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What are the requirements for apparel to enter the European market?

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If you want to sell apparel on the European market, there are several requirements that you need to comply with. Some legal and non-legal requirements are mandatory. Others are voluntary, but meeting them can give you a competitive advantage. Some requirements only apply to certain niche markets. This report will help you understand what the most important requirements are on the European market. You will also learn what your company must do to comply with them and how you can use them to your advantage.

1. What are mandatory requirements for apparel?

There are many legal requirements for exporting denim to Europe, including those concerning product safety, the use of chemicals (REACH), quality and labelling. Check the EU Access2Markets online helpdesk for an overview. Additionally, many buyers have non-negotiable terms and conditions for their suppliers. Although meeting these requirements is not required by law, they are still mandatory.

Follow these steps to ensure that your product meets the relevant legal requirements:

  1. Make sure your product complies with the EU’s General Product Safety Directive (GPSD: 2001/95/EC). If your buyer supplied the product design, it is their responsibility to guarantee it is legally safe for consumers to use.
  2. Make sure you comply with the EU’s REACH Regulation. This restricts the use of chemicals in apparel and trims, including certain azo dyes, flame retardants, waterproofing and stain-repelling chemicals, and nickel.
  3. Ask your buyer if they use a Restricted Substances List (RSL). These are often inspired by the guideline on safe chemicals use from the Zero Discharge of Hazardous Chemicals (ZDHC) foundation. Download the ZDHC Conformance Guidance here.
  4. Specify the material content of every denim item that you export to the EU in accordance with EU Regulation 1007/2011. Check the EU Access2Markets online helpdesk on how to do this. Fibres which collectively form up to 15% of the total weight may be designated by the term ‘other fibres’.
  5. Do not violate any Intellectual Property (IP) rights and do not copy or share designs with other buyers. If your buyer gives you the design, they will be liable in case the item is found to violate a property right.

Special requirements for children’s wear

The EU has a specific standard for the safety of children’s clothing and babywear. This standard contains requirements to ensure that cords and drawstrings are placed safely on apparel for babies and children up to 14 years old. This is to avoid strangulation and choking hazards.

Tips:

  • Do not use cords or strings in the neck area of babywear (hoodies are allowed).
  • Do not use accessories like buttons that can come loose and cause a choking hazard.
  • Do a small parts cylinder test to check which parts are allowed, for example by using this online example of a small objects tester.
  • Check the EU’s 2019 Guidance Document for extra information on safety requirements for children’s clothing and babywear.

Figure 1: Every item of apparel exported to the EU must meet legal requirements. Some categories, such as children’s wear, have specific legal requirements

Every item of apparel exported to the EU must meet legal requirements

Photo by Michael Podger on Unsplash

Flammability

The EU has no specific legal requirements regarding apparel flammability, but several individual countries do, including the UK, Ireland, The Netherlands and Switzerland (in German). The EU has a voluntary standard concerning the burning behaviour of children’s nightwear, which helps in complying with the GPSD.

CE marking

If you want to export personal protective equipment (PPE) to the EU, for example, safety garments or gloves, you have to comply with specific EU safety standards for the design, manufacturing, material use, testing and user instructions concerning PPE. You are obliged to affix CE marking to PPE as a visible indication that your product conforms with the PPE safety requirements.

Biocides

If you add biocides to textiles to protect humans, animals, materials or articles against harmful organisms, such as pests or bacteria, you have to comply with the EU’s Biocidal Product Regulations (BPR) as well as REACH (see above).

Tip:

CITES

The use of endangered species of animals and plants or parts thereof in your product is restricted by the EU wildlife regulatory measures EC 338/97. This regulation is based on the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Some species of animals and plants are excluded from use in apparel altogether, so you cannot use them in your products. Others are subjected to severe importing restrictions.

Tips:

Non-legal mandatory requirements

Besides the legal requirements mentioned above, you may be confronted with non-negotiable terms and conditions that buyers have created for dealing with suppliers. Such requirements are non-legal, but still mandatory.

Corporate social responsibility

Many buyers in Europe are increasing their demands when it comes to corporate social responsibility (CSR). The minimum requirement is that you open up your factory for inspection by the buyer and that you sign a code of conduct in which you state that you respect local labour and environmental laws and avoid corruption. In addition, buyers may require you to get certification concerning fair and sustainable production.

Often — but not always — buyers that are strict on CSR are also strict on the quality of your product. They may require rigorous testing for REACH compliancy and anything from tear force to colour fastness.

Northern European countries the strictest on CSR

Companies from Northern and Western Europe are considered relatively strict on CSR and quality in general. German and Scandinavian companies are well known for being very strict on working conditions and living wage, meaning not the legal minimum wage, but the minimum income workers need to meet their basic needs. Most companies in Germany and France will also demand relatively rigorous testing for REACH compliancy and product quality. Companies in the UK tend to be a bit more lenient, with the Netherlands and Belgium somewhere in between.

The future of non-legal mandatory requirements

Within the next three years, expect buyers to require you to: trace the origins of your materials; use more recycled or regenerated materials; reduce your carbon footprint and chemical use (or select suppliers that do so); measure the environmental impact of your production process, and ensure a living wage and safe working environment for your employees.

Supply chain transparency, social compliance and the ‘circular economy’ are top priorities for both the EU and national governments. For instance, the EU’s new Corporate Sustainability Reporting Directive (CSRD) will require all large European companies from 2023 onward to disclose how they manage social and environmental challenges.

When it comes to the circular economy, the EU is set to introduce new legal measures to increase circularity in textiles, including new directives concerning durability of textile products and a ‘right to repair’. To reduce global carbon emissions, the EU is currently considering a Carbon Border Adjustment Mechanism, also called a ‘carbon border tax’. This is effectively an import duty based on the amount of carbon that was emitted during production.

On a national level, the German fashion industry’s sustainability agreement and the similar fashion industry agreement in The Netherlands call for members to disclose their factories.

Tips:

Table 1: An overview of social and environmental standards popular in the European market

Name of standard

Logo

Type

Cost for manufacturers

Most used in European end markets

Further information on getting certification

Amfori BSCI

Amfori BSCI

Social

External audit costs (variable)

Germany, France, The Netherlands

Available from buyers. Amfori has a list of organisations that can perform an audit.

SA8000®

SA8000®

Social

External audit costs (variable)

Germany, France, The Netherlands, Italy, Spain

Check the SA8000 certification process here

WRAP

WRAP

Social

€1,030 registration fee + external audit costs (variable)

UK, Germany

Check the WRAP certification process here

Sedex

Sedex

Social, environmental

€118/year/per site + external audit costs (variable)

Germany, France, UK, The Netherlands

Check the Sedex certification process here

Fair Wear

Fair Wear

Social

Membership is not open to factories (yet)

Germany, Sweden, The Netherlands, Italy

Check which brands are members

B-Corp

B-Corp

Social, environmental

€865/year minimum

Germany, UK, The Netherlands

Check the B-Corp certification process here

OEKO-TEX® STeP

OEKO-TEX® STeP

Social, environmental

Certification fee + external audit costs (variable)

Germany, France, UK, The Netherlands

Check the OEKO-TEX® STeP application process here

BCI

BCI

Environmental

€2,000/year minimum membership fee

Germany, France, UK, The Netherlands

Check the BCI membership process here

GOTS

GOTS

Social, environmental

€150/year minimum + external audit costs (variable)

Germany, France, UK, The Netherlands

GOTS has a list of organisations that can perform an audit

ZDHC

ZDHC

Environmental

Cost of a third-party indicator of conformance with the ZDHC MRSL (variable)

Germany, France, UK, The Netherlands

The ZDHC has a guide that outlines the requirements for indicating ZDHC MRSL conformance

Non-legal requirements for base materials

The following standards and certifications are the most common in the European market for base materials:

Other possible requirements for base materials:

  • Use of organic cotton. This is cotton grown without the use of GMOs (‘genetically modified organisms’) and synthetic chemicals. Read more about organic cotton in the CBI study on Sustainable cotton.
  • Use of fabrics blended with eco-friendly fibres, such as hemp; regenerated fibres, such as Tencel®, Modal® and Refibra™ (by yarn manufacturer Lenzing); or other sustainable fibres, such as Recover, REPREVE or Infinited Fiber; or even with innovative bio-based polymer fibres, such as PLA, milk, seaweed and soy.
  • Saving water during production by dyeing fabrics with new techniques (using CO2 instead of water), such as Dyecoo or Kitotex®.
  • Use of fabrics dyed with only natural ingredients, such as Rubia, Fibre Bio or Greendyes, or dyes made from recycled materials, such as Recycrom.

Non-legal requirements for textile processing and fabrics

The following standards and certifications may be requested to guarantee that textiles and fabrics have been produced with respect for the environment. Examples of European brands and retailers using these standards are: Peek & Cloppenburg (Oekotex), Zalando (EU Ecolabel), C&A (GOTS) and G-Star (Bluesign). Other companies use private standards, such as Inditex’s Join Life standard for recycled materials and H&M’s private recycling programme.

  • Standard 100 by Oekotex – Label that ensures consumers that all materials used in a garment are tested for harmful substances.
  • EU Ecolabel – Label that ensures consumers that textiles are made using less harmful substances, energy and water.
  • GOTS (Global Organic Textile Standard) – This standard covers everything from the production to the distribution of textiles made from at least 70% organic natural fibres.
  • Bluesign – The Bluesign System reduces impact on people and the environment in the entire textile supply chain, based on input stream management.

Tips:

Non-legal requirements for garment manufacturing

Several standards and certifications in the textile industry aim to encourage fair treatment of workers in garment manufacturing. Here are some of the most requested standards by European buyers.

  • BSCI (Business Social Compliance Initiative). For many European buyers, BSCI is the most popular and often only certification they will require. It is a supply chain management system that helps manufacturers drive social compliance.
  • Especially in the UK, the following social and environmental standards are popular: WRAP (Worldwide Responsible Accredited Production), SEDEX and ETI (Ethical Trade Initiative).
  • Other popular standards that guarantee apparel are made with respect for workers’ rights are SA8000, ISO 26000, FWF (Fair Wear Foundation) and Fairtrade. A popular environmental management standard is ISO 14001.

Tips:

  • For a complete list of certification schemes in the sector consult the ITC Standards Map.
  • Check this freely accessible CSR Risk Check tool to discover the social and environmental risks associated with garment production in your country and ways to manage them.
  • Ask your buyer what standards they want you to comply with. Be aware that complying with a standard costs time and money, not only for the application and the audit, but also for its annual renewal. Because many standards have overlapping criteria, often a few simple interventions will make your factory compliant with more than one standard. Talk to your buyers about such adjustments to avoid having to process several different standards.
  • Familiarise yourself with the Social & Labor Convergence Project. This is an industry initiative to avoid duplication of audits.
  • Note that much of the social and environmental impacts take place at your suppliers. Try to be as transparent as possible and help your buyers to trace the origins of products.
  • Assess your company’s current performance by doing a self-assessment: BSCI for textile factories and LWG’s ‘Tannery of the Future: are you ready for an audit?’ for leather garment producers.

COVID-19 protection on the work floor

EU buyers will expect you to follow local rules and regulations concerning worker safety and COVID-19 protection. There are different ways to create a safe working environment:

  • Nominate an internal health and safety officer who will regularly inform your workers of protection measures and guide them in the adoption of those measures.
  • Use signs, posters and other communication materials to inform all people involved in the process.
  • All workers should have access to clean facilities. Sanitising products should be widely available.
  • All people in the factory should be obliged to wear appropriate PPE, such as face masks.
  • Measure the body temperature of all people entering and leaving the factory.
  • Infected people should not be allowed to enter the factory and should stay at home to prevent further infection.
  • The factory and equipment should be sanitised during the lunch break and at the end of each shift.

Packaging requirements

In most cases, your buyer will give you instructions on how to package the order in a manual (see below). If you agree that your buyer will clear customs in the country of import, it is their responsibility to make sure the instructions comply with EU import procedures.

Payment terms

For a first-time order, European buyers may agree to a down payment (for example, 30%). They will pay the rest (70%) after the order is completed. The safest payment method for you as a manufacturer is the Letter of Credit (LC). An LC means that a buyer’s bank has to pay the supplier when the conditions that both parties have agreed are met. However, many buyers no longer favour LC payments because these block their cash flow. Be aware that LCs do not offer financial protection against bankruptcies.

For further orders, most European buyers will ask for a Telegraphic Transfer (TT) after 30, 60, 90 or sometimes even 120 days. This means that you as a manufacturer finish the production and hand over the shipment to the buyer, including the original documents, before payment is due. The payment will be made after the number of days that you have agreed with the buyer. This is a risky payment agreement, because you take full financial risk. Recently, many manufacturers have pushed back by asking for safer payment conditions.

The buyer manual

When you do business with a European buyer for the first time, they will typically give you a contract and/or a manual to sign. By signing the contract, you confirm that you will meet all the listed requirements. This means you will be held accountable in case of a problem after the delivery of an order. Complying with REACH can be especially challenging. Most European buyers will not ask for expensive testing for small orders, but if illegal chemicals are discovered after delivery, you must pay all expenses involved.

Acceptable quality limit

To guarantee product quality, your buyer may set an AQL (acceptable quality limit) for you. This refers to the quality level that is the worst tolerable. For instance, AQL 2.5 means that your buyer will reject a batch if more than 2.5% of the whole order quantity over several production runs is defective.

Customers also set the product quality standard defining the level of physical standards, such as:

  • pilling
  • colour fastness
  • tear force
  • shrinkage

Tip:

  • Set up a small lab to test all products on physical standards.

2. What additional requirements and certifications do buyers ask for in the apparel sector?

In addition to mandatory (legal) requirements, there are many services that buyers implicitly expect or at least highly appreciate, if you want to do business with them.

Product design and development

Most buyers have their own design team and do not solely rely on the collections that factories present to them. Still, having your own ideas on product design and development will be highly appreciated. Buyers are always looking for special designs, materials or production methods that may help them stand out in the market.

For instance, consider using on-trend (sustainable) materials; special finishes, such as coatings and prints; stretch fabrics for extra comfort; special property fabrics (for instance, with soil-resistant, breathing, waterproof, anti-bacterial or UV-protective properties); quick-drying, easy-iron and crease-resistant fabrics; stay-dark fabrics (colour fastness); and garment dyeing during production to increase flexibility.

Tips:

  • Because of COVID-19, many trade fairs have set up ‘virtual’ shows, online matchmaking events and webinars. Try to attend them online. If the situation allows it, visit fashion fairs in person. This way, you get an idea of the latest fashion trends. Roughly speaking, trends you see in womenswear today will appear in menswear one or two years later.
  • Do not underestimate how difficult it is to understand trends in the European market and translate them to successful apparel items. Inform yourself about the latest market trends in fashion. Check Fibre2Fashion’s online fashion trends page and sign up for trend forecaster WGSN’s newsletter or fashion consultancy Edited’s Insider Briefing.
  • Other online fashion platforms widely followed by European buyers are FashionUnited, Just-Style, The Business of Fashion, Leatherbiz (for leather products) or Sourcing Journal.
  • Check the websites of Fashion for Good and Springwise (type in ‘apparel’, ‘fashion’ or ‘leather’ in the search bar) for the latest innovations in apparel design and production. Check Material District for the latest innovations in materials.
  • Hire a designer to help you with your fabric selection and design input. Post your job offer on The Business of Fashion, FashionUnited or HTNK. For freelance designers, try Upwork or Fiverr.

Garment care preferences

When selecting base materials, keep in mind that most consumers in Europe prefer easy to care for, machine-washable garments. Try to avoid dry-clean-only products, unless you have a specific agreement about this with your buyer.

Communication

Smooth communication is an implicit requirement that all buyers have. Be prepared to follow these basic rules if you want to successfully do business with European buyers:

  • Always reply to every email within 24 hours. Even if it is just to confirm that you have received the email and to say that you will provide a proper reply later.
  • If you encounter a problem with a production order, immediately notify the customer and try to offer a solution.
  • Create a T&A (time and arrival) for every order and share it with your buyer. This file will help you to manage expectations, monitor progress and is the best guarantee for on-time delivery.
  • Create a communication file of every order so you build up a case history. This file is your backup in case of a complaint.
  • Tools like 3D prototyping, such as CLO3d, can help you speed up the approval process.

Speed to market

Fashion companies like Zara have proven that having the right product at the right time is at least as important as being the cheapest. Sales in Europe were already under increased pressure, even before COVID-19. These days, buyers will try even harder to minimise stock and order as late as possible. Manufacturing and delivering fast is an important implicit requirement, just like flexibility in order quantities (see below).

Within the next three years, you should expect stricter requirements on order quantities and delivery times, since European brands and retailers are struggling to attract and hold the attention of consumers. Instead of four or even 12 collections a year, ever more retailers are releasing as many as one micro collection per week, year-round. Ultrafast fashion online retailers increasingly try to mimic trends that can pop up any moment during the fashion season.

There are different ways to optimise manufacturing:

  • Keep stock materials to increase flexibility. Source from fabric suppliers that work with stock yarns and that can help you reduce manufacturing time.
  • Confirm lab dips (a small swatch of fabric to define colour and its recipe before it goes for bulk dyeing), trims and style before the final order is placed.
  • Ask your buyers for a seasonal sales forecast and regular sales updates, to help plan your production capacity.
  • Read the CBI report on trends in the European apparel market to learn about the growing fast-fashion industry in Europe.

Flexibility

Many factories focus only on getting convenient orders: simple styles, large quantities and long delivery times. However, if you want to start a business relationship with a European buyer, be prepared to accept complicated orders first. Buyers will want to test your factory before giving you big, easy orders. Make sure at the start that a buyer will not continue to place only difficult orders with you and convenient orders elsewhere.

Expect a European buyer to require (for their first order):

  • high-quality material and impeccable workmanship;
  • order quantities below your normal minimum order quantity (MOQ);
  • a price level that is lower than you normally would accept for small quantity orders.

Factories in different GSP countries

When all other selling points are equal, European buyers will prefer manufacturers that operate in countries under the EU’s Generalised Scheme of Preferences (GSP). The scheme removes import duties from apparel exported to the EU from 72 countries worldwide, giving buyers a substantial financial advantage.

Tips:

  • Check if your country is one of the 72 countries that falls under the GSP by selecting a country in the box to find the related scheme.
  • If you are supplying from a country on the GSP list, promote yourself as such.
  • If you are not supplying from a country on the GSP list, consider setting up a partnership with a factory from a country that is on the list.

Examples of successful exporters to the EU

The following garment manufacturers are good examples of companies that have successfully put the additional requirements mentioned above into practice.

  • Arvind India is a vertically integrated fabric and apparel manufacturer specialised in woven fabrics. The company offers anything from fabrics to design to cut, make and trim (CMT). It has an extensive paragraph on sustainability on its website, including KPIs on materials, workers and production processes.
  • Kanoria in Ethiopia is set up as an eco-friendly denim factory. The company holds certificates from Cotton made in Africa (CmiA), standard 100 by OEKO-TEX® and the Carbon Performance Improvement Initiative.
  • Crossing in Morocco is a nice example of a modern factory offering graphic design, cutting, sewing, washing, printing and embroidery. The company offers BCI, organic or recycled fabric, 3D pictures and videos of samples for pattern checking.

3. What are the requirements for apparel niche markets?

Niche markets are markets that have a specific target group with special requirements, such as low order quantities, specific dying processes, tech add-ons and special fabrics. Because of this, most mainstream providers do not service this group. However, as sales in the mainstream fashion market are continuously under pressure, ever more European buyers are targeting niche markets to achieve growth. So can you.

When entering the following high-opportunity niche markets, expect very specific buyer requirements:

  • Apparel made from recycled materials. Yarns and fabrics made from recycled cuttings and post-consumer waste are becoming increasingly popular — and not just with brands and retailers that promote themselves as sustainable. The most asked-for standards here are the Textile Exchange’s Recycled Claim Standard and Global Recycled Standard. Read the CBI study on Recycled Fashion.
  • Vegan apparel. In the wake of a rising demand for vegan food in Europe, apparel made without using materials from animal origin is a small but fast-growing niche. If you use plant-based or synthetic alternatives to materials such as leather or wool, you can apply for the PETA-Approved Vegan certification. The PETA website offers a database with more than 1,000 PETA-Approved Vegan brands. Read the CBI report on sustainable apparel for information on this niche.
  • Children’s wear. Use of organic cotton is especially popular in baby and children’s wear, as many parents are willing to pay extra for materials that are grown without the use of chemicals. GOTS is a popular standard for children’s wear. Remember that children’s wear also needs to comply with EU Regulation regarding the safe attachment of drawstrings and accessories (see mandatory requirements above). Read the CBI report on Children’s wear.
  • Workwear. This is a niche with several sub-niches, including apparel that protects against rain and foul weather, against liquid chemicals, against fire and flames, against the thermal hazards of an electric arc and high-visibility apparel. Check the EU Regulation on PPE and its many different related norms and standards. Read the CBI report on workwear.
  • Corporate wear. Many large organisations like banks and hotels tender their corporate wear. These are usually three-year contracts in which a supplier needs to guarantee the quality and colour consistency of deliveries. Expect no specific legal requirements but high demands regarding stock keeping, flexibility, printing, colour fastness and fabric quality.
  • High-performance wear. Companies developing high-performance wear try to create individual USPs on their garments and collection that will help athletes with their performance. Expect no specific legal requirements, but high demands regarding breathability, durability (abrasion, adhesion, colour fastness) and water resistance. Read the CBI report on sportswear for more information on this niche.
  • Adaptive apparel. The cohort of elderly people in Europe is growing and so is this niche. People with certain disabilities or medical conditions often cannot wear regular clothing. Adaptive apparel is constructed in a way that the target group can dress and undress without or with only minimum help. This apparel can also have technical, supportive, moisture control or anti-bacterial functions. Expect no specific legal requirements, but high demands regarding technical textiles, sizing and shape. Read the CBI report on Adaptive apparel.
  • Swimwear. UV-protective swimwear is growing in popularity in Europe as consumers become more aware of the risk of sunburn. UV-protective clothing is considered as Category 1 PPE under the scope of the EU Regulation on personal protective equipment. Read the CBI report on swimwear.
  • Leather fashion. To avoid the risk of Chromium VI in leather apparel and accessories, ever more buyers are requiring chrome-free leather tanning. This can be either vegetable tanned or wet-white tanned leather. The most popular certification for leather is Leather Working Group. Two new standards are the Sustainable Leather Foundation (SLF) and Textile Exchange’s Leather Impact Accelerator (LIA). Read the CBI study on leather fashion accessories.
  • Modest fashion. Many people with an Islamic background prefer ‘modest’ styles. In Europe, this target group is underserved but growing. Source for materials that obscure the female silhouette, so no fabrics that are too stretchy or too thin. For specific requirements, read the CBI study on Islamic wear or this article by fashion consultancy Edited about the rise of modest fashion.
  • Special sizes. Following the ‘body acceptance’ trend, ever more European fashion brands have started to include silhouettes in their size range for specific body types, such as plus size, petit, tall and maternity fashion. Check this article by fashion consultancy Edited about the growing market and requirements for special sizes.
  • Made-to-order fashion is a growing niche, pioneered by companies such as Nike, Spreadshirt, Unspun and Munroe Tailoring, offering consumers highly personalised apparel items. This requires from manufacturers ultra-high flexibility and fast delivery, achieved only by a high level of digitalisation and automation. Read the CBI study about digitalisation of the apparel industry.

Examples

  • MUD Jeans is famous for leasing out jeans, collecting them back and recycling them into new pairs.
  • Veja is a successful shoe brand that uses vegan and recycled materials for its sneakers.
  • C&A is a big European value retailer using only chrome-free tanned leather in its collections of shoes and garments.

Further Reading

The CBI report ‘10 tips for finding European buyers’ can help you with finding interesting prospects and how to approach them.

The CBI study ‘10 tips for doing business with European buyers’ provides tips on how to successfully approach a potential buyer and develop a long-lasting business relationship with them.

This study has been carried out on behalf of CBI by FT Journalistiek.

Please review our market information disclaimer.

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The apparel industry is on its way to changing into a CSR-driven industry, in which flexibility and transparency are the keys to success.

Laurent Lambrette

Laurent Lambrette, Linkwear