# C_2023349EN.01002401.xml

| 29.9.2023 | EN | Official Journal of the European Union | C 349/24 |
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29.9.2023

EN

Official Journal of the European Union

C 349/24

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Opinion of the European Economic and Social Committee on ‘Revision of the Textile Labelling Regulation’

(Exploratory opinion)

(2023/C 349/05)

| Rapporteur: | Antje Sabine GERSTEIN |
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Rapporteur:

Antje Sabine GERSTEIN

Antje Sabine GERSTEIN

| Referral | European Commission, 20.1.2023 |
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| Legal basis | Article 304 of the Treaty on the Functioning of the European Union |
| Section responsible | Single Market, Production and Consumption |
| Adopted in section | 29.6.2023 |
| Adopted at plenary | 12.7.2023 |
| Plenary session No | 580 |
| Outcome of vote
  (for/against/abstentions) | 196/1/4 |

Referral

European Commission, 20.1.2023

Legal basis

Article 304 of the Treaty on the Functioning of the European Union

Section responsible

Single Market, Production and Consumption

Adopted in section

29.6.2023

Adopted at plenary

12.7.2023

Plenary session No

580

Outcome of vote

(for/against/abstentions)

196/1/4

1.   Conclusions and recommendations

Conclusions and recommendations

| 1.1. | The European Economic and Social Committee (EESC) supports the European Commission’s approach of mainly taking as the point of departure for the revision of the Textile Labelling Regulation (TLR) the possibility of new digital labelling technologies, new fibre technologies and their classification and new recycling technologies and thereby acknowledging the new, extensive EU regulatory context for textiles overall. |
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1.1.

The European Economic and Social Committee (EESC) supports the European Commission’s approach of mainly taking as the point of departure for the revision of the Textile Labelling Regulation (TLR) the possibility of new digital labelling technologies, new fibre technologies and their classification and new recycling technologies and thereby acknowledging the new, extensive EU regulatory context for textiles overall.

| 1.2. | Consumers have varying expectations of the level of detail provided by textile labels. The revision of the Textile Labelling Regulation has to satisfy these different degrees of expectations by offering basic and easily understandable information in the first place, while at the same time giving further access to more detailed information. |
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1.2.

Consumers have varying expectations of the level of detail provided by textile labels. The revision of the Textile Labelling Regulation has to satisfy these different degrees of expectations by offering basic and easily understandable information in the first place, while at the same time giving further access to more detailed information.

| 1.3. | Taking into account that the textile sector is one of the most globalised sectors, the EESC believes that it is of the utmost importance that the European Commission strive for an EU-wide and global alignment of labelling requirements with regard to indications of origin, care instructions, size and fibre composition. |
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1.3.

Taking into account that the textile sector is one of the most globalised sectors, the EESC believes that it is of the utmost importance that the European Commission strive for an EU-wide and global alignment of labelling requirements with regard to indications of origin, care instructions, size and fibre composition.

| 1.4. | The EESC calls upon the European Commission to bear in mind the special needs of SMEs in this sector. In order to prevent further offshoring, and given the fact that the sector employs 1,3 million employees EU-wide, the new TLR requirements must provide enough flexibility to address SMEs’ needs and capacities so that employment and skills in this sector of the economy are not only kept, but can further evolve. |
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1.4.

The EESC calls upon the European Commission to bear in mind the special needs of SMEs in this sector. In order to prevent further offshoring, and given the fact that the sector employs 1,3 million employees EU-wide, the new TLR requirements must provide enough flexibility to address SMEs’ needs and capacities so that employment and skills in this sector of the economy are not only kept, but can further evolve.

2.   General comments

General comments

| 2.1. | The EU strategy for sustainable and circular textiles announced the review of the Textile Labelling Regulation (Regulation (EU) No 1007/2011 (1)), which requires textiles sold on the EU market to carry a label clearly identifying the fibre composition and indicating any non-textile parts of animal origin. As part of this review, the strategy mentions the possibility to introduce mandatory disclosure of other types of information, such as sustainability and circularity parameters, products’ size and, where applicable, the country where manufacturing processes take place (‘made in’). |
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2.1.

The EU strategy for sustainable and circular textiles announced the review of the Textile Labelling Regulation (Regulation (EU) No 1007/2011 (1

| 2.2. | In this opinion, the EESC explores the options to expand the scope of the current regulation by considering certain elements already listed in Article 24 of the regulation for a review and other parameters on sustainability and circularity in coherence with current legislative proposals such as the legislative proposal on eco-design requirements for sustainable products. The opinion will take account of the industrial perspective, including costs and improved exchange of information along the value chain, and the consumer perspective, in order to ensure correct, accurate and clear information. |
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2.2.

In this opinion, the EESC explores the options to expand the scope of the current regulation by considering certain elements already listed in Article 24 of the regulation for a review and other parameters on sustainability and circularity in coherence with current legislative proposals such as the legislative proposal on eco-design requirements for sustainable products. The opinion will take account of the industrial perspective, including costs and improved exchange of information along the value chain, and the consumer perspective, in order to ensure correct, accurate and clear information.

| 2.3. | The EESC supports the approach from the European Commission to mainly take as point of departure the possibility of new digital labelling technologies, new fibre technologies and their classification and new recycling technologies and thereby acknowledge the overall new extensive EU regulatory context for textiles including the Green Claims initiative from the European Commission (2). |
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2.3.

The EESC supports the approach from the European Commission to mainly take as point of departure the possibility of new digital labelling technologies, new fibre technologies and their classification and new recycling technologies and thereby acknowledge the overall new extensive EU regulatory context for textiles including the Green Claims initiative from the European Commission (2

| 2.4. | In this context, the EESC underlines that many aspects in the textile sector are already addressed in highly complex horizontal regulatory proposals which are mostly already in the legislative process. Corporate social responsibility and labour-related issues are addressed in the Directive on Corporate Sustainability Due Diligence and the Regulation on Forced Labour. The Empowering Consumers Directive and the Directive on Green Claims will soon regulate the communication of sustainability claims, while the revised Waste Framework Directive will address the basic concepts related to end-of-life management. |
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2.4.

In this context, the EESC underlines that many aspects in the textile sector are already addressed in highly complex horizontal regulatory proposals which are mostly already in the legislative process. Corporate social responsibility and labour-related issues are addressed in the Directive on Corporate Sustainability Due Diligence and the Regulation on Forced Labour. The Empowering Consumers Directive and the Directive on Green Claims will soon regulate the communication of sustainability claims, while the revised Waste Framework Directive will address the basic concepts related to end-of-life management.

| 2.5. | Consumers have varying expectations of the level of detail provided by textile labels. The revision of the Textile Labelling Regulation has to satisfy these different degrees of expectations by offering basic and easily understandable information in the first place, while at the same time giving further access to more detailed information, for example through the voluntary provision of standardised information about the production process. |
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2.5.

Consumers have varying expectations of the level of detail provided by textile labels. The revision of the Textile Labelling Regulation has to satisfy these different degrees of expectations by offering basic and easily understandable information in the first place, while at the same time giving further access to more detailed information, for example through the voluntary provision of standardised information about the production process.

| 2.6. | The EESC points out that revision of the Textile Labelling Regulation is a REFIT initiative with the clear aim of making EU law simpler, fit for purpose and less costly for businesses and consumers. For companies this must include the reduction of compliance costs as well as regulatory clarity and consistency. For consumers accurate, comprehensive and comparable information on textile products is needed. The EESC underlines the importance of maximum harmonisation in order to help the sector make a successful transition towards comprehensive circularity. |
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2.6.

The EESC points out that revision of the Textile Labelling Regulation is a REFIT initiative with the clear aim of making EU law simpler, fit for purpose and less costly for businesses and consumers. For companies this must include the reduction of compliance costs as well as regulatory clarity and consistency. For consumers accurate, comprehensive and comparable information on textile products is needed. The EESC underlines the importance of maximum harmonisation in order to help the sector make a successful transition towards comprehensive circularity.

| 2.7. | The EESC calls for urgent action on the fibre classification system, as the current system is not flexible enough to address the development of innovative fibres, which often have a lower environmental impact than conventional fibres. For many producers of new fibres, this status quo is frustrating because they cannot label their fibres accurately. Furthermore, these novel fibres cannot yet be indicated on textile labels and, thus, identifying them remains a huge challenge for recyclers, which is currently hampering circularity in the sector. The EESC points out that this regulatory gap also negatively affects consumers’ perceptions, as some products might in reality be much more sustainable than is indicated on current labels. |
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2.7.

The EESC calls for urgent action on the fibre classification system, as the current system is not flexible enough to address the development of innovative fibres, which often have a lower environmental impact than conventional fibres. For many producers of new fibres, this status quo is frustrating because they cannot label their fibres accurately. Furthermore, these novel fibres cannot yet be indicated on textile labels and, thus, identifying them remains a huge challenge for recyclers, which is currently hampering circularity in the sector. The EESC points out that this regulatory gap also negatively affects consumers’ perceptions, as some products might in reality be much more sustainable than is indicated on current labels.

| 2.8. | The EESC believes that it is of the utmost importance that the European Commission strive for an EU-wide and global alignment of labelling requirements with regard to indications of origin, care instructions, size and fibre composition. The textile sector is one of the most globalised sectors. Garments made in each place are destined for multiple geographical areas worldwide (EU, US, etc.), with many different labelling requirements (3). Global labelling requirements and global harmonised standards need to be considered where applicable. |
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2.8.

The EESC believes that it is of the utmost importance that the European Commission strive for an EU-wide and global alignment of labelling requirements with regard to indications of origin, care instructions, size and fibre composition. The textile sector is one of the most globalised sectors. Garments made in each place are destined for multiple geographical areas worldwide (EU, US, etc.), with many different labelling requirements (3

| 2.9. | The requirement for maximum harmonisation is linked to a clear policy request from the EESC to avoid further jeopardising the internal market, as more and more disparate requirements on labelling across Member States seem to appear. The EESC therefore considers it vital and timely for the European Commission to propose the TLR revision in the year 2023, which happens to be the 30th anniversary of the single market. |
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2.9.

The requirement for maximum harmonisation is linked to a clear policy request from the EESC to avoid further jeopardising the internal market, as more and more disparate requirements on labelling across Member States seem to appear. The EESC therefore considers it vital and timely for the European Commission to propose the TLR revision in the year 2023, which happens to be the 30th anniversary of the single market.

| 2.10. | The EESC calls upon the European Commission to bear in mind the special needs of SMEs in this sector. In order to prevent further offshoring, and given the fact that the sector provides jobs for 1,3 million employees EU-wide (4), the new Textile Labelling Regulation requirements must provide enough flexibility to address SMEs’ needs and capacities so that employment and skills in this sector of the economy are not only kept, but can further evolve. For example, a generalised conformity control carried out by a certifying body is not feasible for SMEs, which are the backbone of industrial textile production in the EU. A reasonable approach would be to envisage ‘self-certification’ procedures, such as the internal production controls set out in Annex II to Decision No 768/2008/EC (5), whereby SMEs inform and provide guarantees to consumers. |
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2.10.

The EESC calls upon the European Commission to bear in mind the special needs of SMEs in this sector. In order to prevent further offshoring, and given the fact that the sector provides jobs for 1,3 million employees EU-wide (4

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3.   Specific comments

Specific comments

3.1.   Fibre classification

Fibre classification

| 3.1.1. | In recent years, the textile industry has developed a number of novel fibres with proven lower environmental footprints compared to the more traditional fibre options. Although these materials may be based on a similar feedstock, their manufacturing technology and properties often differ significantly from those used in conventional fibres. The novel fibres are currently not recognised by the existing generic fibre classifications in Annex I. Consequently, the innovative fibre types are classified under different fibre names, or as ‘other’ fibre. Considering the green and circular transition, the revised Textile Labelling Regulation should allow for fibres with distinctive characteristics to be recognised as such in Annex I. The anticipated TLR revision should be better adapted to reflect the dynamic progress around innovative fibres. |
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3.1.1.

In recent years, the textile industry has developed a number of novel fibres with proven lower environmental footprints compared to the more traditional fibre options. Although these materials may be based on a similar feedstock, their manufacturing technology and properties often differ significantly from those used in conventional fibres. The novel fibres are currently not recognised by the existing generic fibre classifications in Annex I. Consequently, the innovative fibre types are classified under different fibre names, or as ‘other’ fibre. Considering the green and circular transition, the revised Textile Labelling Regulation should allow for fibres with distinctive characteristics to be recognised as such in Annex I. The anticipated TLR revision should be better adapted to reflect the dynamic progress around innovative fibres.

| 3.1.2. | A wide array of novel fibre types with distinctive characteristics is already close to commercialisation or will become available on the market in the future. However, the current process of updating Annex I is not transparent and uncertain for applicants. Therefore, the EESC recommends that EU authorities assess and revise how to make the updating process more transparent and technically accurate. |
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3.1.2.

A wide array of novel fibre types with distinctive characteristics is already close to commercialisation or will become available on the market in the future. However, the current process of updating Annex I is not transparent and uncertain for applicants. Therefore, the EESC recommends that EU authorities assess and revise how to make the updating process more transparent and technically accurate.

3.2.   Fibre composition tolerance margin

Fibre composition tolerance margin

| 3.2.1. | Considering the transition to the circular economy, the textile industry is increasingly using recycled fibres and materials in production of garments. The current regulation is not perfectly suited to accurately label fibre composition containing recycled content, hampering the transition to a circular economy. Article 20(3) allows for a maximum 3 % deviation between the fibre content stated on the label and the fibre composition established based on authority testing. The current state of technical development in textile sorting and recycling technology, however, generates variance in the fibre composition that sometimes surpasses the tolerance level of 3 %. This is because, particularly in mechanical recycling, it is not possible to fully ensure that the feedstock for recycling is free from impurities of other textile materials. This calls for a need to explore a higher composition tolerance margin in the revised TLR. Based on the expert input, the EESC recommends that the updated level be 3–5 %. An increased tolerance level should only account for the existing limitations in recycling technology, it should not justify poor manufacturing practice. A minor increase in tolerance levels is a welcome step in removing barriers to the uptake of recycled materials in garment production. |
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3.2.1.

Considering the transition to the circular economy, the textile industry is increasingly using recycled fibres and materials in production of garments. The current regulation is not perfectly suited to accurately label fibre composition containing recycled content, hampering the transition to a circular economy. Article 20(3) allows for a maximum 3 % deviation between the fibre content stated on the label and the fibre composition established based on authority testing. The current state of technical development in textile sorting and recycling technology, however, generates variance in the fibre composition that sometimes surpasses the tolerance level of 3 %. This is because, particularly in mechanical recycling, it is not possible to fully ensure that the feedstock for recycling is free from impurities of other textile materials. This calls for a need to explore a higher composition tolerance margin in the revised TLR. Based on the expert input, the EESC recommends that the updated level be 3–5 %. An increased tolerance level should only account for the existing limitations in recycling technology, it should not justify poor manufacturing practice. A minor increase in tolerance levels is a welcome step in removing barriers to the uptake of recycled materials in garment production.

3.3.   Harmonisation with global standards and processes

Harmonisation with global standards and processes

3.3.1.   Harmonisation of testing standards

Harmonisation of testing standards

| 3.3.1.1. | The textile industry is a highly global industry that often applies international standards. The revision of the TLR is an opportunity to align testing methods of fibre composition with global standards. Currently, under Article 19, only EU (EN) standards are allowed for testing of fibre compositions. In most cases, EN standards are very similar to the international ISO standards, but minor existing differences in method parameters lead to discrepancies between ISO and EN test results. Due to the industry’s global value chains, ISO standards are widely applied and preferred by the sector. As a result, businesses are facing increased testing for products destined for the European market, which significantly raises costs. Therefore, the EESC recommends that the revised TLR accept ISO standards as accepted test standards. Furthermore, the EESC recognises current large strides in innovation around new fibre composition detection methods. The European Commission should take account of this progress when revising the TLR. |
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3.3.1.1.

The textile industry is a highly global industry that often applies international standards. The revision of the TLR is an opportunity to align testing methods of fibre composition with global standards. Currently, under Article 19, only EU (EN) standards are allowed for testing of fibre compositions. In most cases, EN standards are very similar to the international ISO standards, but minor existing differences in method parameters lead to discrepancies between ISO and EN test results. Due to the industry’s global value chains, ISO standards are widely applied and preferred by the sector. As a result, businesses are facing increased testing for products destined for the European market, which significantly raises costs. Therefore, the EESC recommends that the revised TLR accept ISO standards as accepted test standards. Furthermore, the EESC recognises current large strides in innovation around new fibre composition detection methods. The European Commission should take account of this progress when revising the TLR.

3.3.2.   Harmonisation with international standards and trade rules

Harmonisation with international standards and trade rules

| 3.3.2.1. | The EESC supports the idea of transforming the Textile Labelling Regulation into a rulebook of harmonised standards for a number of requirements (novel fibre classification, fibre composition testing, sizing, care instructions). As far as possible, these standards should have a global reach. This would lead to greater harmonisation of labelling requirements both within the single market and with the rest of the world. |
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3.3.2.1.

The EESC supports the idea of transforming the Textile Labelling Regulation into a rulebook of harmonised standards for a number of requirements (novel fibre classification, fibre composition testing, sizing, care instructions). As far as possible, these standards should have a global reach. This would lead to greater harmonisation of labelling requirements both within the single market and with the rest of the world.

| 3.3.2.2. | Given the global scope of the textile sector, it is crucial to consider international alignment and collaboration in the revision of the TLR. The European Commission should ensure coherence with the World Customs Organisation and the current revision of the HS codes as well as with the commitments in the WTO Technical Barriers to Trade Agreement on use of international standards. |
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3.3.2.2.

Given the global scope of the textile sector, it is crucial to consider international alignment and collaboration in the revision of the TLR. The European Commission should ensure coherence with the World Customs Organisation and the current revision of the HS codes as well as with the commitments in the WTO Technical Barriers to Trade Agreement on use of international standards.

3.4.   Digital labelling

Digital labelling

| 3.4.1. | The EESC strongly welcomes the intention of the European Commission to digitalise composition labelling in the revised TLR. In addition, in the context of the Eco-design for Sustainable Products Regulation (ESPR), the EESC welcomes the digital labelling and consumer communication initiatives such as the Digital Product Passport. However, it is crucial that the European Commission align these digital initiatives to create a coherent and effective policy framework. |
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3.4.1.

The EESC strongly welcomes the intention of the European Commission to digitalise composition labelling in the revised TLR. In addition, in the context of the Eco-design for Sustainable Products Regulation (ESPR), the EESC welcomes the digital labelling and consumer communication initiatives such as the Digital Product Passport. However, it is crucial that the European Commission align these digital initiatives to create a coherent and effective policy framework.

| 3.4.2. | Currently physical labels are, for multiple reasons, not as effective as desired. Labels are often cut off after product purchase. The text on labels can be washed out because of multiple laundry cycles. Furthermore, making large physical labels in multiple different languages is costly and contributes to plastic waste. The text is small and includes several translations, which also makes it hard for consumers to understand. |
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3.4.2.

Currently physical labels are, for multiple reasons, not as effective as desired. Labels are often cut off after product purchase. The text on labels can be washed out because of multiple laundry cycles. Furthermore, making large physical labels in multiple different languages is costly and contributes to plastic waste. The text is small and includes several translations, which also makes it hard for consumers to understand.

| 3.4.3. | Digital labels would make things easier for companies, as well as improving information provision to consumers by offering them clear text in the appropriate language versions. There is still a need to provide information to less technologically advanced consumers, but options exist, for example by providing information on demand at the point of sale. To be durable, an indelible ‘data carrier’ type marking on the product can guarantee easy access to digital information. |
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3.4.3.

Digital labels would make things easier for companies, as well as improving information provision to consumers by offering them clear text in the appropriate language versions. There is still a need to provide information to less technologically advanced consumers, but options exist, for example by providing information on demand at the point of sale. To be durable, an indelible ‘data carrier’ type marking on the product can guarantee easy access to digital information.

| 3.4.4. | Even if the Commission decides to leave some information on physical labels, this approach should nonetheless lead to an overall significant reduction in label size. The EESC supports the Commission’s view that physical labels, or physical carriers of digital information, should be made more difficult to cut off. Non-abrasive labelling methods are already available. Methods of making labels harder to cut off should ensure durability of information (e.g. information printed directly on the material can be washed out) and should not reduce the functionality of the product (e.g. sewing a label completely onto a garment could reduce its functionality). |
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3.4.4.

Even if the Commission decides to leave some information on physical labels, this approach should nonetheless lead to an overall significant reduction in label size. The EESC supports the Commission’s view that physical labels, or physical carriers of digital information, should be made more difficult to cut off. Non-abrasive labelling methods are already available. Methods of making labels harder to cut off should ensure durability of information (e.g. information printed directly on the material can be washed out) and should not reduce the functionality of the product (e.g. sewing a label completely onto a garment could reduce its functionality).

| 3.4.5. | The European Commission should assess how the Digital Product Passport can be applied in the context of a digital label under the revised TLR. To enable consistency and facilitate implementation, a TLR digital label could also be put on the same data carrier as the Digital Product Passport. |
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3.4.5.

The European Commission should assess how the Digital Product Passport can be applied in the context of a digital label under the revised TLR. To enable consistency and facilitate implementation, a TLR digital label could also be put on the same data carrier as the Digital Product Passport.

3.5.   Labelling exemption for some types of products

Labelling exemption for some types of products

| 3.5.1. | Annex V to the current Textile Labelling Regulation exempts 42 textile product types from the labelling obligation. These are small items (such as watch straps) where adding a label would reduce the product’s functionality. However, the list approach does not provide clear guidance on how operators should label products not listed in Annex V, but which also have reduced functionality with a label. The EESC recommends that the revised regulation provide clarity on how to correctly label products (such as stockings and socks) where mandatory labelling hampers the product’s functionality. For instance, the current list approach could be replaced by a definition of products exempted from mandatory labelling. |
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3.5.1.

Annex V to the current Textile Labelling Regulation exempts 42 textile product types from the labelling obligation. These are small items (such as watch straps) where adding a label would reduce the product’s functionality. However, the list approach does not provide clear guidance on how operators should label products not listed in Annex V, but which also have reduced functionality with a label. The EESC recommends that the revised regulation provide clarity on how to correctly label products (such as stockings and socks) where mandatory labelling hampers the product’s functionality. For instance, the current list approach could be replaced by a definition of products exempted from mandatory labelling.

Brussels, 12 July 2023.

The President of the European Economic and Social Committee

Oliver RÖPKE

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(1)  Regulation (EU) No 1007/2011 of the European Parliament and of the Council of 27 September 2011 on textile fibre names and related labelling and marking of the fibre composition of textile products and repealing Council Directive 73/44/EEC and Directives 96/73/EC and 2008/121/EC of the European Parliament and of the Council (OJ L 272, 18.10.2011, p. 1).

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(2)  COM(2023) 166 final — 2023/0085(COD).

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(3)  Examples of such requirements are Canada’s Textile Labelling and Advertising Regulations (TLAR) and the US Textile Fiber Products Identification Act.

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(4)  https://euratex.eu/wp-content/uploads/EURATEX_FactsKey_Figures_2022rev-1.pdf.

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(5)  Decision No 768/2008/EC of the European Parliament and of the Council of 9 July 2008 on a common framework for the marketing of products, and repealing Council Decision 93/465/EEC (OJ L 218, 13.8.2008, p. 82).

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