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Dos and Don’ts of Labelling


Set out below a brief reminder of rules to be taken into account for items for sale in the UK.  

Fabric type.
 Virtually all textile products must carry a label  indicating the fibre content either on the item or on a removable label (e.g. swing ticket) or  the packaging.   The rules cover products which contain at least 80% by weight of textile fibres.  There are a few specific exceptions to this where smaller parts of an item e.g. linings of gloves must also be labelled. There is also a rather bizarre list of exempt items which includes items such as gaiters and tobacco pouches.   The label must describe the fabric type using one or more of the list of fibres set out in the Regulations for example, wool, cashmere, etc.  Use of designated fibre descriptions e.g. “silky”  or “cotton feel” should not be used excerpt in relation to those fabrics. Decorative matter (e.g. embroidery) which makes up 7% or less of the products is excluded from the indication of fibre content.   Further guidance on the fibre labellingcan be found at: www.tradingstandards.gov.uk 

Do I have to state where the goods are made? There is no requirement that goods sold in the UK bear a “made in” label indicating the country of origin.  This contrasts with the position in some other countries e.g. US where origin labelling is compulsory.  The only UK exception is where the products are branded with images which suggest that they are produced in the UK (e.g. a tee-shirt with a Union Jack motif). In such cases the goods should state country of origin if outside the UK.  Where the country of origin is included it would be sensible to follow the guidance issue by US customs on this issue which provides that the label must state where the most significant part of the manufacturing took place, or where there are several processes of importance, the place where the last of those took place. A proposal for a “made in Europe “ label is currently under discussion in the European parliament. 

What about use of terms such as  “hand made”? All labelling must comply with the Trade Descriptions Act which makes it a criminal offence to apply a false description to any goods, which includes a false description of how they are made.  Customers/wholesalers will also have the right to reject goods that do not comply with description and purchasers could sue for the extra cost of obtaining goods that do comply with the description. There is currently no legislation in the UK which cover the use of words such as “hand made” and “eco-friendly” . If there is a premium price attached to a particular quality or description you should assess whether your products genuinely satisfy that requirement.   There has been some recent discussion within the European Parliament  about introducing eco/ethical labels for clothing with specific requirements and certification procedures ( similar to those for organic food). However due to the costs of setting up and monitoring such a scheme these are likely to start as being voluntary.   

Nightwear and Footwear – special rules There are special rules that govern flammability performance of nightwear which include detailed labelling requirements. For a useful guide see:  www.dti.gov.uk/ccp/topics1/guide/nightwearguide.pdf. Footwear must be labelled with indications of the main material from which the upper, lining and outsole are made. For further details see: www.tradingstandards.gov.uk 

Brand names  If you are including a brand or company name on your labels you should check that the name and logo does not infringe the rights of someone who has registered or is using the same or similar brand for clothing. Where goods are exported you will need to check in the country where the goods will be sold. The increasing importance and value attached to brands is reflected by more claims in this area including two recent cases concerning casual clothing brands “Animal” and “Reef”.  

Exporting overseas  

The above comments relate to products which are put on to the market in the UK.  If you are exporting your products outside the UK or believe that a wholesaler to whom you are selling will be exporting, you need to check the labelling requirements in the destination countries. 

Nick Fenner

Fladgate Fielder



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