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What requirements must home decoration and home textile products comply with to be allowed on the European market?

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This study provides an overview of the requirements, mandatory and non-obligatory, when you would like to enter the European home decoration and home textile (HDHT) market. Mandatory requirements are mainly focused on ensuring that products are safe for consumers. In addition, buyers often have additional requirements exporters should comply with; environmental sustainability requirements are upcoming. Moreover, fair-trade and environmentally friendly made products provide an interesting opportunity. This study shows the most important certifications and eco-labels.

1. What are mandatory requirements?

Within Europe there are several laws that should be taken into account when exporting HDHT products to the European Union. Below you can find an overview of the most important mandatory requirements when entering the European market and how you can deal with these requirements.

General Product Safety Directive

When exporting consumer products to the European Union, make sure to comply to the General Product Safety Directive. It states that products sold on the European market should be safe. In case of potential risk you should take corrective action. A product is safe if it meets European standards and standards in your specific target country. Another key point is that your product must bear information so it can be traced (for example manufacturer’s identity and product reference).

Unsafe products are rejected at the European border or withdrawn from the market. The European Union has introduced a rapid alert system (RAPEX) to list such products. It provides information on the type of products, the risks posed, and measures taken at the national level to restrict or prevent their marketing.

In 2013, the European Commission introduced a new proposal – Product Safety and Market Surveillance Package - to make it simpler to remove unsafe products from the market and to increase product traceability and market surveillance. However, in October 2019 the Parliament decided to carry the file over into the new term and hence the regulation is put on hold.

Currently, the General Product Safety Directive does not take into account risks linked to the evolution of products incorporating machine learning. The European Trade Union Institute (ETUI) states that the European Commission will make a proposal for a revision of the Directive in 2020. New technologies, like Artificial Intelligence, transform the characteristics of many products. Challenges that need to be solved are pre-market surveillance, products with integrated software and the set-up of traceability systems for such products.

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Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH)

REACH is a European regulation on the production and trade in chemical substances and describes what rules companies must comply with. This is done through four processes: the registration, evaluation, authorisation and restriction of chemicals. It applies to all products that contain chemical substances such as furniture and textiles. Which chemicals are relevant for you depends on your specific products and materials.

For example, REACH restricts the use of:

  • Several azo dyes used particularly for textile products.
  • Lead in paints and glazings of ceramics.
  • Cadmium compounds in various applications.
  • Arsenic and creosotes as wood preservatives.
  • Flame retardants, including TRIS, TEPA and PBB.
  • Organostannic compounds and phthalates in PVC.

Make sure to check Annex XVII for all the substances that are restricted under REACH. In October 2018 the European Commission announced new limits for CMR substances (substances that are carcinogenic, mutagenic or toxic for reproduction). These new limits will affect, among others, textiles such as blankets, towels, cushion covers. Requirements will be applicable as per 1 November 2020.

The REACH regulation is evaluated every 5 years to monitor progress in the achievement of its objectives. The second REACH Review – REACH REFIT evaluation - was carried out in 2017. This means the next review will be in 2022. The evaluation will build on the findings of the previous evaluation and examine key developments since then. It will cover the following criteria: effectiveness, efficiency, relevance, coherence and EU added value. Make sure to follow the developments of this regulation.

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Food contact materials regulation

If you want to export products to the European market that - either direct or indirectly - come into contact with food, you should comply with the Food Contact Materials regulation (FCM). It sets out rules on FCM to make sure that substances do not affect the quality of food or consumer health. For the HDHT sector you can think of kitchenware and dinnerware. In case your product intends to come into contact with food, make sure to check the European food safety authority that provides opinions on substances.

Another requirement is that the packaging of products that come into contact with food must be labelled with specific symbols, such as the food safe symbol.

As there are increasing concerns of the health effects of heavy metals, for example lead and cadmium in ceramic, plans have been proposed by the European Commission to lower the maximum limits. It is expected that more stringent limits will be announced in 2020.

The FCM regulation is currently under evaluation; this will be completed in the first quarter of 2020. It will cover the functioning of the FCM regulation and examine materials for which there are no European Union measures and which are subject to permitted national measures. Public consultation shows that for the future more harmonisation at the European level is desirable, compared to individual member state legislation.

In addition, the Joint Research Centre gives an indication on what future developments to expect concerning FCM regulation. It shows possible safety and trade impact of the current legislation and indicates where improvements are needed. It will support a Commission's evaluation to consider what steps can be taken in the future about FCMs in the European Union.

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Timber regulation

With the EU Timber Regulation (EUTR) the European Union seeks to prevent trade in illegally harvested timber and timber products. It is forbidden to place illegally harvested timber products on the European market. For the HDHT sector it applies to, among others, wood products, flooring, plywood and paper. Recycled products are excluded.    

The natural or legal person that actually places timber on the European market for the first time is responsible to exercise due diligence. This means that operators must undertake a risk management exercise to minimise the risk of placing illegally harvested timber - or timber products containing illegally harvested timber - on the European market. This due diligence system consists of the following elements:

  • Information: the operator needs to have access to product information and information on compliance with the national legislation. Upon request, as a supplier you have to provide documents on for example type of product, name of tree species, country of harvest, quantity, company information and compliance with relevant legislation.
  • Risk assessment: based on the above information and criteria set out in the regulation, the operator needs to assess if there is a risk of illegal timber in the supply chain. 
  • Risk mitigation: if there is a risk of illegal timber, the risk can be mitigated by demanding additional information and verification from the supplier.

If your product is FLEGT or CITES licensed, this product is already considered to be legal and no additional information, risk assessment and risk mitigation is needed.

The European Union implemented a FLEGT Action Plan to address illegal logging and associated trade on the basis of cooperation between producers and consumers. Its supply-side measures include a Voluntary Partnership Agreement (VPA’s) – legally binding trade agreements – between the European Union and timber exporting countries. It is expected that in the future more countries will get a VPA; nine countries are in the implementation phase and six countries started with the negotiations. Stay up to date on the developments.

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Wildlife Trade Regulations and CITES

With the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) governments want to ensure that international trade in specimens of wild animals and plants does not threaten their survival. This includes products that are derived from these species. It is implemented in the European Union through the Wildlife Trade Regulations. These regulations have stricter conditions than the CITES; more species are listed and it has stricter import conditions.

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Textile regulation

The European Textile Regulation states that textile products need to be labelled or marked. The purpose is to make sure that consumers within the European Union know what they are buying. It is applicable to all products that contain at least 80% (by weight) of textile fibres. Make sure to have a label that states the full fibre composition of the product and, if applicable, the presence of non-textile parts of animal origin. The label should be durable, easily legible, visible and accessible.

There is no European Union-wide legislation on the use of symbols for washing instructions and other care aspects of textile articles. However, consumers consider care information to be the second most important information on a product label (after size). You are therefore advised to follow the ISO 3758: 2012 standards on the care labelling code using symbols for textiles.

The European Union recently – March 2020 – announced the Circular Economy Action Plan. In the future, the European Commission will launch a new strategy for textiles to strengthen competitiveness and innovation in the sector. Moreover, it wants to boost the European market for sustainable and circular textiles.

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Packaging

Europe has specific packaging and packaging waste legislation. This EU Directive was adopted to harmonise measures concerning the management of packaging and packaging waste and to prevent or reduce its impact on the environment at European level. Buyers may therefore request you to minimise the use of packaging materials (paper, carton, plastic) or to use different kind of (recycled) material.

The objective of this Directive is to prevent materials that are harmful to plants or plant products from being introduced into and spreading within the European Union. It also regulates imports from third countries in line with international plant health standards. Keep this in mind when you decide on the packaging of your product.

Europe also has requirements for wood packaging materials (WPM) used for transport, such as packing cases, boxes, crates, drums, pallets, box pallets, and dunnage. Companies from outside the European Union must follow certain rules on wood packaging material and dunnage. For example, it has to be heat treated or fumigated in line with International Standards for Phytosanitary Measures (ISPM15). In addition, it must be debarked and marked with the ISPM15 stamp and IPPC logo.

In March 2020, the European Union introduced a New Circular Economy Action Plan. It is Europe’s new agenda for sustainable growth. Packaging is identified as a sector that uses most resources and where the potential for circularity is high. All packaging on the European market should be reusable or recyclable in an economically viable way by 2030. The European Commission will review Directive 94/62/EC to reinforce the mandatory requirements for packaging to be allowed on the European market and will also consider other measures.

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Dangerous products resembling foodstuffs

Some decorative items look so much like food, that consumers could mistake them for real food products. In addition, because children could be tempted to eat them, these food-imitating products pose a choking hazard for children. Products resembling foodstuffs are not allowed on the European market. The European Union’s Council Directive 89/357/EEC on dangerous products resembling foodstuffs bans these items from the European market.

Hence, when designing your product, make sure that they do not resemble food too closely in appearance, colour, size, form, labelling, scent, packaging and volume. A variety of products fall within this category, such as food-shaped candles and soaps.

Tip:

  • Check the Safety Gate – Search Alerts of the RAPEX database for products that resemble food to closely. Search for ‘Food-imitating products’. This gives you an idea of the designs to avoid.

CE marking

The European Conformity (CE) mark is the primary way for manufacturers to show compliance with the European Union requirements. Importers and consumers alike are familiar with this mark, as it is a major requirement to eliminate hazards to consumers and appears on many different types of products. In the HDHT industry you will need CE marking if you for instance produce electronic products like lighting.

The CE mark itself does not represent any individual European Union directive. But rather, the CE mark signals that the product complies with applicable European Union directives for that product. In addition to the CE mark, importers must provide a Declaration of Conformity and a technical file to affirm the product fully complies with European Union regulations.

The Declaration of Conformity and technical file can be issued without third-party verification of compliance for the directives. But the European Commission expects importers to verify “the manufacturer outside the EU has taken the necessary steps to allow the product to be placed on the EU market”.

As of January 2019, suppliers - manufacturers, importers or authorised representatives - need to register their appliances that require an energy label in the European Product Database for Energy Labelling (EPREL). This needs to be done before selling the products on the European market. The energy labelling requirements for individual product groups are established under Regulation 2017/1369. It is mandatory for, among others, lighting products.

In addition, electronic products must show the energy efficiency. In July 2017 the European Commission published a new Energy Labelling Regulation (Regulation 2017/1369) to gradually replace the Energy Labelling Directive. Energy efficiency is a crucial element of the European Union’s 2030 Climate and Energy Policy Framework. The legislation is working towards the achievement of the 2030 energy-efficiency targets and the goals for the environment and climate change.

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Electrical and Electronic Equipment Directives

A key marking required to import electrical and electronic equipment such as lighting into the European Union is the Waste Electrical and Electric Equipment label (WEEE). This Directive ensures that importers provide adequate information and give consumers guidance on recycling, sorting and handling of certain products. This mark is mandatory for all electrical and electronic equipment under the European Directive.

Manufacturers or importers in the European Union have the responsibility to register the product that they put on the market and to mark it accordingly. The marking shall be accessible, durable, legible and indelible.

In addition to the WEEE Directive, the European Union has a Directive restricting the use of hazardous substances in electrical and electronic equipment (RoHS). It requires heavy metals and flame retardants to be replaced by safer alternatives and sets out maximum levels for restricted substances. Recently, there has been an update on this Directive, RoHS 3 (EU 2015/863), and adds four new restricted substances to the list, all phthalates. This Directive is in effect from 22 July 2019.

Tips:

  • If you are a producer of electronic products such as lighting you should get familiar with the WEEE Directive.
  • Please check the RoHS guide to find out more about all restricted substances and the maximum levels that are allowed.

Liability for defective products

The directive on liability for defective products states that when a product gets damaged and causes damage to consumers or their property, consumers can get compensation. In that case, producers have to provide compensation whether or not it is the fault of the producer. The importer is liable, but they may pass a claim on to you. The Directive applies to all products used for private consumption – with a minimum of €500 - that are marketed in the European Union. It forbids adding clauses that limit or exclude the liability of the producer.

The Product Liability Directive is currently under evaluation to see if the Directive is still adequate. Especially concerning the liability and safety framework for new technological developments, artificial intelligence, the internet of things and robotics.

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Ban on single-use plastics

The European parliament has voted in favour of banning single-use plastic items. The plastic products to be banned under the Single-Use Plastics Directive include single-use plastic cutlery, plates, cotton buds, straws, stirrers, balloon sticks, oxo-degradable plastics and food containers and expanded polystyrene cups. The ruling has to become law in the European Union by 3 July 2021.

France already passed a law in 2016 banning these items as of 2020 and stating replacements will need to be made from biologically sourced materials that can be composted. For suppliers of bio-degradable alternatives for single use plastics the ban offers new opportunities.

Actions on plastics is identified as a priority in the strategy of Europe’s transition towards a circular economy.  The strategy will transform the way plastic products are designed, used, produced and recycled in the European Union. Make sure to keep up to date on the developments.

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Labelling requirements

The information on the outer packaging of your product should correspond to the packing list sent to the importer. The external packaging labels should include producer name, consignee name, material used, quantity, size, volume and caution signs. Your buyer will specify what information they need on the product labels or on the item itself. For instance, logos or 'made in…' information. This is part of the order specifications. It is common in Europe to use EAN or barcode on the product label.

Tips:

  • Ask your buyer for specific packaging and labelling requirements.
  • Use the English language for labelling unless your buyer has indicated otherwise.

2. What additional requirements do buyers often have?

Sustainability

Currently, social and environmental sustainability make your products stand out on the European market; buyers appreciate a good story. Think of sustainable raw materials and production processes and the impact your company has on the environment, the wellbeing of your workers and society as a whole. Nowadays, an increasing number of European buyers demand the following certification schemes:

  • Business Social Compliance Initiative (BSCI): European retailers developed this initiative to improve social conditions in sourcing countries. They expect their suppliers to comply with the BSCI Code of conduct. To prove compliance, the importer can request an audit of your production process. Once a company is audited, it is included in a database for all BSCI participants.
  • Ethical Trading Initiative (ETI): This initiative is an alliance of companies, trade unions and voluntary organisations. It aims to improve the working lives of people across the globe that make or grow consumer goods.
  • Standards such as ISO 14001 and SA 8000 can be used to meet buyer demands for sustainability. ISO 14001 sets out a framework a company can follow to set up an effective environmental management system. SA 8000 focuses on the fair treatment of workers across industries and in any country; it measures social performance in eight areas. However, compliance with these specific standards will only be demanded in niche markets.

A recent study by the International Trade Centre concluded that, irrespective of the product, retailers in the major European markets are putting more products on their shelves that are environmentally and socially sustainable. Simply, because consumers ask for it.  According to the survey, 98.5% of retailers consider sustainability as a factor in their product sourcing decisions.

In March 2020, the European Union presented measures to make sustainable products the norm in Europe in the future. The European Commission will propose legislation on sustainable product policy to ensure that products placed on the market are designed to last longer, are easier to reuse, repair and recycle, and contain as much recycled material as possible. In addition, single-use products will be restricted and the destruction of unsold durable goods banned. Make sure to follow the developments of the Circular Economy Action Plan.

Tips:

  • If you can show your sustainability performance, this may be a competitive advantage now but it will increasingly become the norm.
  • Show your sustainability performance with a self-assessment like the BSCI Self-Assessment for Producers, or a code of conduct such as the ETI base code.
  • For a full overview of certification schemes in the sector consult ITC Sustainability Map.

3. What are the requirements for niche markets?

Fair trade

The concept of fair trade supports fair pricing and improved social conditions for producers and their communities. Especially when the production is labour intensive, fair trade certification can give you a competitive advantage. Common fair-trade certification schemes are from World Fair Trade Organisation (WFTO), Fairtrade International and Fair For Life.

Tips:

  • Ask buyers what they are looking for. Especially in the fair-trade sector, you can use the story behind your product for marketing purposes.
  • Check the ITC Standards map database for more information on voluntary standards and their requirements, including fair production.
  • Determine which certification programme would be the best fit for you and apply if possible.
  • If a certification is not possible, work according ‘Fair Trade Principles’ without being officially guaranteed or certified. Ensure your company processes are sufficiently documented in order to sustain your claim.

Textile certification

While sustainability is gaining ground, the actual use of certification is still not common in this sector, apart from organic certifications that are becoming widespread. As this is a means of demonstrating sustainability, there is an increasing interest from buyers. There are several eco-labels used for textiles:

  • The Global Organic Textile Standard (GOTS) is a textile-processing standard for organic fibres. It ensures environmental and social responsibility throughout the production chain of textile products.
  • OEKO-TEX Standard 100 certification guarantees that no hazardous chemicals are used in the production of textiles. It provides textile and clothing companies with more transparent supplier relationships and facilitates the flow of information regarding potential problematic substances.
  • The European Union’s Ecolabel seeks to minimise products’ environmental impact and therefore looks at the use of environmentally friendly chemical options. The label is awarded only to products with the lowest environmental impact in a product range.
  • The voluntary Nordic Swan eco-label is used in Sweden, Norway, Finland, Denmark and Iceland for textile products.

Tips:

  • Check the possibility of sourcing organic cotton. Textile products that contain a minimum of 70% organic fibres can become GOTS certified. The easiest way is to use certified organic cotton yarn in case you are weaving the fabric yourself, or certified organic cotton fabric in case you are into CMT (Cutting Making Trimming) only.
  • Read more about GOTS, OEKO-TEX and the European Union’s Ecolabel on the ITC Standards Map.
  • Determine which certification programme would be the best fit for you and apply if possible.

Certification for wooden products

The Forest Stewardship Council certification (FSC) is the most common label for sustainable wooden products, including paper. The FSC label guarantees that a product’s source material comes from responsibly managed forests. These products are especially popular in Western European markets. There are ten principles you must comply with before you can receive a FSC certification. In general, forest should be managed in a way that it preserves biological diversity and it should benefit the lives of local workers and people.

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Certification ethical carpets

Specifically focused on the carpet industry, there are several certification programmes. GoodWeave seeks to end child labour in South Asia. Label STEP is a label for fair trade in handmade carpets and deals with working and living conditions (including prohibition of child labour), fair wages and eco-friendly production of carpet weavers. Care & Fair is an initiative of the European carpet trade. It wants to combat illegal child labour, create better living conditions and focuses on socially acceptable production.

Tips:

  • To target the ethical niche market, you need to find business partners in this niche. Study the initiatives and how they work to determine if your company would be a good match.
  • Use the ITC Standards map to find more information on GoodWeave.

This study has been carried out on behalf of CBI by Globally Cool B.V. in collaboration with Remco Kemper (MDD).

Please review our market information disclaimer.

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