Eurofins Softlines & Leather Monthly Bulletin (November 2022)

EUROPE

Forum enforcement projects 2023-2025 on imported products

On 16 November 2022, ECHA announced the next REACH enforcement project. The new REACH-EN-Force will aim to control imports of substances, mixtures and articles. It will investigate how companies fulfil the registration, authorisation and restriction obligations for products and chemicals they import from outside the EU. It will be implemented in 2023-2025 with the cooperation of national customs authorities and REACH inspectors.

This project arose as a result of the 2019 pilot project where the results indicated that 23% of inspected products were non-compliant with requirements set by EU law and further controls are necessary.

For more information, consult the ECHA’s website here.

Standards updates

The following table summarises the most recent standard updates and upcoming dates of withdrawal (non-exhaustive):

(*) Date of withdrawal: the latest date by which national standards conflicting with an EN (and HD for CENELEC) have to be withdrawn.

CEN
Reference	Title	Date of withdrawal (*)	Supersedes
EN 17528:2022	Clothing - Physiological effects - Measurement of water vapour resistance by means of a sweating manikin	30-04-2023
EN ISO 14389:2022	Textiles - Determination of the phthalate content - Tetrahydrofuran method (ISO 14389:2022)	30-04-2023	EN ISO 14389:2014
EN ISO 11644:2022	Leather - Test for adhesion of finish (ISO 11644:2022)	31-05-2023	EN ISO 11644:2009
EN ISO 7906:2022	Leather - Tests for colourfastness - General principles of testing (ISO 7906:2022)	31-05-2023
EN 15987:2022	Leather - Terminology - Key definitions for the leather trade	30-04-2023	EN 15987:2015
EN ISO 14087:2022	Leather - Physical and mechanical tests - Determination of bending force (ISO 14087:2022)	30-04-2023	EN ISO 14087:2011

FRANCE

Mandatory environmental information in consumer products

A product’s environment and characteristics are relevant information to make available for consumers. It will be mandatory to do so for all consumer products placed on the French market from 2023.

According to Decree 2022-748 of 29 April 2022 relating to consumer information on the environmental qualities and characteristics of waste-generating products, this obligation will come into force gradually.

Below is a summary table with the main dates and turnover of the companies:

Environmental characteristics of waste-generating products
Date	For producers, importers and any other marketers
	Annual turnover	Responsible annually
From 1 January 2023	>50 million euros	>25,000 units of the products
	Not applicable to products for which the last unit is placed on the market between 1 January and 31 March 2023.
From 1 January 2024	> 20 million euros	>10,000 units of the products
From 1 January 2025	> 10 million euros	>10,000 units of the products

This information shall be available in a dematerialised format, accessible free of charge at the time of purchase and reusable so as to allow aggregation.

The producer or importer shall make the information available on a dedicated website or internet page comprising a sheet entitled “product sheet relating to the qualities and environmental characteristics” so as to allow direct research and queries on the internet as well as the extraction of data for the possible automated processing of information.

For more information, consult Ministry of Energy Transition’s website here and Frequently Asked Questions (FAQ)

Environmental information in textiles

On 30 September 2022, the experiment related to environmental labels on textiles was closed. According to Article 2 of the "Climate and resilience" law (law no. 2021-1104 of 22 August 2021 on the fight against climate change and strengthening resilience to its effects), which cancels and replaces article 15 of the law "Anti-waste and circular economy - AGEC" (law n° 2020-105 of 10 February 2021), requests an experiment in environmental labelling, in particular in the clothing and footwear sector. 

Article 2 of the Climate and Resilience Law specifies that environmental labelling must provide information on “the environmental impact of the goods and services considered over their entire life cycle. It must consider:

Greenhouse gas emissions
Damage to biodiversity
Consumption of water and other natural resources.

The law stipulates that the experiment will be followed by an assessment and a decree making environmental labelling mandatory in June 2023. At the moment, Environmental labelling is not mandatory in France. 

Below, you will find proposals and examples that different textile collectives, entities and some companies are using or have presented in the French market on their own initiative because of this law.

- ADEME

This is an A, B, C, D or E rating displayed on products or services, in-store or on the internet, calculated based on the entire life cycle of the product or service, according to a validated reference system.

- UIT

Environmental labelling takes the form of a three-part label covering:

The carbon footprint of the product and the overall environmental impact calculated from 12 environmental indicators, compared to the same product manufactured under average global conditions;
The traceability of the product, which includes the composition of eco-responsible materials and the countries involved in the various stages of the production of the material, spinning, weaving or knitting, dyeing and making; this box also includes the "Triman" indication, intended for the end of life of the product.
Product and brand labels & certifications.

- Traçabilite textile:

Environmental labelling covers:

Raw material origin
Traceability (The locations where the four main stages of manufacture of a textile article take place: SPINNING, WEAVING / KNITTING, ENNOBLING, CONFECTION)
The carbon performance of the manufacturing cycle
A space for brands to defend their supply chain and explain their choices, at their own discretion.
The organization guaranteeing the traceability of the product

For more information, consult the CEDEF’s website here.

NETHERLANDS

Repealing of formaldehyde national requirements for textiles

On 13 April 2022, Decree of 7 April 2022, was published, repealing the Commodities Act Decree formaldehyde in textiles.

This decision is intended to implement EU legislation. By setting a maximum concentration limit for formaldehyde in textiles in Annex XVII to the REACH Regulation, there is no longer room for national regulation of formaldehyde in textiles.

This decree shall enter into force one day after the date of issue of the Official Gazette in which it is placed.

Miscellaneous technical publications relating to textiles

The latest publications in relation to textiles are summarised in the table below:

Date	Country/ Region	Entity	Publication
05/10/2022	Norway	Norwegian Consumer Authority	Guidance to the sustainable apparel coalition This guidance concerns traders’ use of environmental product claims in consumer-oriented marketing, based on the Higg Materials Sustainability Index owned by the Sustainable Apparel Coalition.
27/10/2022	Europe	Funding by the Horizon Europe research and innovation programme	T-REX Project (Textile Recycling Excellence) The project aims to contribute to understanding and identifying the infrastructure, technology and policies needed to encourage the growth of circular value chains in the textile industry. The partners will work towards developing a systematic approach to addressing the problem of textile waste, resource preservation and the reduction of the environmental footprint of the fashion industry.

Recent Prop 65 60-Day Notices - PFOA/PFOS

California Proposition 65 is the ‘Safe Drinking Water and Toxic Enforcement Act of 1986’, which has been effective for almost 30 years. Recently, there have been many new 60-day notices concerning Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA). Please see below Table 1 for the recent 60-day notices.

Table 1: 

Date	Chemical	Product	AG Number
30 September 2022	PFOA	Microfibre tablecloth	2022-02322
10 October 2022	PFOS	Jackets	2022-02404
10 October 2022	PFOA	Crib mattress pads	2022-02405
12 October 2022	PFOA	Fabric shower liners	2022-02441
12 October 2022	PFOA	Golf umbrellas	2022-02442
12 October 2022	PFOS	Comfort bath pillows	2022-02443
17 October 2022	PFOS	Bibs	2022-02498
17 October 2022	PFOS	Superbibs	2022-02499
24 October 2022	PFOS, PFOA	Waterproof rain jackets	2022-02565
8 November 2022	PFOA	Duffle bags	2022-02711
8 November 2022	PFOA	Jackets	2022-02712
8 November 2022	PFOA	Jackets	2022-02713
18 November 2022	PFOA, PFOS	Jackets	2022-02788

CHINA

China issues new and updated Product Standards

The Chinese Ministry of Industry and Information Technology has recently released various new and updated industry and national product standards. Please see Table 1 below:

Table 1: 

Category	Standard
Bag & Luggage	QB/T 5856-2022 Vacuum seal storage bag
Bag & Luggage	GB/T 41002-2022 Children’s cases and bags
Footwear	QB/T 1653-2022 Polyvinyl chloride (PVC) injection molded sandals and slipper HG/T 2019-2022 Black rain boots (shoes)
Textile & Apparel	FZ/T 44008-2022 Chemical filament cleaning wipes
	FZ/T 44009-2022 Tussah sleeping mat
	GB/T 41788-2022 Multifunctional knitted products
	GB/T 41902-2022 Nursing garments
	QB/T 1196-2022 Down and feather pillows and cushion
	QB/T 1195-2022 Down and feather sleeping bags
	QB/T 1193-2022 Down and feather quilt
	QB/T 2540-2022 Leather bracelet
	FZ/T 81007-2022 Casual wear
	FZ/T 81004-2022 Dress and Suit
	FZ/T 08002-2022 Textile products for newborn

PRODUCT RECALLS / ALERTS

Below you will find a monthly summary of product recalls and alerts in Europe (Source “Safety Gate (RAPEX)”) and the U.S. (Source “CPSC”).

Europe

Safety Gate (RAPEX) (European Commission Rapid Alert System for dangerous non-food products – Alerts reported by EU national authorities)

The following 34 alerts regarding textile & leather products were reported between week 43 and week 46 of 2022.

Type of Risk	Number of alerts	Notes
Chemicals	12	Women’s flat shoes The outer sole contains an excessive concentration of dibutyl phthalate (DBP). The product does not comply with REACH Regulation.
		Flip-flops The plastic material of the product contains an excessive concentration of dibutyl phthalate (DBP) and dibutyl phthalate (DBP). The product does not comply with REACH Regulation.
		Boots The product contains and excessive concentration of bis(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP). The product does not comply with REACH Regulation.
		Women’s shoes The outer sole of the shoes contains an excessive concentration of diisobutyl phthalate (DIBP), dibutyl phthalate (DBP) and bis(2-ethylhexyl) phthalate (DEPH). The product does not comply with REACH Regulation.
		Children's sandals The plastic material of the product contains diisobutyl phthalate (DIBP), dibutyl phthalate (DBP) and bis(2-ethylhexyl) phthalate (DEHP). The product does not comply with REACH Regulation.
Choking	10	Children's gloves The small decorative elements can easily be detached from the product. The product does not comply with the requirements of the General Product Safety Directive, nor with EN 71-1.
		Children's blouse The small decorative elements (pebbles) can easily be detached from the product. The product does not comply with the requirements of the General Product Safety Directive, nor with EN 71-1.
		Baby t-shirt and baby clothing set The small decorative elements (beads) can easily be detached from the product. The product does not comply with the requirements of the General Product Safety Directive, nor with EN 71-1.
Injuries	6	Children's and babies’ dress There are long functional cords in the waist area. The product does not comply with the requirements of General Product Safety Directive, nor with EN 14682.
		Children's sports outfit The product bears cords with free ends and toggles in the waist area. The product does not comply with the requirements of General Product Safety Directive, nor with EN 14682.
		Children's sweatpants The trousers have long functional cords to be tied at the waist area. The product does not comply with the requirements of the General Product Safety Directive nor with the European standard EN 14682.
Injuries, Strangulation	3	Babies' clothing set There are long functional cords with free ends in the upper chest area. The product does not comply with the requirements of General Product Safety Directive, nor with EN 14682.
		Children's outfit The product bears cords with free ends in the hood area and in the waist area. The product does not comply with the requirements of General Product Safety Directive, nor with EN 14682.
		Babies' jumpsuit There are long functional cords with free ends in the hood of the jumpsuit. The product does not comply with the requirements of General Product Safety Directive, nor with EN 14682.
Strangulation	3	Children's hat The product has functional cords with free ends at the neck area. The product does not comply with the requirements of the General Product Safety Directive, nor with the European standard EN 14682.
		Sleeping bag The sleeping bag bears long functional cords with free ends. The product does not comply with the requirements of the General Product Safety Directive nor with the European standard EN 16781.
		Children's rain jacket with hood The product has functional cords in hood. The product does not comply with the requirements of the General Product Safety Directive nor with the European standard EN 14682.

The OPSS issues Product Safety Alerts on the UK market. The following alerts regarding textile & leather products were reported between week 43 and week 46 of 2022.

2 recalls regarding textiles

Type of Risk	Number of alerts	Notes
Burn	1	Pyjama set The set fails to meet the flammability requirements of the Nightwear (Safety) Regulations 1985.
Strangulation	1	Costume Costumes were tested and failed; the mask included did not comply with EN71-1 due to, the length of the strap. The product has been identified as not suitable for children under 36 months.

U.S.

From 27 October 2022 to 17 November 2022, the CPSC (Consumer Product Safety Commission) published the following recalls: 2 recall of textile & leather products

Hazard	Number of alerts	Notes
Chemical	1	Footwear Prolonged and direct contact with the shoes’ upper material can expose the wearer to the chemicals benzidine and/or dimethoxybenzidine, which are toxic and can cause adverse health effects.
Puncture and laceration	1	Children’s pajamas Small metal wire pieces can be found in the pajamas, posing puncture and laceration hazards to young children.