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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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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.

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General Product Safety Directive

The General Product Safety Directive applies to all consumer products. It states that products sold on the European market must be safe to use. A product is safe if it meets European standards and standards in your specific target country. 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.

Unsafe products are rejected at the European border or withdrawn from the market. The Safety Gate rapid alert system (RAPEX) lists such products, providing information on the types of product, the risks posed, and measures taken at the national level to restrict or prevent their marketing. A revision of the General Product Safety Directive is scheduled for the second quarter of 2021.

The new Market Surveillance Regulation comes into force in July 2021. It mainly affects online business-to-consumer (B2C) trade between non-European parties and European consumers, which is generally not feasible for you. According to the Market Surveillance Regulation, non-European manufacturers must have an ‘economic operator’ in Europe, often the importer. In online B2C sales, consumers are the importer, which currently makes them responsible for product safety. The new legislation places this responsibility with the economic operator.

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

The REACH Regulation 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

In October 2018, the European Commission announced new limits for 33 CMR substances (substances that are carcinogenic, mutagenic or toxic for reproduction). These limits apply per 1 November 2020 and affect textiles such as blankets, towels and cushion covers. They are listed in entry 72 of Annex XVII and include substances such as formaldehyde, heavy metals, and benzenes.

The REACH regulation is scheduled for review in 2022. The evaluation will build on the findings of the previous evaluation from 2017 and examine key developments since then. It will cover effectiveness, efficiency, relevance, coherence and EU added value.

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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 are referred to as food contact materials (FCMs) and include HDHT products like kitchenware and tableware.

The European Food Contact Materials Regulation aims to ensure that these products do not release any substances in their composition 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.

The FCM legislation also contains specific directives for items made of plastic, recycled plastic, and ceramics. These directives set out rules for the composition of these FCMs, permitted substances and specific migration limits (SMLs).

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. Stricter limits are expected to be announced in 2020.

The results of the latest evaluation of the FCM Regulation were published in July 2020. The report states that despite the regulation’s overall positive impact, there is room for improvement as gaps in implementation and enforcement weaken its performance. The report will serve as input for a commission staff working document (SWD) on the evaluation, including ‘evidence-based conclusions and prioritisation of the areas that require action’.

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Timber Regulation

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

To comply with the EUTR, your European buyers have 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 Timber Regulation.

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 licences 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.

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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 and 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.

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Textile regulation

The European Textile Regulation 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 March 2020 the European Commission adopted the Circular Economy Action Plan, including the intention to launch a new Strategy for Textiles. The goal of this strategy is to strengthen competitiveness and innovation in the sector, boosting the European market for sustainable and circular textiles.

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Dangerous products resembling foodstuffs

Directive 89/357/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.

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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 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 (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 Policy 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.

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Waste Electrical and Electronic Equipment

The Waste of Electrical and Electronic Equipment (WEEE) Directive 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 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. In 2019, the updated RoHS 3 (EU 2015/863) added four new restricted substances to the list, all phthalates.

Tip:

  • Study the WEEE and RoHS directives if you produce electric products, such as lighting.

Liability for defective products

The Product Liability Directive 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 February 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.

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Ban on single-use plastics

In 2019, the European Council adopted the Single-Use Plastics Directive. The 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. These products, including disposable plastic cutlery, will be banned by 2021.

Several European countries are already rolling out their national legislation on this topic. For example, in Germany a ban on the sale of single-use cutlery will come into force on 3 July 2021. France already banned single-use plastic plates, cups and cotton buds in 2020, and straws and cutlery in January 2021. 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 European strategy for plastics in a circular economy will transform the way plastic products are designed, used, produced and recycled in the European Union.

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Europe has specific packaging and packaging waste legislation. This EU Directive 2015/720 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.

Europe also has requirements for wood packaging materials (WPM) 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 6 mm thick or thinner;
  • 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. 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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2. What additional requirements do buyers often have?

Sustainability

Social and environmental sustainability make your products stand out on the European market. 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. Buyers appreciate a strong story to create an emotional connection with their customers.

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 has been 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.

You can read up on options in sustainability by looking into standards such as ISO 14001 and SA 8000. ISO 14001 sets out a framework for setting up an effective environmental management system. SA 8000 focuses on the fair treatment of workers, measuring social performance in eight areas. However, only niche market buyers demand compliance with these standards.

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

The new Circular Economy Action Plan aims to make sustainable products the European norm. An impressive 83% of citizens agree that European legislation is needed to protect the environment. The Commission plans to propose legislation on Sustainable Product Policy, to ensure that products are designed to last longer, are easier to reuse, repair and recycle, and incorporate recycled instead of primary raw material wherever possible. It will also restrict single use, tackle the early failure of products and ban the destruction of unsold durable goods.

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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 an EAN or barcode on the product label. Labelling should be in English, unless your buyer indicates otherwise.

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.

Tips:

  • Ask your buyer for their specific labelling and packaging requirements.
  • See Packaging Europe for the latest packaging developments, with regular news articles about biodegradable packaging.
  • For more information on packaging your products, see our seven tips to organise your export. This study also discusses topics such as delivery and payment terms.

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 your production process is labour intensive, fair trade certification can give you a competitive advantage. Common fair-trade certification schemes are issued by the World Fair Trade Organisation (WFTO) 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.
  • Determine which certification programme would be the best fit for you and apply for it if you can.
  • If certification is not feasible, work according to fair trade principles without being officially guaranteed or certified. Carefully document your company processes so you can support your claim.

Certification for wooden products

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. The FSC label 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. To manufacture FSC-certified products, you need chain of custody certification.

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Sustainable 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 by looking at the use of environmentally friendly chemical options. The label is only awarded to products with the lowest environmental impact in a product range.
  • The voluntary Nordic Swan eco-label is used for textile products in Sweden, Norway, Finland, Denmark and Iceland.

Tips:

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

Certification ethical carpets

There are several certification programmes that are specifically focused on the carpet industry:

  • GoodWeave (formerly known as Rugmark) works to end child labour in South Asia’s carpet sector. The organisation is also implementing a pilot project in India’s general home textile industry.
  • STEP is a label for fair trade handmade carpets produced in Afghanistan, India, Iran, Nepal, Pakistan, and Turkey. It focuses on good working and living conditions, fair wages, eco-friendly production and the prohibition of child labour.
  • Care & Fair is an initiative of the European carpet trade. It aims to combat illegal child labour in India and Pakistan and improve the situation of carpet weaving families in those countries.

Tips:

  • Determine which certification programme would be the best fit for you and apply if you can.
  • 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.
  • Consult the ITC Sustainability Map for a full overview of certification schemes in the sector.

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

Please review our market information disclaimer.

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21 January 2021