generating products, this obligation will come into force gradually.
Below is a summary table with the main dates and turnover of the companies:
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Environmental characteristics of waste-generating products |
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For producers, importers and any other marketers |
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|
Annual turnover |
Responsible annually |
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|
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>50 million euros |
>25,000 units of the products |
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Not applicable to products for which the last unit is placed on the market between 1 January and 31 March 2023. |
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From 1 January 2024 |
> 20 million euros |
>10,000 units of the products |
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From 1 January 2025 |
> 10 million euros |
>10,000 units of the products |
This information shall be available in a dematerialised format, accessible free of charge at the time of purchase and reusable so as to allow aggregation.
The producer or importer shall make the information available on a dedicated website or internet page comprising a sheet entitled “product sheet relating to the qualities and environmental characteristics” so as to allow direct research and queries on the internet as well as the extraction of data for the possible automated processing of information.
For more information, consult Ministry of Energy Transition’s website here and Frequently Asked Questions (FAQ)
Environmental information in textiles
On 30 September 2022, the experiment related to environmental labels on textiles was closed. According to Article 2 of the "Climate and resilience" law (law no. 2021-1104 of 22 August 2021 on the fight against climate change and strengthening resilience to its effects), which cancels and replaces article 15 of the law "Anti-waste and circular economy - AGEC" (law n° 2020-105 of 10 February 2021), requests an experiment in environmental labelling, in particular in the clothing and footwear sector.
Article 2 of the Climate and Resilience Law specifies that environmental labelling must provide information on “the environmental impact of the goods and services considered over their entire life cycle. It must consider:
- Greenhouse gas emissions
- Damage to biodiversity
- Consumption of water and other natural resources.
The law stipulates that the experiment will be followed by an assessment and a decree making environmental labelling mandatory in June 2023. At the moment, Environmental labelling is not mandatory in France.
Below, you will find proposals and examples that different textile collectives, entities and some companies are using or have presented in the French market on their own initiative because of this law.
- ADEME
This is an A, B, C, D or E rating displayed on products or services, in-store or on the internet, calculated based on the entire life cycle of the product or service, according to a validated reference system.
- UIT
Environmental labelling takes the form of a three-part label covering:
- The carbon footprint of the product and the overall environmental impact calculated from 12 environmental indicators, compared to the same product manufactured under average global conditions;
- The traceability of the product, which includes the composition of eco-responsible materials and the countries involved in the various stages of the production of the material, spinning, weaving or knitting, dyeing and making; this box also includes the "Triman" indication, intended for the end of life of the product.
- Product and brand labels & certifications.
Environmental labelling covers:
- Raw material origin
- Traceability (The locations where the four main stages of manufacture of a textile article take place: SPINNING, WEAVING / KNITTING, ENNOBLING, CONFECTION)
- The carbon performance of the manufacturing cycle
- A space for brands to defend their supply chain and explain their choices, at their own discretion.
- The organization guaranteeing the traceability of the product
For more information, consult the CEDEF’s website here.
Repealing of formaldehyde national requirements for textiles
On 13 April 2022, Decree of 7 April 2022, was published, repealing the Commodities Act Decree formaldehyde in textiles.
This decision is intended to implement EU legislation. By setting a maximum concentration limit for formaldehyde in textiles in Annex XVII to the REACH Regulation, there is no longer room for national regulation of formaldehyde in textiles.
This decree shall enter into force one day after the date of issue of the Official Gazette in which it is placed.
Miscellaneous technical publications relating to textiles
The latest publications in relation to textiles are summarised in the table below:
|
Date |
Country/ Region |
Entity |
Publication |
|
05/10/2022 |
Norway |
Norwegian Consumer Authority |
Guidance to the sustainable apparel coalition |
|
27/10/2022 |
Europe |
Funding by the Horizon Europe research and innovation programme |
T-REX Project (Textile Recycling Excellence) |
Recent Prop 65 60-Day Notices - PFOA/PFOS
California Proposition 65 is the ‘Safe Drinking Water and Toxic Enforcement Act of 1986’, which has been effective for almost 30 years. Recently, there have been many new 60-day notices concerning Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA). Please see below Table 1 for the recent 60-day notices.
Table 1:
|
Date |
Chemical |
Product |
AG Number |
|
30 September 2022 |
PFOA |
Microfibre tablecloth |
2022-02322 |
|
10 October 2022 |
PFOS |
Jackets |
2022-02404 |
|
10 October 2022 |
PFOA |
Crib mattress pads |
2022-02405 |
|
12 October 2022 |
PFOA |
Fabric shower liners |
2022-02441 |
|
12 October 2022 |
PFOA |
Golf umbrellas |
2022-02442 |
|
12 October 2022 |
PFOS |
Comfort bath pillows |
2022-02443 |
|
17 October 2022 |
PFOS |
Bibs |
2022-02498 |
|
17 October 2022 |
PFOS |
Superbibs |
2022-02499 |
|
24 October 2022 |
PFOS, PFOA |
Waterproof rain jackets |
2022-02565 |
|
8 November 2022 |
PFOA |
Duffle bags |
2022-02711 |
|
8 November 2022 |
PFOA |
Jackets |
2022-02712 |
|
8 November 2022 |
PFOA |
Jackets |
2022-02713 |
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18 November 2022 |
PFOA, PFOS |
Jackets |
2022-02788 |
China issues new and updated Product Standards
The Chinese Ministry of Industry and Information Technology has recently released various new and updated industry and national product standards. Please see Table 1 below:
Table 1:
|
Category |
Standard |
|
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QB/T 5856-2022 Vacuum seal storage bag |
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GB/T 41002-2022 Children’s cases and bags |
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Footwear |
QB/T 1653-2022 Polyvinyl chloride (PVC) injection molded sandals and slipper HG/T 2019-2022 Black rain boots (shoes) |
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FZ/T 44008-2022 Chemical filament cleaning wipes |
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FZ/T 44009-2022 Tussah sleeping mat |
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GB/T 41788-2022 Multifunctional knitted products |
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GB/T 41902-2022 Nursing garments |
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QB/T 1196-2022 Down and feather pillows and cushion |
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QB/T 1195-2022 Down and feather sleeping bags |
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QB/T 1193-2022 Down and feather quilt |
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QB/T 2540-2022 Leather bracelet |
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FZ/T 81007-2022 Casual wear |
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FZ/T 81004-2022 Dress and Suit |
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FZ/T 08002-2022 Textile products for newborn |
Below you will find a monthly summary of product recalls and alerts in Europe (Source “Safety Gate (RAPEX)”) and the U.S. (Source “CPSC”).
Europe
Safety Gate (RAPEX) (European Commission Rapid Alert System for dangerous non-food products – Alerts reported by EU national authorities)
The following 34 alerts regarding textile & leather products were reported between week 43 and week 46 of 2022.
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Type of Risk |
Number of alerts |
Notes |
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Women’s flat shoes |
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Flip-flops |
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Boots The product does not comply with REACH Regulation. |
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Women’s shoes The product does not comply with REACH Regulation. |
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Children's sandals |
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Children's gloves |
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Children's blouse |
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Baby t-shirt and baby clothing set |
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Children's and babies’ dress |
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Children's sports outfit |
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Children's sweatpants |
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Injuries, Strangulation |
3 |
Babies' clothing set |
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Children's outfit |
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Babies' jumpsuit |
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Children's hat |
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Sleeping bag |
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|
Children's rain jacket with hood |
UK
The OPSS issues Product Safety Alerts on the UK market. The following alerts regarding textile & leather products were reported between week 43 and week 46 of 2022.
2 recalls regarding textiles
|
Type of Risk |
Number of alerts |
Notes |
|
|
|
Pyjama set |
|
|
|
Costume |
U.S.
From 27 October 2022 to 17 November 2022, the CPSC (Consumer Product Safety Commission) published the following recalls: 2 recall of textile & leather products
|
Hazard |
Number of alerts |
Notes |
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|
Footwear |
|
|
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Children’s pajamas |
