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What requirements must apparel comply with to be allowed on 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?

There are several mandatory requirements that exporters to the European market need to comply with. This includes legal requirements concerning product safety, the use of chemicals (REACH), quality and labelling. Additionally, many buyers have created non-negotiable terms and conditions which all their suppliers need to respect. These requirements are non-legal, but still mandatory. Both categories of requirements have become stricter in recent years and this trend will continue.

Product safety

Any item on sale in Europe must comply with the EU’s General Product Safety Directive (GPSD) 2001/95/EC. In addition, certain textile and apparel products have specific safety requirements (see below). Product-specific requirements take precedence over the GPSD. National governments will check if your product meets the applicable safety requirements. If your product is considered unsafe, it will be rejected or withdrawn from the European market. If your buyer has supplied the product design, it is his or her responsibility to make sure it is legally safe for consumers to use. However, if you have any doubts that a design is not compliant with the EU’s GPSD, always discuss this with your buyer before you start the production process.


  • Read more about the EU’s definition of safe apparel in the General Product Safety Directive.
  • Ask your supplier of fabrics, trims and accessories if they have supplied to the EU before and if they are familiar with the legal safety requirements for apparel export to the EU.
  • Learn from previously rejected apparel items in the EU’s RAPEX database. Click ‘Search all notifications’ and select ‘Clothing, textiles and fashion items’ for a list of rejected apparel items with detailed descriptions of safety risks.
  • Standards are regularly updated or added. Check pending requests in the Single Market and Standards database (type ‘textile’ in the search field).
  • Learn from the winners of the EU Product Safety Awards about how to successfully conform to both legal and non-legal safety standards.

REACH and the use of chemicals

Perhaps the best known legal requirement for exporting apparel to the EU is REACH, which stands for registration, evaluation, authorisation and restriction of chemicals. This regulation restricts the use of a large selection of chemicals in textiles and leather. The use of these chemicals in apparel is either restricted by limits in weight, usually measured in mg or kg, or prohibited altogether.

Some EU countries have additional national regulation on specific chemicals. For example, Austria, Finland, Germany, Norway and the Netherlands have specific regulations for formaldehyde in textiles; Austria, Denmark, Germany and the Netherlands also have specific regulations for PCP, while Germany also has regulations for disperse dyes in textiles. Switzerland has its own regulation on chemicals, the ORRChem.

Restricted substances lists (RSLs)

On top of REACH, many fashion brands and retailers have formulated restricted substances lists (RSLs) on their own, which are stricter than REACH. Your product needs to comply with these buyer-specific RSLs if you want to do business with them.

Buyer-specific RSLs are often inspired by the Zero Discharge of Hazardous Chemicals (ZDHC) guideline on safe chemicals use. The ZDHC is a foundation that came out of the 2011 ‘Detox my fashion’ campaign by Greenpeace, which was aimed at safer chemical management practices in the apparel industry. Download the ZDHC Conformance Guide to learn how to comply with the ZDHC guideline.


REACH restricted chemicals commonly used in textiles and leather production

The following list contains the most commonly used chemicals in apparel production that are restricted by REACH. The chemicals listed below are grouped in terms of their most common use in the apparel production process. Note that this list is not complete. For the complete list of chemicals restricted by REACH, see the website of the European Chemicals Agency (ECHA).

Restricted chemicals in dyestuffs:

  • Azo dyes, which may release one or more of the 22 aromatic amines listed in Appendix 8 to the REACH regulation, nonylphenol and nonylphenol ethoxylates, and heavy metals, such as mercury, cadmium and lead.

Restricted flame retardants:

  • Tris (2,3-dibromopropyl) phosphate, tris (aziridinyl) phosphinoxide, and polybrominated biphenyls (PBB).

Restricted waterproofing and stain-repelling chemicals:

  • Perfluorooctane sulfonic acid and its derivatives (PFOS) were originally restricted under REACH, but are now restricted under the Stockholm Convention (see persistent organic pollutants below).

Restricted biocides or preservatives:

  • Dioctyltin (DOT) compounds, tributyltin (TBT) compounds, and pentachlorophenol (PCP).

Restricted compounds in metal trims and accessories (zippers, buttons, jewellery):

  • Nickel

Restricted chemicals in plastic or PVC parts:

  • Polycyclic-aromatic hydrocarbons (PAHs), and phthalates.

Restricted chemicals in leather:

  • Chromium VI

Persistent organic pollutants

Note that the use of persistent organic pollutants (POPs) is also restricted, although in most cases not by REACH but by the Stockholm Convention (EU Regulation 2019/1021). POPs are sometimes used to make textiles waterproof or flame-retardant, or to finish leather. Restricted POPs include:

  • Short-chain chlorinated paraffins (SCCP)


How to become REACH compliant

If you export apparel to Europe, you must be compliant with REACH and other relevant regulations. Always expect your buyer to ask for proof that your product is indeed compliant. Any reputable supplier of yarns, dyes, fabrics and leather, labels, prints, trims and accessories should be able to show you a testing report, a REACH compliance certificate or a REACH compliance declaration for the chemicals they have used.


  • Make sure you only work with suppliers of yarns, dyes, fabrics and leather, labels, prints, trims and accessories that are REACH compliant. Ask for proof that they are.
  • In addition, create a contract with your supplier in which the EU legal requirements are specified and indicated.
  • Perform random product test to ensure your supplier has indeed fulfilled his contract. Always use a certified testing laboratory. The most used competence standard for laboratories is ISO/IEC 17025.

The future of REACH

REACH is updated twice a year, which means ever more chemicals become restricted from use in apparel production. The latest update to REACH will lower the restriction limit of 33 chemicals that are considered carcinogenic, mutagenic or toxic for reproduction. The new regulation will take effect on 1 November 2020.


  • Check the coming restriction limits for CMR chemicals on the website of the European Chemicals Agency.
  • Keep yourself up to date on REACH by checking the candidate list of the substances of very high concern, which are under consideration of being restricted by REACH.
  • Most online search engines will let you create a news alert on a topic, so you can automatically follow the latest news on REACH and its updates.

Special requirements for children’s wear

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


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


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.


  • If you use flame-retardant chemicals in your apparel, be aware that you need to conform with REACH regulation for the use of chemicals (see above).

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.



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).


Labelling your product

You must specify the material content of every item of apparel that you export to the EU, in accordance with EU Regulation 1007/2001. The purpose of this regulation is to let consumers know what type of apparel they are buying.


  • Check the EU Trade Helpdesk to find out which apparel items need to be labelled and how to do it.
  • Labelling the country of origin ‘Made in’ or labelling care instructions are not yet legally required in the EU. Including care labels in your apparel is highly recommended though. Consumers expect it, and the EU may find manufacturers liable for defective products under the Product Liability Directive if you do not provide this information. ISO 3758: 2012 is the preferred standard for care labelling.
  • The care label symbols are property of the company GINETEX. If you export to countries like Belgium, Luxembourg, France or Switzerland, you need to pay a fixed compensation to GINETEX for the use of these symbols.
  • Many EU buyers nominate label suppliers, to prevent differences in quality and colour. If you are ordering the labels, note that communication and on-time delivery are your responsibility.

Intellectual property rights

The illegal copying of registered apparel trademarks and designs is considered a serious threat to the European fashion industry. If you are selling your own designs on the European market, you must make sure you are not violating any intellectual property (IP) rights. These rights may apply to the design of the product as well as to any trademarks or images used. If your buyer provides the design, they will also be liable in case the item is found to violate an IP right.


  • Check the EU’s Intellectual Property Office (EUIPO) website for examples of designs and trademarks and a database containing some of the designs protected by IP rights in the EU. For a database of protected designs outside the EU, check the World Intellectual Property Organization’s (WIPO) website.
  • If you want to protect your design in the EU without paying registration fees, you can use an unregistered community design (UCD), which provides protection from copying only for a period up to three years. In this case, your design is automatically protected without any formality after it is first publicly disclosed, which means it has to be published, used in trade, be part of an exhibition or somehow become reasonably known in the apparel sector.
  • If you want to officially register your design in the EU, you can register it online at the EUIPO. You pay €350 for 5 years protection. For international protection outside the EU, you can register your design with the WIPO, which protects your design in 192 countries.


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.


Non-legal mandatory requirements

In addition to the legal requirements mentioned above, you may come across non-negotiable terms and conditions that buyers have created for dealing with suppliers. Such requirements are non-legal, but still mandatory, meaning you cannot get any business if you don’t comply with them. They can be categorised by requirements that concern your supply chain and requirements that concern your product.

Corporate social responsibility

Under pressure from end consumers, politics and media, many buyers in Europe are increasing their demands regarding corporate social responsibility (CSR). The minimum requirement is 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 any topic from the origin of the fibres in the fabrics you use, to the wages you pay your factory workers and the way you manage your factory waste.

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.

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

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.

Non-legal requirements for base materials

The production of base materials (fibres and non-textiles, like leather, fur and down) has impact on water, chemical and energy use and a negative impact on human and animal welfare. To mitigate these risks, buyers may require you to source your base materials from a certified supplier. The following standards and certifications are the most common in the European market

  • BCI (Better Cotton Initiative). A multi-stakeholder initiative with 1,200 members that helps to improve cotton growing conditions globally.
  • GRS (Global Recycled Standard). Product standard that incorporates recycled material verification, including social and environmental responsibility criteria, as well as chemical management.
  • RDS (Responsible Down Standard) and RWS (Responsible Wool Standard). Third-party verified standards that guarantee animal welfare criteria have been met for animals that are kept for their down or wool, including respect for the Five Freedoms.

To insure quality and, in some cases, also environmentally respectful production methods, buyers may require you to source your base materials at a preferred supplier, such as:

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).

  • 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.


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.


  • 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 Tannery of the Future for leather garment producers.

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


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

The future of non-legal mandatory requirements

Although most requirements on fair and sustainable production are still non-legal, the pressure for legislation is building. The German government has already united 50% of the national fashion industry in a sustainability agreement. An accompanying sustainability mark was launched in 2019. The Netherlands has a similar agreement. Both initiatives are considered a prelude to legislation either on national or EU level. Apparel manufacturers should expect stricter requirements on transparency and CSR in the coming years.


2. What additional requirements do buyers often have?

In addition to legal requirements, such as REACH, and the non-legal but mandatory requirements like standards and certifications, 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 don’t 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.


  • Don’t underestimate how difficult it is to understand trends in the European market and translate them to successful apparel items.
  • Visit international fashion fairs to get an idea of the latest fashion trends. Roughly speaking, trends you see today in women’s wear, you will see one or two years later in men’s wear.
  • Read the CBI’s seasonal Fashion Forecast or sign up for the trend forecaster WGSN’s newsletter for monthly snippets of the website’s best content.
  • Other online fashion platforms widely followed by European buyers are FashionUnited, Just-Style, The Business of Fashion and Leatherbiz (for leather products).
  • 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.
  • 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.


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) of every order and share it with your buyer. This file will help you to manage expectations, monitor progress and is the best guarantee of 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. Especially with sales in Europe being under continuous pressure, buyers will try to minimise stock and order as late as possible. Manufacturing and delivering fast is an important implicit requirement.

Within the next three years, you should expect stricter requirements on 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.


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 in 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 71 countries worldwide, giving buyers a substantial financial advantage.


  • Check if your country is one of the 71 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.

  • Denim Expert Limited from Bangladesh is a factory that has successfully developed into a design and innovation driven manufacturing organisation, supplying garments to buyers in the UK, Ireland, Germany, Spain, the Netherlands and Turkey.
  • Shirt By Shirt from Turkey is a design and innovation driven organisation that offers buyers the flexibility of manufacturing in a variety of countries like Turkey, Vietnam and Bangladesh.
  • Crystal Group from China is a CSR-driven apparel maker that offers buyers the flexibility of manufacturing volume orders in different GSP countries within their own factories.

3. What are the requirements for 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 don’t service this group. However, as sales in the main stream 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.
  • 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.
  • Children’s and baby 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).
  • Pet clothing. The manufacturing of pet clothing requires no compliance with specific regulation. Only the sizing of pet clothing is complicated. Buyers will require you to produce size-adjustable styles.
  • Work wear. 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.
  • Corporate wear. Many large organisations like banks and hotels tender their corporate ware. 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. High-performance wear is a niche market in which many technical innovations are implemented. 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. Check this article on Textile World for background info.
  • Medical and 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. Medic and 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.
  • 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.
  • Leather. 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. Popular certifications for leather are Leather Working Group and Naturleder. The Textile Exchange has also started developing a new international standard for fair and sustainable leather, but is has not published it yet.
  • Zero-emission apparel. Sustainable apparel is outgrowing the niche category (see the ‘Non-legal mandatory requirements’ section in this report). The term can mean many things: organic fabrics, fair wages, responsible waste management and more. In 2019, a big group of buyers has pledged to give special attention to cutting carbon emissions. Kering Group and Gap want to use 100% renewable energy by 2030. H&M even wants to become carbon positive by 2040, so investing in renewable energy can give you a competitive edge.


  • Hip Doggie is a good example of a successful pet apparel company.
  • 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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