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

To enter the European market, you need to comply with several mandatory (legal) requirements, as well as any additional or niche requirements your buyers may have. For home decoration and home textiles (HDHT), legal requirements focus mainly on consumer health and safety. Products should function well, and risks should be minimised, for example by avoiding hazardous chemicals. Trade in wildlife and timber products is restricted, and both social and environmental sustainability are becoming increasingly common requirements.

1. What are mandatory requirements?

The European Union has several laws that apply to HDHT products. Several of these directives and regulations may apply to a single product. This chapter gives you an overview of the most important mandatory requirements for entering the European market.

General Product Safety Directive

The General Product Safety Directive (2001/95/EC) applies to all consumer products. It states that products sold on the European market must be safe to use. Your product must bear information such as the manufacturer’s identity and a product reference, so that dangerous products can be traced. Where necessary for safe use, your product must also be accompanied by warnings and information about any inherent risks.

Standardisation organisations such as CEN and CENELEC create European Standards (EN) to accompany the General Product Safety Directive. These technical documents clarify what is deemed ‘safe’ for specific product types. Adhering to such standards can help you comply with the General Product Safety Directive.

Unsafe products are rejected at the European border or withdrawn from the market. The Safety Gate rapid alert system (RAPEX) lists such products. It provides information on the types of products, the risks posed, and measures taken at the national level to restrict or prevent their marketing. As a result of the latest revision of the General Product Safety Directive, a new General Product Safety Regulation is in the works.

In 2021, the Market Surveillance Regulation (EU 2019/1020) came into force. This mainly affects online business-to-consumer (B2C) trade between non-European parties and European consumers, which is generally not feasible for you. According to Article 4 of the Market Surveillance Regulation, non-European manufacturers of products such as toys or energy-related products must have an ‘economic operator’ in Europe, often the importer.

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

The REACH Regulation (EC 1907/2006) lists restricted chemicals in products that are marketed in Europe. It aims to improve the protection of human health and the environment through the better and earlier identification of the properties of chemical substances. 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. What 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

The REACH regulation is scheduled for revision in 2022.

Food contact materials regulation

Food safety is a major concern in Europe. Safety measures reach further than food itself, to cover materials that come into either direct or indirect contact with food. These so-called food contact materials (FCMs) include HDHT products like kitchenware and tableware.

The European Food Contact Materials Regulation (EC 1935/2004) aims to ensure that these products do not release any substances they are composed of into food at levels that may be harmful to consumer health. They also cannot influence the quality of food. Another requirement is that the packaging of FCMs must be labelled with specific symbols, such as the food safe symbol. In addition, the Regulation on Good Manufacturing Practice (EC 2023/2006) ensures that the manufacturing process of FCMs is well controlled.

FCM legislation also consists of specific Directives for items made of plastic (EU 10/2011), recycled plastic (EC 282/2008) and ceramics (84/500/EEC). These Directives set out rules for the composition of these FCMs, permitted substances and Specific Migration Limits (SMLs). FCMs that pose health hazards are listed in the Rapid Alert System for Food and Feed (RASFF).

Various aspects of FCM legislation are being revised and/or amended. For example, following increasing concerns about the health effects of heavy metals, such as lead and cadmium in ceramics, the European Commission has proposed plans to lower the maximum limits.

Timber Regulation

The EU Timber Regulation (EUTR – EU 995/2010) aims to counter illegal logging by prohibiting illegally harvested timber products on the European market. It also applies to HDHT products like wooden furniture or decorative objects. Recycled products and printed papers are not included.

To comply, your European buyers have to exercise ‘due diligence’, to prove that any timber used in your products was harvested legally. You must be able to provide them with information like the tree species, the origin of the wood and proof of compliance with national laws and regulations. Products with a FLEGT or CITES license also comply with the EUTR, meaning they are exempt from the due diligence obligation.

FLEGT

As part of its FLEGT Action Plan, the European Union introduced Voluntary Partnership Agreements (VPAs). These legally binding trade agreements with exporting countries ensure that exported timber products come from legal sources. They also help exporting countries stop illegal logging by improving foresting regulation and governance.

In 2016, Indonesia became the first country to issue FLEGT licenses under this type of VPA construction. Cameroon, Central African Republic, Ghana, Guyana, Honduras, Liberia, Republic of the Congo and Vietnam are currently in the implementation phase, while Côte d'Ivoire, Democratic Republic of the Congo, Gabon, Laos, Malaysia and Thailand have started negotiations.

Wildlife Trade Regulations and CITES

The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) restricts the international trade in specimens of wild animals and plants, to ensure it does not threaten their survival. This includes products that are derived from these species, like timber or exotic leather goods.

The European Union implements CITES through the Wildlife Trade Regulations. These regulations actually go beyond the requirements of CITES. For example, they include more species than the standard CITES list and set stricter import conditions.

Textile Regulation

The European Textile Regulation (EU 1007/2011) states that textile products must be labelled or marked, to ensure that consumers know what they are buying. This regulation applies to all products that contain at least 80% (by weight) of textile fibres. The label should indicate the full fibre composition of the product and, if applicable, the presence of non-textile parts of animal origin. It has to be durable, easily legible, visible, accessible, and printed in all the official national languages of the European countries the product is sold in.

There is no Europe-wide legislation on the use of symbols for washing instructions and other care aspects of textile articles. Because consumers do consider care information to be important information on a product label, you are advised to follow the ISO 3758:2012 standards on the care labelling code using symbols for textiles.

In 2020, the European Commission adopted the Circular Economy Action Plan as a main building block of the European Green Deal. In March 2022, it presented a proposal for a Strategy for Sustainable and Circular Textiles as part of the Green Deal.

The goal of this strategy is to ensure that by 2030, textile products placed on the European market are:

• durable, repairable and recyclable
• to a great extent made of recycled fibres
• free of hazardous substances
• produced respecting social rights

CE marking for toys and energy-related products

The European Conformity (CE) mark signals that a product meets high safety, health, and environmental protection requirements. However, it does not indicate that a product has been approved as safe. CE marking is compulsory for most products covered by the so-called New Approach Directives, including toys and energy-related products (products that directly use energy or indirectly affect energy consumption). Affixing CE marking to other products is forbidden.

In addition to the CE mark, importers must provide a Declaration of Conformity and a technical file to affirm that the product fully complies with European Union regulations. These documents can be issued without third-party verification of compliance, but the European Commission expects importers to verify that “the manufacturer outside the European Union has taken the necessary steps to allow the product to enter the European market”.

Energy-related products have to comply with the Energy Labelling Regulation (EU 2017/1369) as well. This Regulation is working towards the achievement of the energy efficiency targets and the goals for the environment and climate change in the 2030 Climate and Energy Framework. Since 2019, suppliers (manufacturers, importers or authorised representatives) also need to register appliances that require an energy label in the European Product Database for Energy Labelling (EPREL) before selling them on the European market.

In March 2022, the European Commission adopted an Ecodesign and Energy Labelling Working Plan 2022–2024 as part of the Green Deal. This plan covers new energy-related products and updates and increases the ambition for products that are already regulated. It functions as a transitionary measure until the proposed new Ecodesign for Sustainable Products Regulation enters into force.

Waste Electrical and Electronic Equipment

The Waste from Electrical and Electronic Equipment (WEEE) Directive (2012/19/EU) ensures that importers provide adequate information and give consumers guidance on how to recycle, sort and handle electrical and electronic products. The WEEE label must appear on these products, including lamps and toys. 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 should be accessible, durable, legible and indelible.

The Restriction of Hazardous Substances (RoHS) Directive (2011/65/EU) also aims to increase the amount of WEEE that is appropriately treated and to reduce the volume that goes to disposal. It requires heavy metals and flame retardants to be replaced by safer alternatives and sets out maximum levels for restricted substances.

Dangerous products resembling foodstuffs

Directive 87/357/EEC on dangerous products resembling foodstuffs bans decorative items that look so much like food that consumers could mistake them for real food products. This could be due to characteristics such as shape, colour, smell, appearance and size. Because children could be tempted to eat them, these food-imitating products pose a choking hazard. A variety of products fall within this category, such as food-shaped candles and soaps.

Liability for defective products

The Product Liability Directive (85/374/EEC) entitles consumers to compensation if a defective product causes damage to consumers or their property. The importer is liable, but they may pass a claim on to you. The Directive applies to all products used for private consumption that are marketed in the European Union, with a minimum price of €500. It forbids adding clauses that limit or exclude the liability of the producer.

In 2020, the European Commission published a report on the safety and liability implications of Artificial Intelligence, the Internet of Things and robotics. This report suggests the Product Liability Directive may require some adjustments to address these new technologies.

Ban on single-use plastics

The Single-Use Plastics Directive (EU 2019/204) bans selected single-use plastic products for which alternatives exist on the market, including single-use plastic cutlery, plates, cotton buds, straws, stirrers, balloon sticks, oxo-degradable plastics and food containers and expanded polystyrene cups. Replacements have to be made from biologically sourced materials that can be composted. For suppliers of bio-degradable alternatives for single-use plastics, this offers new opportunities.

Action on plastics is a priority in Europe’s Circular Economy Action Plan. The plastics strategy will transform the way plastic products are designed, used, produced and recycled in the European Union. It includes the Plastic Bags Directive (EU 2015/720), which aims to reduce the consumption of lightweight plastic carrier bags significantly.

Intellectual property rights

When you develop HDHT products for the European market, you have to make sure you do not copy an existing design. Intellectual property (IP) is protected in Europe, and products that violate IP rights are banned from the market. In November 2020, the European Commission adopted a new IP action plan, which should give European companies easier access to fast, effective and affordable protection tools.

Packaging

Europe has a specific Packaging and Packaging Waste Directive (94/62/EC). This 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 ask you to minimise the use of packaging materials (paper, carton, plastic) or use a different kind of (recycled) material.

According to the Plant Health Law (EU 2016/2031), Europe also has requirements for wood packaging materials used for transport, such as:

• packing cases
• boxes
• crates
• drums
• (box) pallets
• dunnage

All wood packaging material and dunnage from non-European Union countries must be:

• heat treated or fumigated in line with International Standards for Phytosanitary Measures (ISPM15)
• marked with the ISPM15 stamp and the IPPC logo
• debarked

These requirements do not apply to:

• wood 6mm thick or less
• wood packaging material made entirely from processed wood produced using glue, heat and pressure, such as plywood, oriented strand board and veneer
• wood packaging material used in trade within the European Union

The objective 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.

In the new Circular Economy Action Plan, packaging is identified as a sector that uses most resources and where the potential for circularity is high. The European Commission is reviewing the requirements on packaging and packaging waste to reinforce the mandatory requirements for packaging to be allowed on the European market and will also consider other measures.

2. What additional requirements and certifications do HDHT buyers often ask for?

Sustainability

Social and environmental sustainability are becoming more and more common requirements on the European market. Think of sustainable raw materials and production processes, as well as the impact your company has on the environment and the wellbeing of your workers and the community. You can use these topics in the “story” behind your product and company. Buyers appreciate good storytelling to create an emotional connection with their customers.

An increasing number of European buyers would like you to comply with the following schemes:

• Business Social Compliance Initiative (BSCI): an initiative to improve social conditions in sourcing countries. They expect their suppliers to comply with the BSCI Code of Conduct.
• Ethical Trading Initiative (ETI): an alliance of companies, trade unions and voluntary organisations. ETI aims to improve the working conditions in global supply chains via their ETI Base Code of labour practice.
• Sedex: a membership organisation striving to improve working conditions in global sourcing chains. The Sedex Advance platform lets you share your sustainable performance, based on a self-assessment.

You can use standards such as ISO 14001 and SA8000 to read up on sustainable options. ISO 14001 sets out a framework for setting up an effective environmental management system. SA8000 focuses on the fair treatment of workers, measuring social performance in eight areas. However, only niche market buyers demand compliance with these standards.

An impressive 83% of citizens agree that European legislation is needed to protect the environment. The new Circular Economy Action Plan of the European Green Deal aims to make sustainable products the norm. In March 2022, the Commission proposed an Ecodesign for Sustainable Products Regulation. It sets new requirements to ensure that products are designed to last longer, are easier to reuse, repair and recycle, and incorporate recycled raw materials wherever possible. It also restricts single use, tackles the premature failure of products and bans the destruction of unsold durable goods.

Crystalline Silica

Respirable Crystalline Silica (RCS) can cause lung cancer through inhalation. The ceramics industry mostly uses crystalline silica in the form of quartz and cristobalite. European buyers care about worker safety, and they may demand good handling of crystalline silica during the production of ceramics.

Labelling and packaging 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
• quantity
• size
• volume
• caution signs

Your buyer will specify what information they need on the product labels or on the item itself, such as logos or ‘Made in…’ information. This is part of the order specifications. It is common in Europe to use EAN or barcodes on the product label. Labelling should be in English, unless your buyer indicates otherwise. For more information on labelling textile products, refer to the section on the Textile Regulation.

When packaging your products for transport, you should comply with the importer’s order specifications. You also have to take into account:

• how you can best prevent damage
• what the optimal packaging dimensions and weight are
• how you can minimise costs
• what packaging material you should use
• whether you have to provide consumer packaging

3. What are the requirements and certifications for HDHT niche markets?

Table 1: Most important certifications requested by European HDHT buyers

Name	Type	Cost for companies	Tips
WFTO	Fair trade	Use the fee calculator to determine your annual fee, which depends on your turnover and location. You also have to pay for a monitoring audit upon application, and every 2-6 years after becoming guaranteed.	Comply with the WFTO’s fair trade principles, even if you cannot afford to become officially guaranteed or certified to show your commitment.
Fair for Life	Fair trade	Certification costs vary depending on factors including company size and location. You have to apply to get an exact offer.	Familiarise yourself with the Fair for Life standard.
FSC	Sustainable wood	The first step towards FSC certification is to contact an FSC accredited certification body for a quote.	Follow the 5 steps towards FSC certification.
GOTS	Sustainable textiles	Companies with 1 facility can expect annual certification costs of €1,200-€3,000, plus an annual license fee of €150.	Use GOTS-certified organic yarn or fabric instead of applying for your own certification. Just make sure to communicate clearly that the certification applies to the yarn or fabric, and not to the rest of the product’s components and related production processes.
OEKO-TEX	Sustainable textiles	The cost of STANDARD 100 certification includes the costs for the licence, company audit, and laboratory and administrative tests. You can obtain a cost estimate from your appointed OEKO-TEX institute.	Use OEKO-TEX-certified yarn or fabric instead of applying for your own certification. This can significantly reduce the costs for laboratory tests by avoiding duplicated tests.

Source: Globally Cool

Fair trade

According to the World Economic Forum, 86% of people want significant change to make the world fairer and more sustainable after COVID-19. The concept of fair trade supports fair pricing and improved social conditions for producers and their communities. Especially if your production process is labour intensive, fair-trade certification can give you a competitive advantage.

Common fair-trade certifications are issued by the World Fair Trade Organisation (WFTO) and Fair for Life. For most fair-trade-oriented buyers in Europe, however, simply complying with the WFTO’s fair trade principles is enough.

Sustainable wood

Forest Stewardship Council (FSC) certification is the most common label for sustainable wooden products, including paper. FSC-certified products are especially popular in Western European markets. FSC chain of custody certification guarantees that a product’s source material comes from responsibly managed forests. These forests should be managed in a way that preserves biological diversity and benefits the lives of local workers and people.

The Programme for the Endorsement of Forest Certification (PEFC) is another option. Like with FSC certification, PEFC chain of custody certification verifies that the certified forest-based material contained in a product comes from sustainably managed forests.

Because these certification programmes are aligned with the EUTR, they also provide a way to show legal compliance.

Sustainable textiles

While sustainability is becoming more and more common, the actual use of certification is lagging behind. However, buyers are increasingly interested in certification to “prove” their sustainability – particularly organic certification.

Some of the most popular certifications for home textiles are:

• Global Organic Textile Standard (GOTS) – a textile-processing standard for organic fibres that ensures environmental and social responsibility throughout the production chain of textile products.
• OEKO-TEX Standard 100 certification – guarantees that textile articles are free from harmful substances.

Other options include the Nordic Swan Ecolabel (used in the Nordic countries) and the EU Ecolabel. The Ecolabel is awarded only to products with the lowest environmental impact in a product range.

Ethical carpets

Several certification programmes focus specifically on the carpet industry:

• GoodWeave (formerly known as Rugmark) works to end child labour in global supply chains, including in the carpet industry in South Asia.
• Care & Fair is an initiative of the European carpet trade. It aims to combat illegal child labour and improve the situation of carpet weaving families in India, Nepal and Pakistan.
• Label STEP focuses on working and living conditions of carpet weavers and the fight against child labour.

This study was carried out on behalf of CBI by Globally Cool B.V. in cooperation with GO! Good Opportunity and Remco Kemper.

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