Textile certification for clothing and footwear

The same short list comes back in every market. Under REACH Annex XVII, entry 43 bans azo dyes that release any listed aromatic amine above 30 mg/kg, entry 27 caps nickel release from studs, zips and buttons at 0.5 µg/cm² per week, entry 47 limits chromium VI in leather to 3 mg/kg, and entry 72 (added by Regulation (EU) 2018/1513) sets 75 mg/kg for formaldehyde in clothing. Entry 51 caps four phthalates at 0.1 % in plasticised prints and coatings. The azo test itself is EN ISO 14362-1. TR CU 017/2011 runs a parallel list with formaldehyde limits by layer. The US has no general chemical list for adult clothing; CPSIA supplies one only for children's products, with total lead at 100 ppm.

Testing is per material and per colourway. A range of twelve styles in four colours may need far fewer tests than it appears, or far more, depending entirely on how many distinct fabrics, dyes and trims sit underneath. Get the material list right first. The budget follows from it.

In the EU, Regulation (EU) 1007/2011 fixes the fibre names you may use and requires the composition in the official language of the country of sale, using the names in its Annex I and nothing else: "Lycra" is a trademark, "elastane" is the fibre name. Footwear is labelled by component under Directive 94/11/EC: upper, lining and sock, outer sole. Care symbols are voluntary in the EU and compulsory in the US under 16 CFR Part 423. Country of origin is a customs matter that the label still has to get right.

Labels are printed late and cheaply, and that is exactly why they hold shipments. Send the artwork for review before the label order goes out.

Three things change. EN 14682 restricts cords and drawstrings on clothing for children up to 14: no functional cords at all in the hood and neck area below age seven, and length and free-end limits above it. Small parts and flammability are assessed, and the chemical limits tighten. In the Eurasian Economic Union children's clothing leaves TR CU 017/2011 altogether and sits under TR CU 007/2011, which takes first-layer garments and anything for children under one year into certification; the second and third layers are declared.

The document changes with it. A declaration is your own signature on your own evidence. A certificate means an accredited body listed in the EAEU unified register tests its own samples and signs next to you. Treating the children's range as a smaller version of the adult range misses both the tests and the document.

TR CU 017/2011 covers 39 positions of light-industry products for adults, and five of them are certification-only. The line is skin contact. First-layer goods, meaning underwear, hosiery, bed linen and anything else worn directly on the skin, are certified. The second and third layers get the same declaration, so a lined coat and the jacket under it take one route. Footwear and leather goods are declared.

Footwear adds chromium VI in leather, the substance most often failed in this group, and solvent residues from adhesives. Safety footwear is not footwear for this purpose. It is personal protective equipment under Regulation (EU) 2016/425, tested to EN ISO 20345 and certified by a notified body, and it belongs in a separate project with its own timeline.

16 CFR Part 1610 classifies clothing textiles by burn time and exempts plain-surface fabrics of 88.2 g/m² or heavier and fabrics made entirely of acrylic, modacrylic, nylon, olefin, polyester or wool, which removes most adult garments from testing. Children's sleepwear has its own standards, 16 CFR 1615 and 1616. CPSIA then adds, for anything designed for children twelve and under, third-party testing at a CPSC-accepted laboratory, a Children's Product Certificate and a tracking label. Adult clothing needs none of that.