EN    EN EN 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 30.1.2009 
SEC(2009) 90  
  
COMMISSION STAFF WORKING DOCUMENT 
Simplification of EU legislat ion in the field of textile names and labelling - Impact 
Assessment – Executive Summary 
{COM(2009) 31 final} 
{SEC(2009) 91} 
 
 
EN 2   EN COMMISSION STAFF WORKING DOCUMENT 
Simplification of EU legislat ion in the field of textile names and labelling - Impact 
Assessment – Executive Summary 
EU legislation in the field of Textile Names and Labelling consists of three Directives, 
amended over recent years in order to introduce ne w fibre names into the European legislation 
(adaptation to technical progres s). Directive 96/74/EC on textile names requires the labelling 
of the fibre composition of textile products us ing only the harmonised names listed in Annex I 
to the Directive. Directives 96/73/EC and 73/44 /EEC specify the methods of analysis to be 
used to check whether the composition of text ile products is in conformity with the 
information supplied in the label.  
These Textile Directives need to be adapted every time a new generic name for a novel fibre 
is to be added to the technical annexes. The procedure starts with the submission to the 
Commission services of an a pplication file prepared by an  economic operator. From a 
political and legal point of vi ew, the introduction of a new fibr e name is a minor technical 
amendment to EU legislation. However, as the legislation is in the form of Directives, it 
requires all Member States to take action to transpose the amending Directives. Experience 
has shown that it takes a long time between the introduction of  a request for a new fibre and 
its legal adoption in the EU. In the framewor k of the legislative simplification programme 
being undertaken by the European Commission, it is proposed to revise EU legislation on 
Textile Names and Labelling in order to simplify its adaptation to technical progress. 
The key issue surrounding the cu rrent regulatory framework, fo r both public authorities and 
industry, is the time taken betw een the initial applic ation for a new fibre and its legal adoption 
across the EU. The simplification of EU legislation in this field is thus focused on streamlining the procedure and on saving time to add a new fibre name to the technical 
annexes of the Directives. Therefore, the options  examined do not affect the provisions for the 
labelling of textile products with respect to the fibre composition and the institutional 
decision-making process is not changed. 
In order to achieve the objectiv e of reducing the time taken to legally market a new textile 
fibre name in the EU, the available solution is to change the three existing Directives into one or three Regulations, the preference going to on e Regulation if it is confirmed by the Legal 
Service that this is a sound solu tion from a legal point of view. 
The Regulation will simplify the adaptation to technical progress. Member States will no 
longer need to transpose techni cal amendments in the form of Directives into national 
legislation, resulting in a direct  reduction of the administrative burden. Furthermore, it will 
allow authorising the marketing of a new textiles fibre name within a period 12 months shorter than the current situ ation, bringing substantial bene fits to economic operators. 
The feasibility of having a non-legislative so lution for textile name s was also examined. 
Dropping altogether textile names labelling is not an option. Information to consumers in this area is important for reasons of comfort associat ed with the properties of certain fibres and 
also for health reasons because some cons umers develop allergie s to certain fibres. 
Furthermore, the European Union legislation in this domain was de veloped in order to 
harmonise national legislations and avoid technical barriers to  free circulati on of textile 
EN 3   EN products in the Community market. In additio n, economic operators benefit from creating 
new fibres and having them widely known. 
The possibility of self-regulation was also cons idered. However, the experience obtained with 
applications for new fibre names has shown that  the names proposed are sometimes closer to 
brand names than to fibre names related to the properties of the fibre; the fibre definition proposed is not always in line with the fibre propertie s, providing therefore wrong 
information to the consumer; and the testing me thods proposed are almost always incomplete 
or not sound preventing market surveill ance authorities of assessing conformity. 
Member States do not favour eith er possibility. Therefore, both  potential options above were 
no further examined. 
It was also considered if ne gative effects on environment and employment could result from 
the proposed simplification of the legislation. W ith respect to environment, the legislative 
simplification does not appear to bring changes to the current situation. There is no evidence 
of environmental problems associ ated with the rhythm of new textile fibres brought to the 
market. On the contrary, it could be argued th at environmental benefits may arise from 
encouraging the production of fibres which can replace a natural fibre such as cotton, whose 
production process involves some environmental problems. Therefore, the investigation on 
potential negative effects result ing from putting an additional ne w textile fibre in the market 
each year was no further pursued. 
A similar situation occurs with respect to empl oyment. If any effects may result from bringing 
new textile fibres earlier to the market, those effects can only be positive. In fact, innovation associated with new textile fibres is a comp etitive advantage of the European textiles and 
clothing industry. Together with other aspects, it has contributed to enab le the industry to go 
through deep modernisation and restructuring pr ocesses over decades and remain world leader 
in areas such as technical and industrial textiles and fashion. Th e trends in the sector show 
developments into less but larger and more modern companies employing less but better paid 
employees. The job losses in the European textil e and clothing sector are mainly related to the 
changes in the combination of production factor s at international level. In Europe, as 
compared to other regions in the world, the combination of technologies, know-how and labour force costs provide competitive advant ages for the production of high value-added, 
quality and innovative products and compan ies are regularly dropping mass production. 
Within this framework, new textile fibres ar e contributing to givi ng a new shape for the 
textiles and clothing industry and in spite of a reduction in its share in the European economy, 
it remains at 3,5% of the manufacturing added value 
1. Therefore, negative effects on 
employment resulting from the proposed legisl ative simplification were not identified and 
were not further examined.  
Along with the option for a Regulation, further po ssibilities of reducing the time between the 
introduction of a request for a new fibre and its legal adoption in th e EU were assessed. 
Experience in recent years has shown that applic ation files are almost always incomplete, in 
particular with respect to testing methods. It was therefore decided to examine whether 
providing more specific guidanc e on how to prepare an appli cation file would bring net 
benefits to economic operators, c onsumers and public administrations. 
                                                 
1 Eurostat 
EN 4   EN In addition, it was also considered the possibility  of making the application files be examined 
by one of the existing specialis ed laboratories before its s ubmission to the Commission 
services. 
Finally, it was explored the idea of passing to the standardisati on process the contents of the 
technical directives related to the testing methods. Technical me thods can be transformed into 
European standards. This possibility would furt her simplify the European Union legislation. It 
was therefore worth examining if this operati on does not compromise the key objective of 
reducing the time for legally marketing new fibres in the EU. 
With those objectives, the following policy op tions and sub-options were considered: 
(1) Option 1: No policy change  – this option will be analysed as the “baseline” scenario 
and each option will be compared with the current procedure; 
(2) Option 2: Adopt new regulation(s)  – this involves replacing the three directives on 
textile names and labelling by one (or a seri es of) regulations, w ith sub-options as 
follows: 
(a) Option 2.1: Adopt such new regulation(s)  without any addi tional provisions; 
(b) Option 2.2: Adopt such new regulation( s), adding an annex specifying the 
contents of the application file; 
(c) Option 2.3: Adopt such new regulation(s) , including provisions to establish a 
list of laboratories recognised by Member States; 
(d) Option 2.4: Adopt such new regulation(s) , including an annex specifying the 
contents of the application file and provi sions to establish a list of laboratories 
recognised by Member States (Option 2.2 plus Option 2.3). 
(3) Option 3: Adopt a combined reg ulatory / non-regulatory approach 
(standardisation)  - this means a new regulati on would contain the provisions 
currently included in Directive 96/74/EC (as amended) while the quantification methods would be transferred to the domain of standardisation. 
(a) Option 3.1: Adopt such new regulation(s) /standardisation procedures without 
anyadditional provisions; 
(b) Option 3.2 Adopt such new regulation(s)/s tandardisation procedures, adding an 
annex specifying the contents  of the application file; 
(c) Option 3.3 Adopt such new regulation(s) /standardisation procedures, including 
provisions to establish a list of labor atories recognised by Member States; 
(d) Option 3.4 Adopt such new regulation(s) /standardisation procedures, including 
an annex specifying the contents of th e application file and provisions to 
establish a list of laboratories recognis ed by Member States (Option 3.2 plus 
Option 3.3). 
The policy options proposed coul d result in significant savings in the length of time required 
to obtain a new fibre name following an appli cation, bringing economic benefits and reducing 
EN 5   EN the costs. Furthermore, the analysis has shown that significant savings in time have the 
potential to encourage innovation. 
Industry and Member States consider that sp eeding up the process of introducing a new fibre 
name leads to more fibres being brought to the market. According to the industry, one new 
fibre generates net benefits per year betw een € 100,000 and € 2 million, depending on several 
factors. If one or two further new fibre names are put forward each year, benefits for industry 
would increase considerably. Benefits of new and innovative fibres for downstream producers 
using them have not been analysed. However, it  is worth mentioning that a recent fibre named 
elastane, with particular elastic properties, ha s enabled important changes to take place in 
clothing production, bringing competitive advantages and substantial profits. 
With respect to SMEs, it appears to be particularly important to reduce the time between 
investment in a new fibre and the ability to  market it under a new na me. According to the 
information provided by the industry, the whol e business of a SME may be dependent on the 
time it takes a certain fibre to go to the market. 
The analysis and comparison of the policy options leads to the following conclusions: 
• the greatest benefits for i ndustry arise from reducing the time taken between an 
application for a new fibre name being submitted and the ability to place the fibre 
on the market with the new name. This re sults in savings in administrative costs 
and earlier realisation of revenue from sa le of the fibre. Options 2.4 and 3.4 (Case 
A) potentially deliver the most signifi cant cost savings a nd overall benefits. 
Potential time savings under these Options  are 18 to 33 months, up to 6 months 
greater than for the other Options;  
• the greatest benefits to Member State auth orities are from replacing the Directives 
with Regulation(s), because they w ould no longer need to transpose the 
amendments into national legislation. This  could generate sign ificant cost savings 
to Member States. These cost savings aris e under all sub-options of Options 2 and 
3;  
• there are potential benefits to industry and public authorities associated with 
providing guidance on the co ntents of the application file (Options 2.2 and 3.2) 
and on setting up a list of recognised nati onal laboratories unde r (Options 2.3 and 
3.3). If these Options result in the submissi on of application file s more in line with 
the requirements of the Commission services , this could result in significant time 
savings up to 18-27 months for both i ndustry and public authorities; and 
• all of the Options will retain the benefits for consumers of certainty that the 
named fibres meet specified characteris tics. Consumers may also gain additional 
benefits from new fibres reaching the market earlier.