Textile Labelling and Origin Rules for EU and US Apparel Imports

A garment can pass every quality inspection and still be refused at import because a label is wrong. Fibre composition, care instructions and country of origin are all regulated separately in the EU and the US, and the origin rules in particular are counter-intuitive for buyers who assume the country where a garment was sewn is always its origin.

European Union: Regulation (EU) 1007/2011

The Textile Labelling Regulation requires that any textile product placed on the EU market carries a label stating its fibre composition in descending order by weight, using only the fibre names listed in the regulation. "100% cotton" is a permitted designation; "cotton rich" is not. Where a product is 100 percent of one fibre, the label may say "100%", "pure" or "all".

There is a permitted tolerance: up to 2 percent of the total weight may be foreign fibres where this is technically justified by the manufacturing process, and 5 percent where it results from fibre recycling. Non-textile parts of animal origin must be declared. The label must be durable, legible and in the official language of the member state where the product is sold. Care symbols follow a separate framework and, while not harmonised in the same regulation, must be consistent with ISO 3758 in practice.

United States: the Textile and Wool Acts and FTC rules

The Textile Fiber Products Identification Act and the FTC Textile, Wool and Fur Acts require a label disclosing generic fibre names in descending order by weight, the percentage of each fibre to the nearest whole number, the registered identification number or name of the manufacturer or marketer, and the country where the product was processed or manufactured.

The RN number is the most frequently missed item. Either the US-based importer RN, or the full legal name of the foreign manufacturer, must appear on the label. A foreign factory name alone is permitted if no RN is available, but this must be the legal entity name, not a brand name. Care labelling is separately regulated under the Care Labeling Rule, 16 CFR 423, which requires washing or dry-cleaning instructions and a warning where a method would harm the product.

Country of origin: 19 CFR 134 and the knit-to-shape rule

For textiles, US Customs applies specific tariff shift and process rules rather than a general substantial transformation test. The rule that catches most apparel importers is the knit-to-shape rule: most knitted garments take their origin from the country where the fabric pieces were knitted to shape, not where they were assembled. A sweater whose panels were knitted in China and sewn in another country is still a product of China for marking and duty purposes.

For cut-and-sewn woven garments, the cut generally confers origin: the country where the fabric was cut to shape is the country of origin. Dyeing, printing or other finishing alone does not confer origin. Marking must be on the inside centre of the neck midway between the shoulder seams, or on the inside of a waistband, and must be conspicuous and legible to an ultimate purchaser.

EU non-preferential origin

The EU applies its own non-preferential origin rules under the Union Customs Code. For most apparel, origin is conferred by the last substantial transformation, and for many garment categories this is weaving or knitting combined with making-up rather than making-up alone. Preferential origin under a free trade agreement or the GSP scheme is determined separately under the relevant protocol and is evidenced by a statement on origin or a Form A certificate — this is the document that reduces or removes duty, and it is not the same as the made-in label.

A pre-shipment label checklist

• Fibre composition in descending order, using only permitted fibre names, with the correct tolerance applied.
• Country of origin determined by the correct rule for the construction — knit-to-shape, cut, or substantial transformation.
• RN number or the full legal name of the manufacturer or marketer for US shipments.
• Care instructions consistent with the actual tested performance of the garment, not a generic template.
• Label language matching each destination member state for EU shipments.
• Label placement at the inside centre neck or waistband, and durability through the expected life of the garment.
• Childrens products: CPSIA tracking label permanently affixed, plus a childrens product certificate for US imports.