What are the requirements for apparel to enter the European market?

If you want to export apparel to the European market, you need to comply with several requirements. This report will help you understand what the most important mandatory and voluntary requirements are for the European market. You will also learn how you can ensure compliance with these requirements, and how you can use compliance to help your business.

1. What are mandatory requirements for apparel?

There are many legal requirements for exporting apparel to Europe, including those concerning product safety, the use of chemicals (REACH), quality and labelling. Check the EU Access2Markets online helpdesk for an overview. Additionally, many buyers have created non-negotiable terms and conditions for their suppliers. Although meeting these requirements is not required by law, they are still mandatory.

Follow these steps to ensure that your product complies with the relevant legal requirements:

1. Make sure your product complies with the EU’s General Product Safety Directive (GPSD: 2001/95/EC). If your buyer supplied the product design, it is their responsibility to guarantee it is legally safe for consumers to use.
2. Make sure you comply with the EU’s REACH Regulation. This restricts the use of chemicals in apparel and trims, including certain Azo-dyes; flame retardants; waterproofing and stain-repelling chemicals and nickel.
3. Ask your buyer if they use a Restricted Substances List (RSL). These are often inspired by the guideline on safe chemicals use from the Zero Discharge of Hazardous Chemicals (ZDHC) foundation. Download the ZDHC Conformance Guidance here.
4. Specify the material content of every apparel item that you export to the EU, in accordance with EU Regulation 1007/2011. Check the EU Access2Markets online helpdesk on how to do it. Fibres which collectively account for up to 15% of the total weight, may be designated by the term ‘other fibres’.
5. Do not violate any Intellectual Property (IP) rights and do not copy or share designs with other buyers. If your buyer provides the design, they will be liable in case the item is found to violate a property right.

Special requirements for children’s wear

The EU has a specific standard for the safety of children’s clothing and babywear. This standard contains requirements to ensure that cords and drawstrings are placed safely on apparel for babies and children up to 14 years old. This is to avoid strangulation and choking hazards.

Figure 1: Every item of apparel exported to the EU must meet legal requirements. Some categories, such as children’s wear, have specific legal requirements

Source: Photo by Michael Podger on Unsplash

Flammability

The EU has no specific legal requirements regarding apparel flammability, but several individual countries do, including the UK, Ireland, The Netherlands and Switzerland (in German). The EU has a standard concerning the burning behaviour of children’s nightwear (pdf), which helps in complying with the GPSD.

CE marking

If you want to export personal protective equipment (PPE) to the EU, for example, safety garments or gloves, you have to comply with specific EU safety standards for the design, manufacturing, material use, testing and user instructions concerning PPE. You are obliged to affix CE marking to PPE as a visible indication that your product conforms with the PPE safety requirements.

Biocides

If you add biocides to textiles to protect humans, animals, materials or articles against harmful organisms, such as pests or bacteria, you have to comply with the EU’s Biocidal Product Regulations (BPR) (pdf) as well as REACH (see above).

CITES

The use of endangered species of animals and plants or parts thereof in your product is restricted by the EU wildlife regulatory measures EC 338/97. This regulation is based on the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Some species of animals and plants are excluded from use in apparel altogether, so you cannot use them in your products. Others are subjected to severe importing restrictions.

Watch this video by Compliance Gate for an overview of EU regulations for exporting apparel and textiles to Europe.

Non-legal mandatory requirements

Besides the legal requirements mentioned above, you may be confronted with non-negotiable terms and conditions that buyers have created for dealing with suppliers. Such requirements are non-legal, but still mandatory. Examples are packing instructions and payment conditions.

Corporate social responsibility

Many buyers in Europe are increasing their demands regarding corporate social responsibility (CSR). The minimum requirement is that you open your factory for inspection by the buyer. You also have to follow a code of conduct which states that you comply with local laws. In addition, buyers may require you to have specific certifications concerning fair and sustainable production and social requirements.

Northern European countries the strictest on CSR

Companies from Northwestern Europe are considered to have the highest standards on CSR and quality. German and Scandinavian companies are well known for being very strict on working conditions and living wage. Most companies in Germany and France will also demand relatively rigorous testing for REACH compliancy and product quality. Companies in the UK tend to be a bit more lenient, with the Netherlands and Belgium somewhere in between.

The future of non-legal mandatory requirements

Within the next three years, expect buyers to require you to: trace the origins of your materials; use more recycled or regenerated materials; reduce your carbon footprint and chemical use (or select suppliers that do so); measure the environmental impact of your production process, and ensure a living wage and safe working environment for your employees.

Social compliance, transparency, recycling and reducing greenhouse gas emissions are top priorities for both the EU and national governments. For instance, the EU’s new Corporate Sustainability Reporting Directive (CSRD) will require all large European companies from 2023 onward to disclose how they manage social and environmental challenges. Under a newly proposed anti-deforestation law, companies that sell leather to the EU will need to have a fully transparent supply chain, verifying exactly on which land the cattle was raised.

Regarding the circular economy, the EU is set to introduce new legal measures to increase circularity in textiles, including new directives concerning durability of textile products and a ‘right to repair’. The EU is also considering the introduction of an EU-wide EPR for apparel (extended producer responsibility). This would make companies responsible for the way their products are disposed of, recycled or repaired. Some countries, such as the Netherlands, have set up national EPR schemes.

To reduce global carbon emissions the EU is currently considering a Carbon Border Adjustment Mechanism, also called a ‘carbon border tax’. This is effectively an import duty based on the amount of carbon that was emitted during production.

Table 1: An overview of social and environmental standards popular in the European market

Name of standard	Logo	Type	Cost for manufacturers	Most used in European end markets	Further information on getting certification
Amfori BSCI		Social	External audit costs (variable)	Germany, France, The Netherlands	Available from buyers. Amfori has a list of organisations that can perform an audit.
SA8000®		Social	External audit costs (variable)	Germany, France, The Netherlands, Italy, Spain	Check the SA8000 certification process here
WRAP		Social	€1,030 registration fee + external audit costs (variable)	UK, Germany	Check the WRAP certification process here
Sedex		Social, environmental	€118/year/per site + external audit costs (variable)	Germany, France, UK, The Netherlands	Check the Sedex certification process here
Fair Wear		Social	Membership is not open to factories (yet)	Germany, Sweden, The Netherlands, Italy	Check which brands are members
B-Corp		Social, environmental	€865/year minimum	Germany, UK, The Netherlands	Check the B-Corp certification process here
OEKO-TEX® STeP		Social, environmental	Certification fee + external audit costs (variable)	Germany, France, UK, The Netherlands	Check the OEKO-TEX® STeP application process here
BCI		Environmental	€2,000/year minimum membership fee	Germany, France, UK, The Netherlands	Check the BCI membership process here
GOTS		Social, environmental	€150/year minimum + external audit costs (variable)	Germany, France, UK, The Netherlands	GOTS has a list of organisations that can perform an audit
ZDHC		Environmental	Cost of a third-party indicator of conformance with the ZDHC MRSL (variable)	Germany, France, UK, The Netherlands	The ZDHC has a guide that outlines the requirements for indicating ZDHC MRSL conformance

Non-legal requirements for base materials

The following standards and certifications are the most common in the European market for base materials:

• Better Cotton Initiative (BCI). A multi-stakeholder initiative with 1,200 members that helps to improve cotton growing conditions globally. Read more about it in the CBI study on Sustainable cotton.
• Global Recycled Standard (GRS). Product standard that incorporates recycled material verification, including social and environmental responsibility criteria, as well as chemical management. Read more about it in the CBI study on Recycled fashion.
• Responsible Down Standard (RDS) and RWS (Responsible Wool Standard). Third-party verified standards that guarantee animal welfare criteria have been met for animals that are kept for their down or wool, including respect for the Five Freedoms. If you use merino, buyers may require that you use only non-mulesing wool. The use of Angora and Mohair is already banned by many European brands due to animal cruelty concerns.

Other possible requirements regarding base materials:

• Use of organic cotton. This is cotton grown without the use of GMO’s (‘genetically modified organisms’) and synthetic chemicals. Read more about organic cotton in the CBI study on Sustainable cotton.
• Regenagri is a new standard developed by Control Union for regenerative (cotton) farming.
• Use of fabrics blended with eco-friendly fibres, such as hemp; regenerated fibres such as Tencel®, Modal® and Refibra™ (by yarn manufacturer Lenzing); or other sustainable fibres such as Recover, REPREVE or Infinited Fiber; or even with innovative bio-based polymer fibres such as PLA, milk, seaweed and soy.
• Saving water during production by dyeing fabrics with new techniques (using CO2 instead of water) such as Dyecoo or Kitotex®.
• Fabrics dyed with only natural ingredients such as Rubia, Fibre Bio or Greendyes or dyestuffs made from recycled materials such as Recycrom.

Non-legal requirements for textile processing and fabrics

The following standards and certifications may be requested to guarantee that textiles and fabrics have been produced with respect for the environment. Examples of European brands and retailers using these standards are: Peek & Cloppenburg (Oekotex), Zalando (EU Ecolabel), C&A (GOTS) and G-Star (Bluesign). Other companies use private standards, such as Inditex’s Join Life standard for recycled materials and H&M’s private recycling programme.

• Standard 100 by Oekotex – Label that ensures consumers that all materials used in a garment are tested for harmful substances.
• EU Ecolabel – Label that ensures consumers that textiles are made using less harmful substances, energy and water.
• GOTS (Global Organic Textile Standard) – This standard covers everything from the production to the distribution of textiles made from at least 70% organic natural fibres.
• Bluesign – The Bluesign System reduces impact on people and the environment in the entire textile supply chain, based on input stream management.

Non-legal requirements for garment manufacturing

Several standards and certifications in the textile industry aim to encourage fair treatment of workers in garment manufacturing. Here are some of the most requested standards by European buyers.

• BSCI (Business Social Compliance Initiative). For many European buyers, BSCI is the most popular and often only certification they will require. It is a supply chain management system that helps manufacturers drive social compliance.
• Especially in the UK, the following social and environmental standards are popular: WRAP (Worldwide Responsible Accredited Production), SEDEX and ETI (Ethical Trade Initiative).
• Other popular standards that guarantee apparel are made with respect for workers’ rights are SA8000, ISO 26000, FWF (Fair Wear Foundation) and Fairtrade. A popular environmental management standard is ISO 14001.

Packaging requirements

In most cases, your buyer will give you instructions on how to package the order, in a manual (see below). If you agree that your buyer will clear customs in the country of import, it is their responsibility to make sure the instructions comply with EU import procedures.

Payment terms

For a first-time order, European buyers may agree with a down payment (for example, 30%). They will pay the rest (70%) after the order is completed. The safest payment method for you as a manufacturer is the LC (Letter of Credit). An LC obligates a buyer’s bank to pay the supplier when the conditions that both parties have agreed are met. However, many buyers no longer favour LC payments because these block their cash flow. Be aware that LCs do not offer financial protection against bankruptcies.

For further orders, most European buyers will ask for a TT (Telegraphic Transfer) after 30, 60, 90 or sometimes even 120 days. This means you as a manufacturer will finish the production and hand over the shipment to the buyer, including the original documents, before payment is due. The payment will be made after the number of days that you have agreed with the buyer. This is a risky payment agreement because you take full financial risk.

The buyer manual

When you do business with a European buyer for the first time, they will typically give you a contract and/or a manual to sign. By signing the contract, you confirm that you will comply with all the listed requirements. This means you will be held accountable in case of a problem after the delivery of an order. Complying with REACH can be especially challenging. Most European buyers will not ask for expensive testing for small orders, but if illegal chemicals are discovered after delivery, you will bear all expenses involved.

Acceptable quality limit

To guarantee product quality, your buyer may set an AQL (acceptable quality limit) for you. This refers to the quality level that is the worst tolerable. For instance, AQL 2.5 means that your buyer will reject a batch if more than 2.5% of the whole order quantity over several production runs is defective.

Customers also set the product quality standard defining the level of physical standards, such as:

• pilling
• colour fastness
• tear force
• shrinkage

2. What additional requirements and certifications do buyers ask for in the apparel sector?

In addition to mandatory (legal) requirements, there are many services that buyers implicitly expect or at least highly appreciate, if you want to do business with them.

Product design and development

Most buyers have their own design team and don’t solely rely on the collections that factories present to them. Still, having your own ideas on product design and development will be highly appreciated. Buyers are always looking for special designs, materials or production methods that may help them stand out in the market.

For instance, consider using: on-trend (sustainable) materials; special finishes such as coatings and prints; stretch fabrics for extra comfort; special property fabrics (for instance, with soil-resistant, breathing, waterproof, anti-bacterial or UV-protective properties); quick-drying, easy iron and crease-resistant fabrics; stay dark fabrics (colour fastness); and garment dyeing during production to increase flexibility.

Garment care preferences

When selecting base materials, keep in mind that most consumers in Europe prefer easy to care for, machine-washable garments. Try to avoid dry-clean-only products, unless you have a specific agreement about this with your buyer.

Communication

Smooth communication is an implicit requirement that all buyers have. Be prepared to follow these basic rules if you want to successfully do business with European buyers:

• Always reply to every email within 24 hours. Even if it is just to confirm that you have received the email and to say that you will provide a proper reply later.
• If you encounter a problem with a production order, immediately notify the customer and try to offer a solution.
• Create a T&A (time and arrival) for every order and share it with your buyer. This file will help you to manage expectations, monitor progress and is the best guarantee for on-time delivery.
• Create a communication file of every order so you build up a case history. This file is your backup in case of a complaint.
• Tools like 3D prototyping, such as CLO3d, can help you speed up the approval process.

Speed to market

Fashion companies like Zara have proven that having the right product at the right time is at least as important as being the cheapest. Sales in Europe were already under increased pressure, even before Covid-19. Now buyers will try even harder to minimise stock and order as late as possible. Manufacturing and delivering fast is an important implicit requirement, just like flexibility in order quantities (see below).

Within the next three years, you should expect stricter requirements on order quantities and delivery times, since European brands and retailers are struggling to attract and hold the attention of consumers. Instead of four or even 12 collections a year, ever more retailers are releasing as many as one micro collection per week, year-round. Ultrafast fashion online retailers increasingly try to mimic trends that can pop up any moment during the fashion season.

There are different ways to optimise manufacturing:

• Keep stock materials to increase flexibility. Source from fabric suppliers that work with stock yarns and that can help you reduce manufacturing time.
• Confirm lab dips (a small swatch of fabric to define colour and its recipe before it goes for bulk dyeing), trims and style before the final order is placed.
• Ask your buyers for a seasonal sales forecast and regular sales updates, to help plan your production capacity.
• Read the CBI report on trends in the European apparel market to learn about the growing fast-fashion industry in Europe.

Flexibility

Many factories focus only on getting convenient orders: simple styles, large quantities and long delivery times. However, if you want to start a business relationship with a European buyer, be prepared to accept complicated orders first. Buyers will want to test your factory before giving you big, easy orders. Make sure at the start that a buyer will not continue to place only difficult orders with you and convenient orders elsewhere.

Expect a European buyer to require (for their first order):

• high-quality material and impeccable workmanship;
• order quantities below your normal minimum order quantity (MOQ);
• a price level that is lower than you normally would accept for small quantity orders.

Factories in different GSP countries

When all other selling points are equal, European buyers will prefer manufacturers that operate in countries under the EU’s Generalised Scheme of Preferences (GSP). The scheme removes import duties from apparel exported to the EU from 72 countries worldwide, giving buyers a substantial financial advantage.

Examples of successful exporters to the EU

The following garment manufacturers are good examples of companies that have successfully put the additional requirements mentioned above into practice.

• Arvind India is a vertically integrated fabric and apparel manufacturer specialised in wovens. The company offers anything from fabrics to design to CMT. It has an extensive paragraph on sustainability on its website, including KPI’s on materials, workers and production processes.
• Kanoria in Ethiopia is set up as an eco-friendly denim factory. The company holds certificates from Cotton made in Africa (CmiA) and standard 100 by OEKO-TEX®.
• Crossing in Morocco is a nice example of a modern factory offering graphic design, cutting, sewing, washing, printing and embroidery. The company offers BCI, organic or recycled fabric, 3D pictures and video of samples for pattern checking.

3. What are the requirements for apparel niche markets?

Niche markets are markets that have a specific target group with special requirements, such as low order quantities, specific dying processes, tech add-ons and special fabrics. Because of this, most mainstream providers don’t service this group. However, as sales in the mainstream fashion market are continuously under pressure, ever more European buyers are targeting niche markets to achieve growth. So can you.

When entering the following high-opportunity niche markets, expect very specific buyer requirements:

• Apparel made from recycled materials. Yarns and fabrics made from recycled cuttings and post-consumer waste are becoming increasingly popular — and not just with brands and retailers that promote themselves as sustainable. The most asked-for standards here are the Textile Exchange’s Recycled Claim Standard and Global Recycled Standard. Read the CBI study on Recycled Fashion.
• Vegan apparel. In the wake of a rising demand for vegan food in Europe, apparel made without using materials from animal origin is a small but fast-growing niche. If you use plant-based or synthetic alternatives to materials such as leather or wool, you can apply for the PETA-Approved Vegan certification. The PETA website offers a database with more than 1,000 PETA-Approved Vegan brands. Read the CBI report on sustainable apparel for information on this niche.
• Children’s wear. Use of organic cotton is especially popular in baby and children’s wear, as many parents are willing to pay extra for materials that are grown without the use of chemicals. GOTS is a popular standard for children’s wear. Remember that children’s wear also needs to comply with EU Regulation regarding the safe attachment of drawstrings and accessories (see mandatory requirements above). Read the CBI report on Children’s wear.
• Work wear. This is a niche with several sub-niches, including apparel that protects against rain and foul weather, against liquid chemicals, against fire and flames, against the thermal hazards of an electric arc and high-visibility apparel. Check the EU Regulation on PPE and its many different related norms and standards (pdf). Read the CBI report on workwear.
• Corporate wear. Many large organisations like banks and hotels tender their corporate wear. These are usually three-year contracts in which a supplier needs to guarantee the quality and colour consistency of deliveries. Expect no specific legal requirements but high demands regarding stock keeping, flexibility, printing, colour fastness and fabric quality.
• High-performance wear. Companies developing high-performance wear try to create individual USPs on their garments and collection that will help athletes with their performance. Expect no specific legal requirements, but high demands regarding breathability, durability (abrasion, adhesion, colour fastness) and water resistance. Read the CBI report on sportswear for more information on this niche.
• Adaptive apparel. The cohort of elderly people in Europe is growing and so is this niche. People with certain disabilities or medical conditions often cannot wear regular clothing. Adaptive apparel is constructed in a way that the target group can dress and undress without or with only minimum help. This apparel can also have technical, supportive, moisture control or anti-bacterial functions. Expect no specific legal requirements, but high demands regarding technical textiles, sizing and shape. Read the CBI report on Adaptive apparel.
• Swimwear. UV-protective swimwear is growing in popularity in Europe as consumers become more aware of the risk of sunburn. Read the CBI report on swimwear.
• Leather fashion. To avoid the risk of Chromium VI in leather apparel and accessories, ever more buyers are requiring chrome-free leather tanning. This can be either vegetable tanned or wet-white tanned leather. The most popular certification for leather is Leather Working Group. Two new standards are the Sustainable Leather Foundation (SLF) and Textile Exchange’s Leather Impact Accelerator (LIA). Read the CBI study on leather fashion accessories.
• Modest wear. Many people with an Islamic background prefer ‘modest’ styles. In Europe, this target group is underserved but growing. Source for materials that obscure the female silhouette, so no fabrics that are too stretchy or too thin. For specific requirements, read the CBI study on Islamic wear or this article by fashion consultancy Edited about the rise of modest fashion.
• Special sizes. Following the ‘body acceptance’ trend, ever more European fashion brands have started to include silhouettes in their size range for specific body types, such as plus size, petit, tall and maternity fashion.
• Made-to-order fashion is a growing niche, pioneered by companies such as Nike, Spreadshirt, Unspun and Munroe Tailoring, offering consumers highly personalised apparel items. This requires from manufacturers ultra-high flexibility and fast delivery, achieved only by a high level of digitalisation and automation. Read the CBI study about digitalisation of the apparel industry.

Further Reading

The CBI report ‘10 Tips for Finding European Buyers’ can help you with finding interesting prospects and how to approach them.

The CBI study ‘10 Tips for Doing Business with European Buyers’ provides tips on how to successfully approach a potential buyer and develop a long-lasting business relationship with them.

Frans Tilstra and Giovanni Beatrice for FT Journalistiek carried out this study on behalf of CBI.

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