EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 30.1.2009 
SEC(2009) 91 
  
COMMISSION STAFF WORKING DOCUMENT 
Simplification of EU legislat ion in the field of textile names and labelling - Impact 
Assessment Report 
{COM(2009)31 FINAL} 
{SEC(2009)90} 
 
 
EN 2   EN COMMISSION STAFF WORKING DOCUMENT 
Simplification of EU legislat ion in the field of textile names and labelling - Impact 
Assessment Report 
 
EN 3   EN TABLE OF CONTENTS 
COMMISSION STAFF WORKING DOCUMEN T Simplification of EU legi slation in the field of 
textile names and labelling.................................................................................................... ..... 2 
1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES... 5 1.1. Consultation of other Commission Services................................................................ 5 1.2. Consultation with Member States ................................................................................ 5 1.3. Stakeholder consultation .............................................................................................. 5 1.4. External study ............................................................................................................ .. 6 
1.5. Results of the consultation ........................................................................................... 6 1.6. Scrutiny by the Commission impact assessment board ............................................... 7 2. PROBLEM DEFINITION ........................................................................................... 8 2.1. Legislative background ................................................................................................ 8 2.2. Context ................................................................................................................... ...... 9 
2.3. Problem identification................................................................................................ 10 2.4. Community competence and subsidiarity .................................................................. 11 3. OBJECTIVES ............................................................................................................ 12 3.1. Overall objective ........................................................................................................ 1 2 
3.2. Specific objectives ..................................................................................................... 12  
4. POLICY OPTIONS ................................................................................................... 12 4.1. Overview of the policy options.................................................................................. 12 4.2. Development of sub-options ...................................................................................... 14 4.3. Description of options examined ............................................................................... 15 5. ANALYSIS OF IMPACTS ....................................................................................... 16 5.1. Environmental and social impacts ............................................................................. 16 
5.2. Time Savings Associated with the Policy Options .................................................... 17 5.2.1. Overview of time savings .......................................................................................... 17 
5.2.2. Time savings associated w ith Option 2 (Regulation) ................................................ 19 
5.2.3. Time savings associated with Opti on 3 (Regulation + Standardisation) ................... 19 
5.3. Costs and Benefits of the Policy Options................................................................... 21 
 
EN 4   EN 5.3.1. Assumptions and costs estimations............................................................................ 21 
5.3.2. Costs and Benefits of Opti on 1 (baseline scenario) ................................................... 25 
5.3.3. Costs and Benefits of Option 2.1 ............................................................................... 26 5.3.4. Costs and Benefits of Option 2.2 ............................................................................... 29 5.3.5. Costs and Benefits of Option 2.3 ............................................................................... 31 5.3.6. Costs and Benefits of Option 2.4 ............................................................................... 35 5.3.7. Costs and Benefits of Option 3 .................................................................................. 36 5.4. Impact on Small and Medium Enterprises................................................................. 38 5.5. Impact on Innovation ................................................................................................. 38 
5.6. International context .................................................................................................. 39 
6. CONCLUSIONS........................................................................................................ 39 6.1. Changing the three Directiv es on Textile Names into one Regulation (Option 2.1) . 39 
6.2. Providing further guidance to applicants  for a new fibre name (Option 2.2) ............ 40 
6.3. Creating a network of recognise d laboratories (Option 2.3)...................................... 41 
6.4. Providing further guidance and creating a ne twork of recognised la boratories (Option 2.4)
............................................................................................................................... ..... 42 
6.5. Testing methods transferred to the do main of standardisation (Option 3) ................ 42 
7. MONITORING AND EVALUATION ..................................................................... 43 
ANNEX 1 – Summary of consultation responses.................................................................... 44 ANNEX 2 - Comparison of activities for preparation, assessment and approval of an application to 
a new textile fibre name, according to the re gulatory and the regulatory+non-regulatory 
(standardisation) approaches examined ................................................................................... 75 
ANNEX 4 - Steps Involved in the Adoption a New Fibre Name in EU legislation ................ 82 ANNEX 5 – Impact Assessment Board opinion of 9 September 2008 ................................... 85 
 
EN 5   EN  
1. PROCEDURAL  ISSUES  AND  CONSULTATION  OF INTERESTED  PARTIES 
The revision of EU legislati on on Textile Names and Labelling1 was announced in 2006 in 
the “First progress report on the strategy for the simplification of the regulatory 
environment”2 and was included in the Commission Le gislative and Work Programme for 
2008. The idea for a revision of Textile Names legisl ation came to light in recent years as a 
result of the experience developed with re gular technical amendments to the current 
Directives in order to introduce new fibre name s into the legislation. Industry and Member 
States representatives have suggested this re vision in meetings and bilateral contacts. For 
the industry representatives, th e legislation should be reviewed in order to shorten the time 
needed to trade legally a new fibre within th e EU. Member States re presentatives consider 
that introducing new fibre names in the Euro pean legislation is important to promote 
innovation in the European industry and from the perspective of consumer's information. However, the political content of technical amendments to Textile Names legislation does not justify the heavy procedures and costs invo lved in the transposition of a Directive. A 
lighter legislative solu tion should be used. 
1.1. Consultation of other Commission Services 
Work on the impact assessment for this initiative  started in 2007; an inter-service steering 
group involving Directorates-General EN TR, JRC, SANCO, TRADE and SG was 
established in March 2008. The members of the inter-servi ces group were invited to 
participate in the meetings with the consultant  that carried out the ex ternal study as well as 
to participate in the meetings with stakehol ders and Member States representatives. The 
comments on the draft impact assessment re port were mainly provided by e-mail. 
1.2. Consultation with Member States 
In the framework of meetings of the Co mmittee and Working Group on Textile Names and 
Labelling, which took place in 2005 and 2006, Member St ates asked for a simpler 
procedure to add new fibre names to existing legislation. In partic ular, several Member 
States suggested that the Textile Directives be transformed into a Regulation. 
In order to discuss th e key elements of the initiative and aspects requiring particular 
attention, Commission servi ces convened three meetings with Member States 
representatives and other stakeholders on 17 January 2008, 9 April 2008 and 7 July 2008. 
In addition, further input was requested from  Member States on the basis of a specific 
questionnaire. 
1.3. Stakeholder consultation 
Due to the limited scope of th is revision, a targeted consulta tion of interested parties was 
the preferred option. Stakeholde rs participated at the thre e meetings organised by the 
                                                
 
1 Directives 96/74/EC (as amended), 96/73/EC (as amended) and 73/44/EC. 
2 Commission Working Document COM (2006) 689 final 
 
EN 6   EN Commission during 2008. Industr y and the CEN provided fee dback at the occasion of 
bilateral meetings with Commission services. Furthermore, input for the impact assessment 
was requested from key stakeholders on the basis of specific questionnaires. 
The following groups of stakeholders participat ed in the consultation process: industry and 
retail associations, trade unions , consumer organisations, Eur opean standardisation bodies, 
as well as national administrations3. 
In the framework of the meetings organized by the Commission services, stakeholders and 
Member States representative s were invited to present th eir views, suggestions and 
proposals during a period going from January to July 2008. In addition, the consultant in 
charge of the external study st arted consultations with stake holders on 2 April 2008, when 
a first set of questions was sent to industry, and continued until 2 June 2008, when the last response was received. The consultation period is therefore in line with the Commission's 
Minimum Consultation Standards
4. 
1.4. External study 
In order to support the assessment of likel y impacts of the proposal, the Commission 
services ordered a study to an external cons ultant, using the framew ork contract available 
within DG Enterprise and Industry.  
In particular, the study analysed  the potential effects linked to  the different alternatives 
proposed for the revision and assessed the co sts and benefits for public authorities, 
economic operators and consumers. To this end, the consultant circulated a number of 
questionnaires to industry repr esentatives, public authorities (Member States and European 
Commission), the European Committee for St andardisation (CEN) and to consumer 
associations. 
The study "Simplification of EU  legislation in the Field of Textile Names and Labelling – 
An Impact assessment of Policy Options", carried out by Risk Assessment and Policy 
Analysts Limited (RPA) will be posted in th e website of DG Enterprise and Industry. 
1.5. Results of the consultation 
This proposal is the result of regular contacts of Commission se rvices with representatives 
from Member States, industry asso ciations and other stakeholders. 
All stakeholders welcomed the initiative. Member States representatives, industry 
associations and other parties have been invol ved from early stages of the development of 
the proposal, providing fruitful contributions for the assessment of its likely impacts and 
for the drafting of the text.  
                                                 
3 CIRFS/BISFA (International Bureau for the Standardisation of Man Made Fibres), Euratex, AEDT (European 
Association of National Organisations of Textile Reta ilers), Trade Unions, ANEC (European Association for 
the Co-ordination of Consumer Representation in Standardisation), BEUC (European Consumers’ 
Organisation), CEN (European Committee for Standa rdisation), Member St ates representatives. 
4 Communication from the Commission: "Towards a reinforced culture of consultation and dialogue – General 
principles and minimum standards for consultation of interested parties by the Commission" – COM(2002)704 
final. 
 
EN 7   EN Member States representatives have generally indicat ed that they prefer a regulation to a 
directive because the political and administrative burden is lower. They have also considered that improving guidance and clar ifying requirements on developing application 
files would enable to gather all the relevant  information before the legislative process 
starts. As a result, the period of time needed to  process an applicati on would be shortened. 
With respect to the consideration of nati onal laboratories that could provide a first 
assessment on the file to the applicant, Member States generally consider that it will promote a higher quality of appl ications and a harmonisation of  approaches. However, if a 
network of recognised laboratorie s is to be created, this s hould not imply additional costs 
for Member States. It was wi dely indicated by Member States that passing the testing 
methods agreed by the Committee on Textile Names and Labelling to the European Committee for Standardisation (CEN), instead of including them in the legislation, has the 
advantages of making adaptations  easier and more flexible. In addition, it would ensure 
transparency and uniformity of testing procedures all over the EU, facilitating matters to national laboratories. However, Member States  have a major preoccupation in this area 
related to the time needed to have a European  standard adopted, which varies from 1 to 5 
years. The possibility of involving CEN in  the process of adopting a new fibre name 
should not compromise the major objective of  the proposed legisl ative simplification. 
The industry favours a solution enabling to sp eed up the process for adoption of a new 
textile fibre name. Industry representatives cons ider that the current guidance is clear but 
there is always scope for improvements. They recognise that companies are inexperienced in putting an application file for a new textile fibre name into practice. With respect to the use of officially recognised laboratories to produce a firs t assessment of the application, 
industry representatives have st ated that they currently enco urage members to make use of 
existing laboratories in preparing their applic ations because they believe it shortens the 
time needed by the Commission services to exam ine the application. The conversion of test 
methods into European standards overseen by  CEN has, for the industry, the positive 
aspect of allowing easier routine revisions carried out by CEN every 5 years. However, 
industry strongly opposes the involvement of CE N if it represents creating an additional 
step in the decision-making process. 
Consumer associations are not currently wo rking with textile fibre names issues. The 
replies sent are very general, indicating that they think that positive impacts for consumers 
are to be expected from streamlining of  procedures, including the changing from a 
directive into a regulation, cl earer and more detailed guidance to industry applicants, 
independent review by a recognised laboratory be fore an application is submitted, transfer 
of fibre testing methods to European standards. 
A summary of the replies to th e questionnaires from competen t authorities in the Member 
States and from stakeholders is presented in Annex 1. 
1.6. Scrutiny by the Commission impact assessment board 
The impact assessment board of the European Commission
5 assessed a draft version of the 
impact assessment in August 2008. It issued its opinion on 9 September 20086. The impact 
                                                 
5 http://ec.europa.eu/governance/impact/iab_en.htm 
6 Cf. Annex 5 
 
EN 8   EN assessment board made several suggestions for improvement; in the light of these 
suggestions, the final impact assessment report: 
– Explains better how the feasibility of the st andardisation approach will be assessed in 
the future. 
– Gives further reasons to discard non-leg islative and self-re gulatory options. 
– Clarifies certain aspects related to the esta blishment of recognised  laboratories and the 
role of the Joint Research Centre  in the examination process.  
– Describes briefly the international context as regards the granting of new fibre names 
and the implications on trade of textile products. 
2. PROBLEM  DEFINITION 
2.1. Legislative background 
The current regulatory framework for the labe lling of textile products consists of three 
basic Directives: 
– Directive 96/74/EC7 on textile names requires the labelling of the fibre composition of 
textile products using only the harmonised na mes listed in Annex I to the Directive.  
– Directives 96/73/EC8 and 73/44/EEC9 specify the methods of analysis to be used to 
check whether the composition of textile products  is in conformity with the information 
supplied in the label.  
Textile Directives need to be adapted to t echnical progress every time a new generic name 
for a novel fibre must be added to the technical annexes. In the last years, new fibre names 
have been added to the technical annexes of the Directives by way of amendments to the 
Directives: 
– Directive 97/37/EC10 added four new fibres to the list of fibre names (cashgora, lyocell, 
polyamide, aramid).  
– Directive 2004/34/EC11 added the new fibre polylactide to the list of fibre names. 
– Directive 2006/3/EC12 added the new fibre elastomultiester to the list of fibre names. 
– Directive 2007/3/EC13 added the new fibre elastolefin to the list of fibre names. 
– Directive 2006/2/EC14 added two fibre names (polylactide and elastomultiester) to the 
uniform test methods for the quant ification of binary mixtures. 
                                                 
7 OJ L 32, 3.2.1997, p. 38–55, as amended 
8 OJ L 32, 3.2.1997, p. 1–37, as amended 
9 OJ L 83, 30.3.1973, p. 1–19   
10 OJ L 169, 27.6.1997, p. 74–75 
11 OJ L 89, 26.3.2004, p. 35–35 
12 OJ L 5, 10.1.2006, p. 14 
13 OJ L 28, 3.2.2007, p. 12-13 
14 OJ L 5, 10.1.2006, p. 10–13 
 
EN 9   EN – Directive 2007/4/EC15 added the new fibre elastolefin to the uniform test methods for 
the quantification of binary mixtures 
Two more applications are currently bei ng examined and new amendments to the 
Directives are expected for 2008 and 2009. 
2.2. Context 
The textiles sector is an important part of the European manufactur ing industry, with a 
turnover of over €100 billion in 2005 and employing over 1 million workers16. It accounts 
for 3.5% of the total number of manufacturing firms in th e EU (around 77,000) but less 
than 2% of manufacturing turnover. The averag e size of textiles companies is lower than 
the average size for all EU manu facturing, with the greatest nu mber of small firms in the 
Member States, Spain and Portugal. The major players in EU textiles  production are Italy, 
Germany, France, the UK and Spain, but there ar e significant textiles sectors in Belgium, 
the Czech Republic, Lithuania, Portugal and Slovenia. 
A study of the competitiveness of the EU textile  industry notes that the sector has faced 
significant economic challenges in recent years. Th e profitability of the sector in the period 
covered by the study was only 0.53 %, directly related to the continuing overcapacity of the 
sector, despite a decline in  production of nearly  14% between 2000 and 2005. This is due 
to a complex set of factors, including the Eu ro/Dollar rate and China's accession to WTO, 
which has enabled Chinese exporters to benefit from the initial steps of quota liberalization 
since December 2001. 
EU textile industry has undertaken a lengthy pr ocess of restructuring, modernisation and 
technological progress in response to the si gnificant economic challenges faced by the 
sector in recent years. Eu ropean companies have impr oved their global position by 
concentrating on competitive advantages such as quality, design, innovation and products with higher value-added. The EU industry ha s a leading role at world level in the 
development of new products, technical text iles and non-wovens for novel applications 
such as geo-textiles, hygiene  products, the automotive indus try or the medical sector. 
Role of fibre research and innovation
 
A key area for research is the development of new speciality fibres and fibre composites 
for innovative textile products, iden tified as one of the thematic priorities  in the Strategic 
Research Agenda of the European Technolog y Platform for the Future of Textile and 
Clothing. Fibre innovation at th e upstream end of the text ile value adding chain is a 
powerful source of new products, processing  options and appli cation areas in many 
downstream user sectors17. In fact, the number of requests for new fibre names to be added 
to EU legislation has increased in recent years and th is trend is expected to consolidate as 
the European textile sector evolve s into a more innovative industry.  
                                                 
15 OJ L 28, 3.2.2007, p. 14–18 
16 Figures for the textile sector, excluding clothing manufacture. Source: Institut Français de la Mode (2007), 
"Study on the competitiveness, economic situation and location of production in the textiles and clothing, 
footwear, leather and furniture indust ries", prepared for the European Commission, Enterprise and Industry 
Directorate General 
17 Strategic Research Agenda of the European Technology  Platform for the Future of Textiles and Clothing 
 
EN 10   EN Applications for new fibre names have been submitted by a number of different 
companies, including both large and small firm s. Industry indicates that, in general, 90-
95% of R&D activities are focussed on improve ments and developments on existing fibres. 
Although only 5-10% of R&D activ ities are likely to result in a fibre requiring a new 
generic name, these new fibres generate ofte n new uses and technolog ical processes in a 
wide number of domains such as clothing,  medical, environmental and industrial 
applications. 
2.3. Problem identification 
Adoption of a new fibre name in EU legislation  
Adding a new fibre to the annexes of the text ile Directives necessitates a lengthy procedure 
at European level, requiring all Member States in the EU to adapt their national laws subsequently. Enterprises must wait for seve ral years before being able to use the new 
names they have applied for. 
The Commission services expect that the numbe r of new fibres added to the technical 
annexes is likely to increase in the coming year s. Member States authorities also indicated 
that they expect the number of new fibres requiring names to increase, some suggesting that there could be two to three new fibr e name applications per year. Industry (as 
represented by BISFA
18) noted that the future trend is difficult to predict. However, it also 
suggested two applications a y ear as a realistic estimate. 
For the purposes of this analysis and identifi cation of the system's defaults, the application 
process under the existing Textiles Directive has been divided into five key steps which 
involve varying actions by the stakeholders involved (industry and public authorities). 
These are set out below, further details are availa ble in Annex 4. 
– Step 0: Preparation of Application  
– Step 1: Submission of Application  
– Step 2: Assessment and Initial Review of Application 
– Step 3: Technical Examination of Application  
– Step 4: Preparation of Draft Proposals 
– Step 5: Amendment of Direc tive and National Legislation  
– The key issue surrounding the current re gulatory framework, for both public 
authorities and industry, is the time taken between the initial application for a 
new fibre and its legal adoption across the EU, i n particular with respect to the 
technical examination and the transposit ion of the amendments into national 
legislation. 
This translates in particular into: 
                                                 
18 BISFA: International Bureau for the Standardisation of Man Made Fibres.  
 
EN 11   EN a) Burden for public authorities.  
The current process imposes a burden on public authorities. Member States need to 
transpose each adaptation to technical progres s of the Directives in to national legislation. 
Member States have expressed problems w ith transposition of amendments to the 
Directives and have suggested that they be transformed into a Regul ation. In particular, 
Member States with a federal political orga nisation have to follow the complete federal 
procedures to transpose the t echnical adaptation into national legislation. These procedures 
involve regional and local authorities or parlia ments. The political content of introducing a 
new fibre name for consumer's information in the European legislati on does not appear to 
justify the heavy procedures and costs related to the transposition of a Directive. According 
to information provided in the regulatory impact assessment by the UK for the last amendment of the UK textiles legislation, th e involved costs were estimated at around 1 
million euros
19. These costs are certainly different across Member States. However, this 
estimation allows the conclusion that they are si gnificant at EU level. They appear to be 
disproportionate compared to  the political relevance of  the amending Directives.  
b) Costs for economic operators  
For economic operators, the delay between an application for a new fibre name and the 
time when it can legally be placed on the market may have implications at different levels. In the first place, it delays the return of th e investment for the company that has developed 
the new fibre. Secondly, it will postpone benef its for those companies that will develop and 
market products using the new fibre. Thirdly, a more rapid process for approval of new 
fibres would contribute to im proving the rate of innovation in  the textiles and clothing 
sector by encouraging new applications for new fibre names. As a result, reducing delays is 
foreseen to improve the overall profitability of the sector. 
Consideration is given also to the costs fo r companies for preparing and ensuring the 
follow up of an application for a new fibr e name submitted for technical examination. 
According to industry representa tives (BISFA), these costs may be particularly significant 
for small and medium enterprises. Currently there is no specific format for preparing an 
application. This may pose part icular difficulties for SMEs w ith limited experience in the 
preparation of such dossiers. 
2.4. Community competence and subsidiarity 
Member States recognised in the 1970’s th e need for harmonization of Community 
legislation in the area of textile names. Diff erent (non-harmonised) textile fibre names in 
the EU Member States would create a technical barrier to trade in the Internal Market. In 
addition, consumer interests would be better pr otected if the information provided in this 
area is the same within  the Internal Market. 
 
This rationale is still valid today and Comm unity rules, based on ar ticle 95 of the EC 
Treaty, are necessary to avoid fragmentation of the market. T hus, the simplification of the 
existing regulatory framework can on ly be achieved by Community action. 
                                                 
19 DTI (2006): Full Regulatory Impact Assessment, The Textile Products (Indications of Fibre Content) 
(Amendment and Consolidation of Schedules of Textile Names and Allowances) Regulations 2006, UK 
Department for Trade and Industry, 13th December 2006. 
 
EN 12   EN Furthermore, the policy opti ons do not modify the politi cal balance between Member 
States and EU. In all of them a Committee is foreseen to assist the Commission and give an 
opinion on the implementing m easures proposed, following th e rules of a regulatory 
committee with scrutiny. This is the case today with Directive 96/74/EC. 
3. OBJECTIVES  
3.1. Overall objective 
The general objectives of the European legisl ation in the field of Textile Names are to 
ensure the proper functioning of the internal market for textile products and to protect 
consumer interests through correct inform ation on textile fibre composition. If the 
provisions of the Member States with regard to the names, composition and labelling of 
textile products were to vary from one Me mber State to another, this would create 
hindrances to the proper functi oning of the internal market. 
While the general objectives of the Textile Names Directives remain the same, the revision 
of this legislation aims at simplifying and improving the existing regulatory framework for 
the development and uptake of novel fibres, with a view to encourage innovation in the 
textile and clothing sector. 
The revision should also enhan ce the transparency of the process to add new fibres to the 
list of harmonised fibre names. At the same time, it should introduce more flexibility to 
adapt legislation in order to keep up with the needs of the technological developments 
expected in the sector. 
It must be pointed out that it is not an objective of the revisi on to extend EU legislation to 
other labelling requirements beyond the curren t scope of the Textile Names Directives 
which is the fibre composition and the harmonisation of textile fibre names. 
3.2. Specific objectives 
– Reduce the burden for public administrations  as regards the examination of the 
application and facilitate the legislative pr ocess with respect to the changes involving 
adaptation to technical progress.  
– Shorten the time from investment  to return for fibre producers  and reduce costs for 
businesses of application for a new fibre authorisation.  
– Allow fibre users and consumers  to benefit faster from th e use of novel fibres and 
innovative products. 
4. POLICY  OPTIONS 
4.1. Overview of the policy options 
Several broad lines of action to  speed up the adoption of new fi bre names were considered.  
The first option that appeared to be the strongest available so lution was changing the 
Directives on Textile Names and Labelling in to one or three Regulations. This change 
 
EN 13   EN appeared to have the potential to simplify the adaptation to technical progress. Member 
States would no longer need to transpose techni cal amendments in the form of Directives 
into national legislation, resulting in a di rect reduction of the ad ministrative burden. 
Furthermore, it would allow authorising the ma rketing of a new textiles fibre name within 
a period of time 12 months shorter than the curr ent situation, bringing substantial benefits 
to economic operators. 
The feasibility of having a non-legislativ e solution was examined. One way could be 
dropping altogether textile names labelling. Howe ver, Member States agree on the need to 
harmonise textile fibre names to avoid prolifer ation of different name s since the 70s; thus, 
EU legislation in this fiel d reflects the shared concern of the Commission and Member 
States that fibre names should provide inform ation on the characterist ics of the fibre and 
not be linked to a commercial name. Information to consumers in this area is important for reasons of comfort associated with the propert ies of certain fibres and also for health 
reasons because some consumers develop alle rgies to certain fibres. Furthermore, the 
European Union legislation in this domain was developed in order to harmonise national 
legislations and avoid technica l barriers to free circulatio n of textile products in the 
Community market. In addition, economic oper ators obtain substantial benefits from 
creating new fibres and having them widely known and marketed. Furthermore, as it was 
already highlighted in this report, textiles names labelling has the potential to encourage 
innovation in the EU industry. In view of that, this possibility would not gather the support 
of Member States. 
The possibility of self-regulation was also considered. However, the experience obtained 
with applications for new fibre names has s hown that the names propos ed by the applicants 
are sometimes closer to brand names than to fibre names related to the properties of the 
fibre. In addition, the fibre defi nition proposed is often not in line with the fibre properties, 
providing therefore wrong information to th e consumer. Finally, the testing methods 
included in the application f ile are almost always incomp lete or not sound, preventing 
market surveillance authoritie s of assessing conformity co rrectly. All these points are 
sensitive to Member States, keen on examin ing the name and proposed definition as well 
as on introducing modifications where approp riate. These views are reiterated in the 
framework of the meetings of the Committ ee and the Working Group on Textile Names 
and labelling which take place regularly. Ther efore, a non-legislative initiative was no 
further examined. 
– Option 1: no policy change that would leave the situation as it is. 
– Option 2: a regulatory approach  in which the three Directives on Textile Names and 
Labelling would be replaced by one (or a series of) regulation(s), keeping both 
harmonised names and quantification methods within the EU legislative framework. 
Such replacement of the Dire ctives by a re gulation would provide a legal instrument 
which is directly applicable in Member States. This change is mainly of a technical nature as the provisions for the labelling of textile products and the institutional 
decision-making proce ss are not affected. 
– Option 3: a combined regulatory/non-regulatory approach in which a new regulation 
would contain the main provisions currently  included in Directive 96/74/EC and the 
Directives on quantification methods w ould be replaced by European standards. 
 
EN 14   EN 4.2. Development of sub-options 
Further to the simplification of the legislative process, other possibilities to facilitate and 
reduce the time taken with the technical ex amination of the application files were 
considered. 
Recent experience has shown that the applic ation files for new fibre names are usually 
insufficient and incomplete. This situation im plies that more information needs to be 
required from applicants, obliging to further te sting work. It has happe ned that applicants 
have taken an additional period of 18 to 24 mont hs to complete their applications with the 
required information; this situation occurs de spite the fact that t echnical guidelines are 
available in DG Enterprise and Industry we bsite. It was therefore decided to examine 
whether the inclusion of an Annex to the Regulation containing technical guidance would 
improve the situation. 
To improve the quality of the technical files a nd, therefore, to facilit ate the technical work 
required for adding a new fibre name to EU legislation, the following additional 
approaches have been considered  within the options 2 and 3:  
a) To include an annex in the legal act describing the technical file to be submitted by the 
manufacturer. This would effectively clarify the requirements for submitting an application for a new fibre name and make these binding (as opposed to the current non-
binding/guideline status);  
b) to identify recognised national laborator ieswhich would support applicants in the 
preparation of a complete technical file (prior  to applying for a new fibre name), with the 
recognised laboratory providing a report on the results of the analysis carried out. This 
would help to ensure that the application file contained all the information necessary. 
Overall, it is envisaged that:  
– applicants will be responsible for the development of method s to identify and 
quantify the new fibre ( however, in some cases the applicant may ask one of the 
recognised laboratories to undertake this step too); 
– the recognised laboratory , identified by national authorities, will review the file and 
ensure that the application file meets th e requirements of Commission services. A report 
from the laboratory, including data to suppor t the validity of quantification methods 
would accompany the application file;  
– the use of recognised laboratories should remain voluntary  and therefore the report  
issued by the laboratory should not have a legal status; and 
– the technical examination by the Commission services would focus on checking the 
adequacy of the application and validation of quantification methods. The Commission 
will remain responsible for commi ssioning ring trials when needed.  
c) a) and b) taken simultaneously.  
 
EN 15   EN 4.3. Description of options examined 
The combination of each option with the differe nt approaches to facilitate the technical 
examination resulted in a range of  sub-options to be analysed focusing on their capacity to 
streamline the current procedure, save time and reduce costs. 
Option 1: No policy change  – this option will be analysed as the “baseline” scenario and 
each option will be compared w ith the current procedure; 
Option 2: Adopt new regulation(s)  – this involves re placing the three directives on textile 
names and labelling by one (or a series of) regulations, with sub-options as follows: 
– Option 2.1: Adopt such new regulation(s)  without any addi tional provisions; 
– Option 2.2: Adopt such new regulation(s), addi ng an annex specifying the contents of 
the application file; 
– Option 2.3: Adopt such new regulation(s), in cluding provisions on the intervention of 
laboratories recognised by Member States; 
– Option 2.4: Adopt such new regul ation(s), including an annex specifying the contents of 
the application file and provi sions on the intervention of  laboratories recognised by 
Member States (Option 2.2 plus Option 2.3). 
Option 2 will simplify the adaptation to techni cal progress. Member States no longer need 
to transpose the technical adaptations into  national legislation resulting in a direct 
reduction of their administrative burden. In addi tion, the time related to the transposition of 
a Directive into national legislation is eliminated. Additional reductions in costs or increases in benefits are investig ated within sub-options 2.2 to 2.4. 
Option 3: Adopt a combined reg ulatory / non-regulatory approach  - this means that a 
new regulation would contain th e provisions currently included  in Directive 96/74/EC (as 
amended) while the quantification methods would be transferred to the domain of 
standardisation. 
– Option 3.1: Adopt such new regulation(s)/s tandardisation proce dures without any 
additional provisions; 
– Option 3.2: Adopt such new regulation(s)/sta ndardisation procedures, adding an annex 
specifying the contents of the application file; 
– Option 3.3: Adopt such new regulation(s) /standardisation pro cedures, including 
provisions on the intervention of labo ratories recognised by Member States; 
– Option 3.4: Adopt such new regulation(s)/s tandardisation procedures, including an 
annex specifying the contents of the appl ication file and provisions to establish 
laboratories recognised by Member St ates (Option 3.2 plus Option 3.3).  
In Option 3, it is examined whether the st andardisation process may bring additional 
benefits or reductions of costs.  
 
EN 16   EN The assumptions for this option are more co mplex. A proposal for a European Standard 
may come from any interested party, such  as the European Commission (EC), the 
European Free Trade Association (EFTA) and National Standards Bodi es (NSB). There are 
two processes for adopting European standards:  
– the ‘classical’ process, which generally takes up to 36 months to complete; and  
– the shorter Unique Acceptance Process (UAP), which takes 8 - 12 months.  
A description of the steps i nvolved in adopting a standard  is presented in Annex 3. 
It was assumed that the UAP would be more commonly used in the ca se of textile fibre 
testing methods. Although CEN is not formally  involved in the process of adopting a new 
fibre name, in practice the National Experts who assist the JRC always include members of 
the CEN relevant committees. This could in principle avoid enteri ng into a classical 
process for the establishment of a standard. Th e risks associated with this possibility are 
highlighted in the conclusions. It was theref ore retained a period of 12 months for the 
standardisation procedures. 
The key uncertainty with Option 3 is whether a fibre with a new name  could be placed on 
the market during the period when the test me thod was being converted to a standard. Two 
scenarios are, ther efore, considered: 
– Case A : This assumes that the marketing of the fibre under the new fibre name is 
possible as soon as the amendmen t to the regulation is published, before  the agreed test 
methods are adopted as a European Standard by CEN. In essence, although the work by 
CEN takes 12 months, the fibre could be mark eted during this peri od, with this then 
reflecting a best case situation. The time sa vings for Option 3 under this scenario are 
essentially equivalent to Option 2 (a nd its various sub-options); and  
– Case B : This assumes that the marketing of th e fibre under the new fibre name is only 
possible when the amendment to the regulation is published and after  the agreed test 
methods are adopted as a European Standard by CEN. This is th e worst case situation 
and essentially adds 12 months (the maximum time taken under UAP) to the time taken under Option 2 (and its various sub-options). 
For all the options and sub-options above, Table I in Annex 2 presents a detailed 
description of the activities to  be carried out during the proc ess of preparation, assessment 
and approval of an application to a new textil e fibre name, according to the five key steps 
described in section 2.3 and Annex 4. 
5. ANALYSIS
 OF IMPACTS 
5.1. Environmental and social impacts 
It was considered if negative effects on environment and employment could result from the 
proposed simplification of the legislation. 
With respect to environment, the legislat ive simplification does not appear to bring 
changes to the current situation. There is no evidence of environmental problems 
 
EN 17   EN associated with the rhythm of new textile fibres brought to th e market. On the contrary, it 
could be argued that environmental benefits  may arise from encouraging the production of 
fibres which can replace a natural fibre su ch as cotton, whose pr oduction process involves 
some environmental problems. Therefore, th e investigation on poten tial negative effects 
resulting from putting an additional new textil e fibre in the market each year was no 
further pursued. 
A similar situation occurs with respect to employment. If any effects may result from 
bringing new textile fibres ear lier to the market, those effects can only be positive. In fact, 
innovation associated with new textile fibres is a competitive advantage of the European 
textiles and clothing industry. Together with ot her aspects, it has contributed to enable the 
industry to go through deep modernisation an d restructuring processes over decades and 
remain world leader in areas such as tech nical and industrial text iles and fashion. The 
trends in the sector show developments into  less but larger and more modern companies 
employing less but better paid employees. Th e job losses in the European textile and 
clothing sector are mainly related to the ch anges in the combinati on of production factors 
at international level. In Europe, as co mpared to other regions in the world, the 
combination of technologies, know-how and labour force costs provide competitive 
advantages for the production of high valu e-added, quality and innovative products and 
companies are regularly dropping mass producti on. Within this framework, new textile 
fibres are contributing to giving a new shape for the text iles and clothing industry and in 
spite of a reduction in its share in the European econom y, it remains at 3,5% of the 
manufacturing added value20. Therefore, negative effects on  employment resulting from 
the proposed legislative simplification were not  identified and were not further examined.  
5.2. Time Savings Associated with the Policy Options 
5.2.1. Overview of time savings 
The time taken in the different steps for the assessment and approval of the more recent 
applications was retained in the baseline scenario (current Directives). The time taken with the application that was more rapidly approve d was identified as a best case scenario and 
the one taking more time to be approved gene rated the worst case scenario considered. 
From the replies to the questionnaires from st akeholders, Member States and the JRC, the 
time was then estimated for the options develo ped in the section 4 above, according to the 
steps described in section 2.3. Table 5.1 below summarises the results of this analysis. 
                                                
 
20 Eurostat 
 
EN 18   EN Table 5.1:Time in Months Taken for Each Step of the Application Process (Prior to Marketing) (Best Case (BC) and Worst Case (WC )) 
 Option 1 Option 2.1 Option 2.2 Option 2.3 Option 2.4 Option 3.1 Option 3.2 Option 3.3 Option 3.4 
Steps in the Application Process  BC WC BC WC BC  WC BC WC BC WC BC WC  BC WC BC WC BC WC 
Step 0 - Preparation of Application2  0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 
Step 1 - Submission of Application2  0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 
Step 2 – Assessment of Application  1 3 1 3 1 3 1 3 1 3 1 3 1 3 1 3 1 3 
Step 3a – Convening Working Group  6 18 6 18 3 6 3 9 3 3 6 18 3 6 3 9 3 3 
Step 3b – JRC & Ring Trials  9 15 9 15 9 15 6 9 6 9 9 15 9 15 6 9 6 9 
Step 3c/3d – Report on Technical 
Examination 1 3 1 3 1 3 1 3 1 3 1 3 1 3 1 3 1 3 
Step 4 – Draft Proposals 1 3 1 3 1 3 1 3 1 3 1 3 1 3 1 3 1 3 
Step 5a – Directive/Regulation Amended 6 12 6 12 6 12 6 12 6 12 6 12 6 12 6 12 6 12 
Step 5b – Standard adopted by CEN (Option 3)           0 12 0 12 0 12 0 12 
Step 5c – Transposition (Option 1) 12 12         0 0 0 0 0 0 0 0 
Option 1: Total Number of Months  36 66                 
Option 2: Total Number of Months   24 54 21 42 18 39 18 33         
Option 3:Total Number of Months up to 
CEN publication of European Standard           24 66 21 54 18 51 18 45 
 Option 1 (the 
current 
process) 
could take 
36 - 66 
months  in 
total Option 2.1 
shows a 12 
month time 
saving 
compared to 
Option 1,  as 
MS no 
longer have 
to transpose 
Directive Option 2.2 
shows a 3-12 
months time 
saving  
compared to 
Option 2.1  
due to 
guidance on 
application 
file Option 2.3 
shows a 6-15 
months time 
saving 
compared to 
Option 2.1  
through use 
of 
recognised 
laboratories  Option 2.4 
shows a 18-
33 months 
time saving 
compared to 
Option 1   The best case scenario under Option 3 is the same as the best 
case Scenario under Option 2. However, under worst case 
assumptions, the time savings in Option 2 may be largely 
offset under Option 3 by the 12 months needed for a standard 
going through CEN.  
 
 
1. The time taken for Option 1 is based on experience to date (from the three amendments completed in the last five years), of the minimum and maximum time actually taken for each step. 
Because of the small number of cases, it is not possible to provide a m eaningful average time. 
2. Submission of the application is taken as the start of the pr ocess. In practice, some sub-op tions may affect the time taken by the applicant to prep are an application. . 
 
EN 19   EN  
5.2.2. Time savings associated with Option 2 (Regulation) 
Under best case assumptions for Option 1, the time savings for Option 2 are 
estimated as being between 12 and 18 mont hs. A 12 months time saving is associated 
with the fact that Member States no longe r have to transpose an amending Directive 
into national legislation. A further 3 to 6 months are expected to be saved due to a 
more developed technical guidance for appli cants and through the use of recognised 
laboratories. 
Under worst case assumptions for Option 1 (delays occur in several of the steps and 
the fibre and/or quantitative methods ar e technically complex), the maximum time 
savings delivered by Option 2 would be up to 33 months. The variation in savings 
across the sub-options to Op tion 2 is shown in Table 5.2. 
Table 5.2: Potential Time Savings Compa red to Baseline: Option 2 Sub-Options  
Options  Best Case Worst Case 
Time taken – baseline 36 66 
Time savings - Option 2.1 12 12 
Time savings - Option 2.2 15 24 
Time savings - Option 2.3 18 27 
Time savings - Option 2.4 18 33 
The analysis suggests that Option 2.4 has the potential for delivering the most 
significant overall reductions in the am ount of time taken from the point of 
application to being able to market a fibre under a new name. Under the worst case 
assumptions, the additional savings could be up to 6 months greater than for the other 
sub-options, while under the best case a ssumptions there may be no difference 
between this sub-option and sub-Option 2.3.  
5.2.3. Time savings associated with Op tion 3 (Regulation + Standardisation) 
As mentioned in section 4.2, the assumpti ons for Option 3, the combined regulatory 
and non-regulatory option, are more comp lex. Two scenarios are, considered 
depending on the moment when a fibre wi th a new name could be placed on the 
market. 
The differences in the time savings under Scenarios A and B for Option 3 are set out 
in Table 5.3. Essentially, if it is assumed th at the process stops after Step 5a (which 
concludes with the amendment of the regulation), then the time savings is the same 
as for Option 2; if the proce ss does not stop until  after Step 5b (i ncluding approval by 
CEN), then the time savings are reduced by 12 months across all sub-options. 
Table 5.3: Potential Time Savings Compa red to Baseline: Option 3 Scenarios  
Options  Best Case Worst Case 
Time taken - baseline 36 66 
Case A - Fibre can be placed on the market  after Step 5a (equivalent to Option 2) 
Time savings - Option 3.1  12 12 
Time savings - Option 3.2  15 24 
Time savings - Option 3.3  18 27 
Time savings - Option 3.4  18 33 
Case B - Fibre can be placed on the market  after Step 5b (adoption of the standard) 
Time savings - Option 3.1  0 0 
 
EN 20   EN Table 5.3: Potential Time Savings Compa red to Baseline: Option 3 Scenarios  
Options  Best Case Worst Case 
Time taken - baseline 36 66 
Time savings - Option 3.2  3 12 
Time savings - Option 3.3  6 15 
Time savings - Option 3.4  6 21 
Figures 5.1 and 5.2 illustrate the impacts of  each policy option on the time taken for 
each step required to adopt a new fi bre name (under best and worst case 
assumptions) relative to Option 1. 
Figure 5.1:  Time Taken (Best Case) For Each Step of the Application Process
111111111666
333333999
99
6666111
11
1111111
11
1111666
66
666612
0510152025303540
Option 1 Option 2.1 Option 3.1 Option 2.2 Option 3.2 Option 2.3 Option 3.3 Option 2.4 Option 3.4
Policy OptionsTime Taken in MonthsStep 5c
Step 5b
Step 5a
Step 4
Step 3c
Step 3b
Step 3a
Step 2
 
Figure 5.2:  Time Taken (Worst Case) For Each Step of the Application Process
33333333318 18 18
6699
3315 15 15
15 15 9 9
99333
33
33
33333
33
33
3312 12 12
12 12
12 12
12 1212
12
12
1212
010203040506070
Option 1 Option 2.1 Option 3.1 Option 2.2 Option 3.2 Option 2.3 Option 3.3 Option 2.4 Option 3.4
Policy OptionsTime Taken in MonthsStep 5c
Step 5b
Step 5a
Step 4
Step 3c
Step 3b
Step 3a
Step 2
 
 
EN 21   EN 5.3. Costs and Benefits of the Policy Options 
5.3.1. Assumptions and costs estimations 
The first step was to determine the baseline – the costs and benefits associated with 
the current situation. Howeve r, only three applications for new fibre names have 
been completed in the last five years,  with a further tw o under way, providing a 
limited evidence base. Furthermore, only limited information was received from textile/fibre manufacturers. 
Given the lack of concrete data, it was necessary to make a series of assumptions to 
provide the basis for the anal ysis. A number of assumptions and scenarios have been 
derived to provide best estimates of the pot ential costs and benefits of the various 
policy options. These assumptions and estim ates are based on information obtained 
from consultation (for instance, with CI RFS/BISFA) and/or obtained from previous 
(related) studies or other referenced sour ces. The assumptions have been reviewed 
and agreed by CIRFS/BISFA. 
The uncertainty also meant that relati vely wide ranges are provided for most 
variables, as the data base was insufficient to provide averages or to determine the probabilities that values would fall at particular points on the range. 
In estimating the costs and benefits (costs savings) relating to the policy options, the 
emphasis is on three main types of cost:  
– the administrative costs incurred by industry, the Commission and Member 
States in relation to the technical examination and by Member State authorities related to the transposition of EU Directives into na tional legisla tion. Industry 
may also incur additional testing costs in meeting requests for additional data 
during the technical examination;  
– the sales/revenue lost  as a function of the time ta ken between the introduction of 
the application for a new fibre name and the moment at which the fibre can be legally put on the EU market; and  
– the impact on innovation , development of new products or processes and on the 
overall research and innovati on potential of the textile sector, taking  into account 
the specific circumstances of Sma ll and Medium Enterprises (SMEs). 
A summary of the assumptions is as follows: 
– two cost scenarios have been developed: a high cost scenario  (based on 
information provided by industry) and a low cost scenario  (based on information 
from previous related studies). Furt hermore, “lower bound” and “upper bound” 
costs have been derived for each of thes e above scenarios to provide for a more 
robust assessment. The "lower bound" costs show the costs of the best cases in 
terms of time taken in the application pr ocess as explained in section 5.2, while 
the "upper bound" costs show the costs of the worst cases. These scenarios and the 
resulting cost estimates have been  reviewed and agreed by industry 
representatives (CIRFS/BISFA);  
 
EN 22   EN – costs have been calculated per fibre name application  focussing on three main 
types of cost: administrative costs, losses of revenue from delays in bringing new 
fibres to market and impacts on innovati on. The cost calcula tions are based on a 
series of simple spreadsheet models, in line with the concepts underlying the EU Standard Cost Model, although sufficiently detailed data were  not available to 
give a full breakdown of costs by activity;  
– for simplicity, a current rate for applications for new fibre names of one per year  
has been used, although the actual fibre appl ication rate in the last 10 years is 
around 0.6/0.8 per year (three or four fibre applications  every five years). In 
effect, the cost or benefit per application is equivalent to an annua l cost or benefit;  
– these annual costs and benefits have been  calculated over a ten-year time period, 
discounted at 4% to provide a consistent  basis for comparison. The 10-year period 
takes account of the period over which the benefits of a new fibre will mainly accrue; and  
– the major non-economic impacts not readily subject to monetary valuation appear 
to accrue to consumers. Thes e have been highlighted.  
The main staff time costs for industry asso ciated with an application arise before 
submitting an application, during the prepar atory stages; these costs are mainly 
related to the research and development of a new fibre and they are not influenced by 
the process of approval of a new fibre name . Therefore they are not included in the 
impact assessment. Staff time will also be required during the application process; 
this is included in the impact assessment . CIRFS/BISFA indicated that one to three 
staff members are always present at mee tings and submissions, and suggested that 
these staff work full-time on the application at a cost of up to €1 million throughout 
the two to three years that an application takes to reach the point when an amendment to the Directives is adopted at EU level (Steps 2 to 5a
21). This implies a 
cost of around €300,000 per year for three staff or €8,300 per person per month on 
average. This was adopted as the high-cost scenario.  
The external consultant previous work on other application processes allows the 
conclusion that both this time estimate a nd the cost per person may be on the high 
side. In fact, in some cases the cost may be  close to half of the indicated in the high 
cost scenario. Therefore it was assumed that  the average cost may vary between the 
high cost scenario and the half of it,  meaning €150,000 per year or €4,160 per month 
per person. In addition, it is also assumed th at three staff will only work full-time on 
the application during the stages where ther e is likely to be communication between 
the Commission and the applicant, meaning dur ing the assessment of the application, 
the working group discussions and the prep aration of the repor t on the technical 
examination (Steps 2, 3a and 3c). They w ill not work on the application during other 
stages, in particular during the preparat ion of the Commission's proposal and the 
transposition of the amendments into nationa l legislation. (steps 1, 4 and 5). This was 
adopted as the low-cost scenario. 
                                                 
21 According to CIRFS/BISFA, co mpanies undertake no additional work  during the period when the 
amended Directives are being transposed by the Member States. 
 
EN 23   EN Table 5.4 below sets out the average costs of staff working on a fibre, for both the 
low and the high cost scenarios. 
Table 5.4: Average Cost of Staff Working on a Fibre 
 Low Cost Scenario  High Cost Scenario  
Average cost per man-hour  of staff working on fibre  €25 €50 
Average cost per man-day  of staff working on fibre1 €200 €400 
Average cost per man-month  of staff working on 
fibre2 € 4,166 € 8,333 
Average cost for 3 staff per month3  €12,500  €25,000  
Average cost for 3 staff per year  €150,000  €300,000  
Average cost for 3 staff over 3 years  €450,000  €900,000  
1. Based on an 8-hour working day 
2. Based on a 21-day working month  
3. In practice, industry has suggested that this re presents the costs of one to three staff. It could 
therefore represent one very senior manager or t echnical expert; three “middle level” administrative 
staff, or any number of permutations of these. Based on the limited data available, there is no sound 
basis to allocate the costs between them.  
Applying the average monthly cost of €12,500 and €25,000 to the number of months 
required for each step of the current applic ation process (Option 1) (as set out in 
Table 5.1), the administrative costs for industry under both the low and high cost 
scenarios are illustrated in Table 5.5. This shows costs ranging from €100,000 to 
€300,000 per application under the low cost scenario  and costs ranging from 
€600,000 to €1,350,000 per application  for the high cost scenario . 
Table 5.5: Administ rative Costs to Industry per Applicat ion Associated with the Application 
Process - Low Cost and High Cost Scenario  
Low Cost Scenario1 High Cost Scenario2  Steps in the Application 
Process Lower Bound Upper Bound Lower Bound Upper Bound 
Step 1 - Submission  - - - - 
Step 2 - Assessment  € 12,500 € 37,500 € 25,000 € 75,000 
Step 3a - Working Group  € 75,000 € 225,000 € 150,000 € 450,000 
Step 3b - JRC & Ring Trials  - - € 225,000 € 375,000 
Step 3c - Working Group  € 12,500 € 37,500 € 25,000 € 75,000 
Step 4 - Draft Proposals - - € 25,000 € 75,000 
Step 5a - Directive Amended - - € 150,000 € 300,000 
Total  € 100,000 € 300,000 € 600,000 € 1,350,000 
1. Assumes three staff work full-time throughout steps 2, 3a and 3c, at a total cost of €12,500 per 
month  2. Assumes three staff work full-time throughout steps 2 to 5a, at a total cost of €25,000 per month  
The Lower and Upper Bound represent costs associated  with each step in the “best-case” and “worst-
case” scenarios respectiv ely for Option 1 (as set out in Table 5.2) 
Under both the high and low cost scenar ios, reducing the time taken for the 
application process will reduce the administrative burden on industry.  
Tables 5.6 and 5.7 show the impact on the administrative costs of the different 
timescales for the application process (fro m Table 5.1) under the low and high cost 
scenarios. 
Table 5.6: Administrative Costs to Industry per Application1 Associated with Different 
Timescales for Application Pro cess – Low Cost Scenario  
Options  Best Case 
(Months)  Worst Case 
(Months)  Lower  
Bound (€) Upper  
Bound (€)  
Option 1 8 24 € 100,000 € 300,000 
Option 2.1 8 24 € 100,000 € 300,000 
 
EN 24   EN Option 2.2 5 12 € 62,500 € 150,000 
Option 2.3 5 15 € 62,500 € 187,500 
Option 2.4 5 11 € 62,500 € 137,500 
1. Assuming three staff work full time at a cost of €12,500 per month throughout steps 2, 3a and 3c. 
 
Table 5.7: Administrative Cost s to Industry per Application1Associated with Different 
Timescales for Application Process – High Cost Scenario  
Options  Best Case 
(Months)  Worst Case 
(Months)  Lower  
Bound (€) Upper  
Bound (€)  
Option 1 24 54 € 600,000 € 1,350,000 
Option 2.1 24 54 € 600,000 € 1,350,000 
Option 2.2 21 42 € 525,000 € 1,050,000 
Option 2.3 18 39 € 450,000 € 975,000 
Option 2.4 18 33 € 450,000 € 825,000 
1. Assuming three staff work full time at a cost of €25,000 per month throughout the application 
process. 
As explained before the costs associated wi th the research and development of a new 
fibre are not influenced by the process of approval of a new fibre name and therefore 
they are not included in the impact a ssessment. However, in addition to the 
administrative costs, applicants also face costs in developing test methods for the quantification and identification of the new textile fibre in order to enable market 
surveillance authorities to assess if the info rmation provided in a textile label is in 
conformity with the content of the textile or clothing product bearing the label.  
Discussions with CIRFS/BISFA  indicate that administra tive costs account for around 
60% to 80% of total costs of supporting an  application, with test development 
accounting for the remaining 20%  to 40%. In order to reduc e the potential number of 
combinations between administrative costs a nd testing costs, we have considered in 
this report that, in the lower bound of  both low and high cost scenarios, 
administrative costs account for 80% of the total costs and testing costs account for the remaining 20%. In the upper bound, admini strative costs account for 60% of the 
total costs and testing costs account for the remaining 40%. 
The rationale for these assumptions is th at the lower bound show s the costs of the 
best cases in terms of time taken (more rapi d) in the application process as explained 
in section 5.2, probably invol ving an easier and less cost ly testing work. It was 
assumed that the opposite situa tion occurs in the worst cas es (more time taken in the 
application process). 
On this basis, for Option 1, industry cost s in developing test methods could range 
from €25,000 to €200,000 for the low cas e scenario and €150,000 to €900,000 for 
the high cost scenario, per applicat ion, as illustrated in Table 5.8. 
Although the test development co sts have been derived from the administrative costs, 
these test development costs are assumed to be fixed costs which will not necessarily 
be affected as a result of the shorter time periods under any of the policy options. Hence, the testing costs derived for Option 1 are applied to all Options.  
The test development costs could be increas ed, if further testing is required during 
the technical examination stage, as shown in table 5.8 below. Based on the 
 
EN 25   EN experience with recent applications for new fibre names, which have generally 
required additional technical information, im plying further testing, the hypothesis of 
a 50% increase was retained. This would im ply additional test development costs of 
€12,500 to €100,000 for the low cost scenar io and €75,000 to €450,000 for the high 
cost scenario, as part of the additional work during the technical examination step. 
Table 5.8: Calculation of Industry Test Development Costs  
Low Cost Scenario High Cost Scenario  
Lower 
Bound Upper 
Bound Lower 
Bound Upper 
Bound 
Option 1 - Administrative costs1  €100,000 €300,000 € 600,000 € 1,350,000 
Total administrative and test 
development costs  €125,0002 €500,0003 €750,0002 €2,225,0003 
Test development costs4  € 25,000 € 200,000 € 150,000 € 900,000 
Additional testing costs5 € 12,500 € 100,000 € 75,000 € 450,000 
1. Administrative costs taken from Table 5.5.  
2. Lower Bound assumes that administrative costs acc ount for 80% of the total costs of preparing an 
application. 
3. Upper Bound Assumes that administrative costs acco unt for 60% of the total costs of preparing an 
application. 
4. Calculated from total costs minus administrative costs. 
5. Assumes an additional expenditure of 50% of test development costs if further testing is required 
during the technical examination. 
5.3.2. Costs and Benefits of Op tion 1 (baseline scenario) 
Industry 
On the basis of the assumptions set out a bove, the administrative and testing costs to 
a company under the current process range from €137,500 , in the case of the less 
time consuming application process,  to €2.7 million  per application , in the worst 
case on time taken in the appl ication process, as shown in Table 5.9 below. The top 
end of this range appears to be quite high based on information provided by one 
company, which had spent €2 million so far in  tests, research and development and 
submissions relating to a fibre (the estimates shown in table 5.9 do not include research and development costs as these are incurred before an application is made). 
 
Table 5.9: Administrative and Testing Costs to Industry per Application of Option 1  
Low Cost Scenario High Cost Scenario 
 Lower 
Bound Upper Bound Lower 
Bound Upper Bound 
Administrative costs € 100,000 € 300,000 € 600,000 € 1,350,000 
Test development costs € 25,000 € 200,000 € 150,000 € 900,000 
Further testing during 
technical examination 
(where necessary) € 12,500 € 100,000 € 75,000 € 450,000 
Total  € 137,500 € 600,000 € 825,000 € 2,700,000 
Assuming that the current rate  of applications continues, at around 1 per year, the 
total annual costs to industry  (undiscounted) would be €137,500 to €2.7 million  
per application . Assuming a 4% discount rate for costs incurred in future years 
gives total costs to industr y over ten years of between €1.25 million to €25 million . 
The main benefit  to industry of having a new textile name is the marketing value. 
CIRFS/BISFA has suggested th at a new textile fibre with  a new generic name can 
generate an extra €100,000 to €1 million in revenue in its first year, rising to 
 
EN 26   EN €500,000 to €2 million in the second year. This gap between potential revenues is 
explained by a smaller or wider use of the new fibre as a result of its own success or 
of being a speciality fibre with a niche market as compared to a commodity fibre benefiting from a mass market. Because of un certainties over the timing of revenue 
increases, it was assumed that annual be nefits per fibre per year will range from 
€100,000 to €2 million. If such benefits accr ue over 10 years (based on discussion 
with CIRFS/BISFA) and a 4% discount rate ap plies, this gives benefits of between 
€910,000 and €18.2 million per fibre.  This indicates that the benefits of Option 1 
significantly outweigh the costs. 
Sales of some new fibres which were give n new generic names recently have been in 
the region of €10 million to €50 million; although this level of sales depends on timing and other business factor s. It also depends on whet her the new fibre is being 
marketed as a speciality fibre or a commodity fibre. Most fibres with new generic names start off as speciality fibres, with the hope that they can become a commodity 
fibre in future. A whole new business unit can be  a spin-off as a result of this change.  
Consumers 
The main benefit to consumer s of Option 1 is that it pr ovides certainty that the 
named fibres contained within textile products  meet specified characteristics and that 
Competent Authorities have a basis for testin g textile products to ensure that they 
contain the named fibres. This benefit could not be quantified, as none of the 
consumer organisations contacted is activ ely working on the issu e of textile fibre 
names. 
However, this benefit will apply equally to all Options with the only difference being 
in how quickly the benefit is realised; th e lack of quantifica tion therefore does not 
affect the relative costs a nd benefits of the Options. 
Public Authorities 
The costs to the Commission of Opti on 1 are estimated at approximately €300,000 - 
€400,000 per application . According to JRC, ring tests cost around €120,000 while 
other activities undertaken on behalf of th e Commission involving the full laboratory 
analysis of the new textile fibre cost around €250,000. In addition, meetings of the Committee on Textile Names and Labelling are likely to cost around €15,000 for the 
travel expenses of participants, plus the costs of the room and translation facilities, provided by the Commission. Assuming a 4% di scount rate, this gives total costs to 
the Commission over ten years of between €2.7 million to €3.6 million . 
There are also staff time costs to Compet ent Authorities in the EU-27 in attending 
meetings of the Working Group and the Co mmittee and costs to national experts in 
attending meeting(s) convened by the JRC. The scale of these costs will depend on 
the number of meeting days and the cost pe r day of Competent Authority staff. As 
these factors are unlikely to vary signifi cantly between the Options, they are not 
discussed further. 
5.3.3. Costs and Benefits of Option 2.1 
Industry 
 
EN 27   EN The costs to industry under this sub-option will be the same as those under Option 1 
(shown in Table 5.9), as there is no change to the application process, only removal 
of the process of transpositi on of amendments to the Directives into Member State 
national laws. 
There would also be no administrative cost  savings to industry from completing the 
process of adding a new fibre name one year  earlier, as there is no administrative 
activity during tr ansposition.  
There is a benefit to industry from this opt ion related to the adva ntage of being able 
to market a fibre with a new name one year earlier.  
CIRFS/BISFA has indicated that delays in  the time taken in granting a new fibre 
name could result in companies:  
– facing a longer gap between investment in the fibre and realisation of profit; 
– realising a reduced period of patent prot ection due to the delay between filing and 
being able to take advantage of a patent for marketing; and  
– losing time which could have been used in  the creation of mark et awareness with 
corresponding premium price se tting (i.e. obtaining extra margins for a fibre with 
a new generic name).  
According to CIRFS/BISFA, the main bene fit of speeding up the process is the 
support which is given to the marketing st rategy of the compa ny which has applied 
for the fibre name. For instance, for one of  the fibres (currently going through the 
process), the company involved is not ma nufacturing any other fibre. The whole 
business is, therefore, dependent on the success of this fibre. This may not be the case for other companies, but whole business units or sections ma y be dependent on 
the time it takes a certain fibre to get to market. Speeding up the process, therefore, enables a company to strengthen its position overall 
In the absence of detailed information, two scenarios have been used to estimate the 
potential losses which might arise from dela ying the placing on the market of a fibre 
with a new name, and thus the bene fits of reducing such delays:  
– Scenario 1  assumes that the only impact of a de lay is to increase the time between 
investment in the fibre and the generation of revenues (of €100,000 to €2 million per year); there is no reduction in the overall revenue  from the fibre. Table 5.10 
sets out the first-year benefits of avoi ding a one-year delay in  receiving revenues 
(assuming a 4% discount rate) for different annual revenue values. These benefits 
range from around €4,000 to €77,000 per fibre . Assuming the current rate of one 
new fibre per year continues, the total be nefits incurred by industry over a 10 year 
period from avoiding the one -year delay are between €35,000 and €700,000 (at 
4% discount rate). As a conservative estim ate, only the first-year benefits have 
been included. This reflects the signifi cance to companies of avoiding a year 
where costs are incurred but no benefits  are received (therefore, the company 
might incur borrowing costs). These first-ye ar benefits will ar ise over the 10-year 
time period for analysis, as each fibre is pl aced on the market. Thus, an alternative 
approach would be to compare the net pr esent value of the revenue stream for 
 
EN 28   EN each fibre with, and without, a one-year delay. This results in a higher benefit per 
fibre, of £31,000 to £624,000 per fibre . However, the total benefits to industry 
would be difficult to determine, as they  would accrue at different times over a 
total period of 19 years as a minimum (from the start of the revenue stream for the 
first fibre to the end of th e revenue stream for the 10th fibre, assuming that the 
introduction of new fibres is constant at one per year). Note th at this may not be 
the case in practice. The average figure of one fibre per year may relate to two or 
three fibres introduced in a given year followed by no new fibres in the following 
two or three years (consisten t with what currently appears to be the case). As 
assumptions on the timing of these new fibr es coming to market will change the 
present value estimate, it was decided to pr ovide an indication of the benefits in 
relation to one fibre only. 
Table 5.10: Potential Benefits of Avoiding a One Year Delay in Placing a Fibre on the Market – 
Scenario 1 
 Lower Bound Upper Bound 
Annual revenue per fibre  €100,000 €2 million 
First-year benefits per fibre of avoiding a 1 year 
delay in achieving in additional revenue 
(discounted at 4%) € 3,846 € 76,923 
Total first year benefits to industry over 10 years 
of avoiding a 1 year delay in achieving additional revenue for 10 fibres (discounted at 4%) €35,041 €700,837  
– Scenario 2  assumes that the delay in placing the fibre on the market results in a 
loss of one year’s revenue; this could occu r, for example, if the period of sales 
under patent protection is one year shorter.  In this case (Table 5.11), the benefits 
of reducing delay by one year would be equivalent to one year’s revenue of 
€100,000 to €2 million per fibre.  Assuming the current rate, of one new fibre per 
year, the total benefit to industry from a voiding a one-year loss of profits could be 
equivalent to €911,000 to €18.2 million  over 10 years (using a 4%  discount rate).  
Table 5.11: Potential Benefits of avoiding One Year Delay in Placing a Fibre on the Market – 
Scenario 2 
 Lower Bound Upper Bound 
Extra Revenue per Fibre  € 100,000 € 2 million 
Loss from 1 year Delay for the 
first fibre  € 100,000 € 2 million 
Total benefits to industry over 10 
years of avoiding a 1 year delay in 
achieving additional revenue 
(discounted at 4%) € 911,090 € 18,221,792 
The wide gap between the values obtained with scenarios 1 and 2 above do not allow 
an undisputable conclusion. However, it is legitimate to assume that the potential 
direct benefits for industry from avoiding one year delay in pl acing a new fibre on 
the market may be substantial. 
Consumers 
This option would result in no change in th e benefits for consumers of the Textiles 
Directives, but the benefits woul d be brought forward by one year. 
Public Authorities 
 
EN 29   EN Option 2.1 involves replacing the three direc tives on textile names and labelling by 
one (or a series of) regulations. In terms of administrative burden:  
– cost savings are expected for the Co mmission, including the JRC, and the 
Committee on Textile Names and Labelli ng. The Commission may incur savings 
through not having to deal with queries fr om Member States regarding technical 
problems with transposing the legislation and with the checking of transpositions. 
However, there is no real change in  their current res ponsibilities; and 
– cost savings are expected for Member St ate authorities, from no longer having to 
transpose amendments to Directives. Acco rding to information provided in the 
regulatory impact assessment by the UK for the last amendment of the UK textiles legislation
22, the costs of amending current natio nal legislation to implement an 
amended Directive are around £700,000 (around  €1 million). It was not possible 
to obtain details on these costs. However,  even assuming that these costs may be 
lower in most Member States, the benefits  to them of not ha ving to transpose 
amendments to Directives appear to be considerable. 
5.3.4. Costs and Benefits of Option 2.2 
Industry 
Option 2.2 involves adopting new regulation( s) and adding an annex specifying the 
contents of the application file. As indicated  previously in this report, the experience 
with the applications for new fibre names put forward by companies in recent years 
has shown that additional technical inform ation from applicants is always needed. 
Obtaining the required information from the involved enterprises has taken more 
than 12 months in some cases. It is estimated that the submission of a complete or close to complete applica tion file could bring potent ial time savings for Option 2.2 
compared to Option 1 of 3 to 12 months, as indicated in Table 5.2.  
Table 5.12: Administrative Costs of Option 2.2 Compared to Option 1 (details in Tables 5.6 and 
5.7) 
Low Cost Scenario High Cost Scenario 
 Lower 
Bound Upper 
Bound Lower 
Bound Upper 
Bound 
Administrative costs of Option 1 per 
fibre € 100,000 € 300,000 € 600,000 € 1,350,000 
Administrative costs of Option 2.2 
per fibre € 62,500 € 150,000 € 525,000 € 1,050,000 
Cost Saving per Fibre  € 37,500 € 150,000 € 75,000 € 300,000 
Discounted at 4% over 10 years  € 341,659  € 1,366,000  € 683,317  € 2,733,269  
Table 5.12 above shows the potential administ rative cost savings arising from the 
time reduction, for the high and low cost cases. These range from €37,500 to 
€300,000  per application . Assuming that the rate of a pplications remains at one per 
year for 10 years, the total benefit to  industry over 10 years would be between 
€340,000 and €2.7 million at a 4% discount rate. 
                                                 
22 DTI (2006): Full Regulatory Impact Assessment, The Textile Products (Indications of Fibre 
Content) (Amendment and Consolidation of Sc hedules of Textile Names and Allowances) 
Regulations 2006 , UK Department for Trade and Industry, 13th December 2006.  
 
EN 30   EN The industry may save testing costs which re sult from additional testing that has been 
always required by the Comm ission services and Member States national experts in 
the assessment of recent applications. Howeve r, to keep a cautious approach, these 
potential cost savings were not taken into account for Option 2.1. 
The benefits already calculated for Option 2.1 with regard to the 12 months spared 
with the Directives transposition proce ss, therefore avoiding one year delay in 
placing a fibre on the market as shown in  Tables 5.10 and 5.11, would also apply for 
Option 2.2.  
Furthermore, the inclusion of a technica l annex in the regulation describing the 
requirements of the application file (Option 2.2) is considered to bring additional time savings between 3 to 12 months as compared to Option 2.1 (Table 5.2). This shorter timescale would imply further bene fits, estimated in Table 5.13 below. These 
additional benefits could range from around  €1,000 , considering the assumptions of 
scenario 1 in Option 2.1 , to €2 million , considering the assumptions of scenario 2 in 
Option 2.1. These benefits could be equivalent to between €9,100 and €18.2 million  
over 10 years (discounted at 4%).  
Table 5.13: Potential Benefits of Avoiding an Additional 3 - 12 months Delay or Loss of 
Revenue  
 Lower Bound Upper Bound 
Annual revenue per fibre1 €100,000 €2 million 
Scenario 1: Benefits of avoiding a 1 year delay in achieving 
additional revenue (discounted at 4%)1.  € 3,846 € 76,923 
 
Scenario 2: Benefits of avoiding a 1 year delay in achieving 
additional revenue (discounted at 4%)1 €100,000 €2 million 
Scenario 1: Delay in Revenue 
Additional benefits of a further 3 month reduction in the 
time taken to achieve revenue2 €962 €19,230 
Additional benefits of a further 12 month reduction in the time taken to achieve revenue  € 3,846 € 76,923 
Scenario 2: Loss of Revenue  
Additional benefits of avoiding loss of 3 months revenue2 €25,000 €500,000 
Additional benefits of avoiding loss of 12 months revenue €100,000 €2 million 
1. See Tables 5.10 and 5.11. 
2. Calculated as 25% of benefits of avoiding a one-year delay 
CIRFS/ BISFA is of the opinion that the long timescale of the cu rrent process cannot 
be blamed on unclear guidance and, therefor e, that this Option would not result in 
additional savings compared to Option 2.1. CIRFS/BISFA considers that the current 
guidance is quite clear, but, as  with any other type of guida nce, there is always scope 
to provide further support, whether by the Commission or BISFA. The practical 
reality is that companies do not submit a pplications on a regular basis for a new 
generic name and, as such, they are always  going to be relativ ely inexperienced in 
preparing a dossier (without  some additional help). However, CIRFS/BISFA has 
later (July 2008) suggested that an a nnex containing technical guidance would 
provide helpful support to applicants. The JRC considers that clear guidance would 
significantly help both appli cants (who would clearly know  what information they 
have to provide) and the JRC (which would receive much more complete 
information).  
The JRC indicates that the aspect of appli cations which would benefit the most from 
such guidance is the part linked to analytical methods for identification, 
 
EN 31   EN quantification and characterisati on of new fibres. In its experi ence, this part is rarely 
complete and sometimes missing and never in cludes experimental data to support the 
proposed quantitative methods. This gives the impression that the proposed methods 
have not been fully tested in-house. 
JRC considers that, ideally, the application should cont ain not only a complete 
description of the proposed methods but al so data concerning their development, 
their robustness and their in -house performances, so that when the JRC checks the 
validity of the methods, it would have data  for comparison. Applications should also 
contain the quantitative beha viour of the new fibre with  the already established 
methods. JRC considers that, if the gui dance obliges appli cants to present 
experimental data to support the proposal of new analytical methods, this would 
probably avoid the presentation of inadequa te methods to the JRC as well as time 
wasted in demonstrat ing the inadequacy.  
Consumers 
This option would result in no change in th e benefits for consumers, but the benefits 
would be brought forward by further 3-12 moths compared to Option 2.1. 
Public Authorities 
The Commission may incur some costs from having to prepare guidance for the 
applicants to a new fibre name. These cost s do not imply specific financial expenses. 
They are related to the time required fr om Commission officials to prepare and 
discuss an annex with technical guida nce to include in the Regulation. The 
preparation of a guidance document may take the equivalent of one to two weeks of 
the work of one Commission official, in cluding contacts with  other Commission 
services and with indus try representatives.  
Some additional benefits are expect ed for the Commission from Option 2.2, 
compared to Option 2.1. These may arise from having to place fewer requests for further information to industry as the file s received are in a more complete form. 
This could result in some time savings; how ever, the scale of these cost savings is 
uncertain and cannot yet be quantified. In the long-term, it is likely that the on-going benefits of creating guidance will outweigh the additional one-off costs.  
No additional benefits are expected for Member State authorities, compared to 
Option 2.1. Member States authorities do, however, believe that  creating guidance 
would clarify the requirements and necessary elements of the application and thereby 
shorten the time of the application process. 
5.3.5. Costs and Benefits of Option 2.3 
Industry 
Option 2.3 involves including provisions to esta blish a list of la boratories recognised 
by Member States that possess the capacities to assess an application for a new textiles fibre name. As expl ained before, this option, as  compared to the baseline 
scenario (Option 1), saves time in the assessment and approval of a new textile fibre name. As a result, administrative costs for industry are lower. As shown in Table 
 
EN 32   EN 5.14, the savings in administra tive costs would be between €37,500  (lower bound, 
low cost scenario) and €375,000  per fibre (upper bound, hi gh cost scenario).  
However, industry could incur costs in paying national laboratories to review 
dossiers before an application is made to the Commission for a new fibre name. The 
extent of the costs will depend on the de gree to which tests by national laboratories 
replace those that would curr ently be carried out by industr y, rather than duplicating 
work that industry undertakes. 
In order to provide an indi cation of the costs, it was assumed (based on discussions 
with CIRFS/BISFA) that 10% to 25% of the work on test methods currently 
undertaken by companies will be repeated by laboratories. Accordingly, additional 
costs of 10% were taken into account fo r the lower band of low and high cost 
scenarios and increased costs of 25% we re considered for the upper band in both 
scenarios. Applying these percentages to th e costs of developing test methods, shown 
in Table 5.8, results in an additional cost to industry for the tests duplicated by the 
laboratories of between €2,500 and €225,000 per fibre . 
CIRFS/BISFA, however, does not consider that there would be any extra costs to 
companies from Option 2.3, as it currently  encourages members to make use of 
external laboratories in prep aring their application. Rather , the advantage is that the 
Commission does not spend time and mone y repeating work already done by 
industry. Using national laborat ories might increase the time taken to put together an 
application dossier (Step 0); however, this step is not addressed in this impact 
assessment because is takes place before an application is submitted.  
By using the services of recognised labor atories to prepare an application file, 
applicants will very likely present a complete dossier. Therefore, companies will save the costs incurred on the further testing that has been always needed with recent 
cases during the assessment of the application as a result of the incompleteness of the 
files. These costs range from €12,500 to €450,000. As shown in Table 5.14 below net savings in test development costs c ould fall within a range of between €10,000 and 
€225,000 . 
To sum up, net administrative and test de veloping cost savings would be between 
€47,500 and €600,000 per fibre . Assuming that the rate of applications remains at 
one per year for 10 years, the total bene fit to industry over 10 years would be 
between €432,000 and €5.5 million (at a 4% discount rate). 
Table 5.14: Cost Savings to Industry of Option 2.3 compared to Option 1 (per application)  
Low Cost Scenario High Cost Scenario 
 Lower 
Bound Upper 
Bound Lower 
Bound Upper 
Bound 
Administrative Costs  
Administrative costs of Options 1and 
2.11  € 100,000 € 300,000 € 600,000 € 1,350,000 
Administrative costs, Option 2.31 € 62,500 € 187,500 € 450,000 € 975,000 
Savings in administrative costs2 € 37,500 €112,500  € 150,000 € 375,000 
Test Development Costs  
Current test development costs (Option 
1)3 € 25,000 € 200,000 € 150,000 € 900,000 
Additional cost of repeating tests4  € 2,500 € 50,000 € 15,000 € 225,000 
Savings from not repeating tests during € 12,500 € 100,000 € 75,000 € 450,000 
 
EN 33   EN Table 5.14: Cost Savings to Industry of Option 2.3 compared to Option 1 (per application)  
technical examination3 
Savings in test development costs 
(savings from non-repetition minus 
additional costs from repeating tests)  €10,000 €50,000 €60,000 €225,000 
Total cost savings (savings in 
administrative costs plus savings in test 
development costs)  € 47,500 €162,500 €210,000 €600,000 
Discounted at 4% over 10 years € 432,768 € 1,480,521 € 1,913,288 € 5,466,537 
1. From Tables 5.6 and 5.7.  
2. Current administrative costs (Option 1) minus administrative costs under Option 2.3  
3. From Table 5.8: additional testing costs.  
4. 10% duplication – lower bound; 25% duplication – upper bound 
As indicated for Option 2.2 above, the benef its already calculated for Option 2.1 with 
regard to the 12 months sp ared with a regulation on th e Directives transposition 
process, therefore avoiding one year delay in placing a fibre on the market as shown 
in Tables 5.10 and 5.11, would also apply for Option 2.3.  
Furthermore, Option 2.3 is estimated to save  between 6 to 15 months as compared to 
Option 2.1 (Table 5.2). This shorter ti mescale would imply further benefits, 
estimated in Table 5.15 below, according to  the approach used in the previous 
options: scenario 1 assumes that the additiona l benefits are the equivalent of avoiding 
a one-year delay in receiving revenues at a 4% discount rate and scenario 2 assumes 
that the additional benefits are the equivalent to one year's revenue. These could range from around €2,000  to €2.5 million  per fibre as shown in Table 5.15 below. 
These benefits could be equivalent to between €18,200 and €22.8 million  over 10 
years (discounted at 4%).  
Table 5.15: Potential Benefits of Avoiding an Ad ditional 6 - 15 months Delay in Placing a Fibre 
on the Market  
 Lower Bound Upper Bound 
Annual revenue per fibre1 €100,000 €2 million 
Scenario 1: Benefits of avoiding a 1 year delay in achieving in 
additional revenue (4%)1 € 3,846 € 76,923 
Scenario 2: Benefits of avoiding a 1 year delay in achieving in 
additional revenue (4%)1 €1000,000 €2 million 
Scenario 1: Delay in Revenue  
Additional benefits of a further 6 month reduction in the time 
taken to achieve revenue2 €1,923 €38,461 
Additional benefits of a further 15 month reduction in the time 
taken to achieve revenue3 € 4,807 € 96,153 
Scenario 2: Loss of Revenue  
Additional benefits of avoiding loss of six months revenue2 €50,000 €1 million 
Additional benefits of avoiding loss of 15 months revenue3 €125,000 €2.5 million 
1. See Tables 5.10 and 5.11. 
2. Calculated as 50% of benefits of avoiding a one year delay. 3. Calculated as 125% of benefits of a avoiding a one year delay. 
The analysis suggests that using a recognised laboratory to prepar e an application for 
a new textiles fibre name will bring potential benefits to applicants. However, from a legal point of view, applications will always  need to be assessed by the Commission 
services, including the JRC. The report from  the laboratory can not  be granted a legal 
status avoiding any further examination from Commission services and the group of 
Member Sates experts on textile fibre name s. As a result, the use of a recognised 
laboratory by a company should remain on a voluntary basis. 
 
EN 34   EN Consumers 
This option would result in no change in th e benefits for consumers, but the benefits 
would be brought forward by a further 6-15 months compared to Option 2.1. 
Public Authorities 
Some additional benefits are expected for the Commission, JRC and the Working 
Group from this Option. Lower costs will ar ise because the check on the application 
file by a recognised laboratory should reduc e the need to request supporting data 
from the applicant and, possibly, from fewer ring trials being required to validate the 
test methods. If 25% of costs are saved, this could result in  savings of around 
€75,000 per fibre . Assuming that the current rate of  one fibre application per year 
continues, this would result  in cost savings over ten years (discounted at 4%) of 
around €680,000.  
A number of laboratories experienced in the domain of textile labelling and having 
the technical capabilit ies necessary to undertake these tasks already ex ist across the 
EU. Member States may incur some costs in identifying recognised national laboratories; the scale of these costs is, however, limited. In fact, existing accreditation systems may be used for this purpose.  
Most Competent Authorities in the Member  States believe that the creation of 
recognised laboratories w ould improve the quality of applications, create 
competence, result in a shor ter processing time and reduce d processing costs. Some 
Member States raised concerns indicating that:  
– there will be insufficient work for the laboratories . This seems to borne out by 
the best-case projections of two to three fibres a year across the EU;  
– there may be a lack of adequate skills and expertise  to act as an accredited 
laboratory in most Member States. One Member State indicated that it had no 
laboratory which could serve the above f unction (others indicated that they had 
between one and three) while another i ndicated it had only two to three experts 
who were sufficiently knowledgeable rega rding the identifica tion and analysis 
methods for textiles which can be very advanced, e.g. thermal analysis, NMR; 
– laboratories would have different approaches , which may result in a variability 
in applications; and  
– some authorities, however, expressed c oncern at the implications for Member 
States of the extra cost  of identifying recognised laboratories. The laboratories 
would also have to allocate significant resources for the co-operation which would 
be required.  
The JRC considered that the formal creation of a European Network of Public 
Notified Laboratories (enforcem ent laboratories), which would assist the JRC in the 
evaluation of applications and take part  in the validation of new methods and 
coefficients, would be a major benefit. It facilitates the assessment of applications 
and the organisation of ring trials. This ne twork already exists informally (known as 
the European Network of National Experts on Textile Labelling). However, it is not 
officially recognised in the legislation, situation that is sometimes a source of 
 
EN 35   EN confusion with respect to the laboratories that should be part of the network. The 
official creation of such a network is  being explored with Member States 
representatives, on the basis of the existing European Ne twork of National Experts. 
In order to minimise potential costs, the solution being explored with Member States 
representatives considers that, in a first phase, the laboratories that benefit already 
from accreditation are those that would join the network. The work to be carried out 
through the network does not require the pa rticipation of 27 laboratories, meaning 
that all Member States do not need to be  represented. Therefore, it is possible to 
propose a solution that does not oblige Member States to incur in costs in order to 
develop its laboratories capacities at this stage; furthermore, this brings potential new 
customers to existing laboratories. In addi tion, the list of recognised laboratories 
would remain open in order to  allow that Member States indicate furthe r laboratories 
to be part of the network in the future. It should be noted th at the JRC, being a part of 
the Commission, plays an institutional role in the examination of applications and 
should remain independent to av oid any conflict of interests. 
The evaluation of the foreseen regulation, pr oposed to take place af ter 3 to 5 years of 
its entering into force, would assess the results obtained with this solution and 
suggest corrective meas ures if needed.  
5.3.6. Costs and Benefits of Option 2.4 
Industry  
Option 2.4 involves adopting new regulatio n(s) (Option 2.1), adding an annex 
specifying the contents of the application file (Option 2.2) and establishing a list of 
recognised national laboratories (option 2.3) . The costs and benefits calculated under 
Options 2.1, 2.2 and 2.3 are, theref ore, combined under Option 2.4.  
Table 5.16 shows the cost savings of Opti on 2.4 compared to Option 1. It considers 
the administrative costs as presented in Ta bles 5.6 and 5.7, and the cost savings from 
testing resulting from the fact that there would be no need for a pplicants to repeat 
tests as estimated in Table 5.14 for Option 2.3. The total administrative and testing 
cost savings range from €47,500 to €600,000.  Assuming that the rate of applications 
remains at one per year for 10 years, the total benefit to industry over 10 years would be between €430,000 and €5,5 million (at a 4% discount rate). 
Table 5.16: Cost Savings to Industry of Option 2.4 Compared to Option 1 (per Application) 
Low Cost Scenario High Cost Scenario 
 Lower 
Bound Upper 
Bound Lower 
Bound Upper 
Bound 
Administrative costs of Option 11  € 100,000 € 300,000 € 600,000 € 1,350,000 
Administrative costs, Option 2.4 1 € 62,500 € 137,500 € 450,000 € 825,000 
Savings in administrative costs2 € 37,500 € 112,500 € 150,000 € 375,000 
Cost savings from Testing3 € 10,000 € 50,000 € 60,000 € 225,000 
Total Cost Savings  € 47,500 € 162,500 € 210,000 € 600,000 
Costs over 10 years, discounted at 4%  € 432,768  € 1,480,521  € 1,913,288  € 5,466,537  
1. From Tables 5.6 and 5.7.  
2. Current administrative costs (Option 1) minus administrative costs under Option 2.4  
3. From Table 5.14.  
As indicated for Options 2.2 and 2.3, the be nefits already calculated for Option 2.1 
with regard to the 12 months spared with a regulation on the Directives transposition 
 
EN 36   EN process, therefore avoiding one year delay in placing a fibre on the market as shown 
in Tables 5.10 and 5.11, would also apply for Option 2.4. 
Furthermore, as indicated in Table 5.2, the potential time savings for Option 2.4 
compared to Option 2.1 is 6-21 months. This shorter timescale will generate 
additional benefits compared to those s hown for Option 2.1 in Tables 5.9 and 5.10, 
from further reductions to delays in bri nging fibres with new names to market. As 
shown in Table 5.17 below, these could range from around €2,000  to €3.5 million  
per fibre. These benefits could be equivalent to between €18,200 and €31.9 million  
over 10 years (discounted at 4%). 
 Table 5.17: Potential Benefits of Avoiding an Additional 6 - 21 months Delay in Placing a 
Fibre on the Market  
 Lower Bound Upper Bound 
Annual revenue per fibre1 €100,000 €2 million 
Benefits of avoiding a 1 year delay in achieving in additional 
revenue (4%)1 € 3,846 € 76,923 
Scenario 1: Delay in Revenue  
Additional benefits of a further 6 month reduction in the time 
taken to achieve revenue2 €1,923 €38,461 
Additional benefits of a further 21 month reduction in the 
time taken to achieve revenue3 € 6,730 € 134,614 
Scenario 2: Loss of Revenue  
Additional benefits of avoiding loss of 6 months revenue2 €50,000 €1 million 
Additional benefits of avoiding loss of 21 months revenue3 € 175,000 €3.5 million 
1. See Table 5.9 
2. Calculated as 50% of benefits of avoiding a one year delay 
3. Calculated as 175% of benefits of avoiding a one year delay 
Consumers 
This option would result in no change in the benefits for consumers but benefits 
would be brought forward by a further 6-21 months. 
Public Authorities 
Under Option 2.4 (as for Option 2.3) a savi ng of 25% of the costs of JRC would 
provide benefits of around €75,000 to €100,000 per fibre . Assuming that the current 
rate of one fibre application per year con tinues, this would result in cost saving over 
ten years of around €680,000 to €910,000 (discounted at 4%).  
Option 2.4 would also retain the benef its of Option 2.2 for the Commission, from 
having to make fewer requests for further information to industry, as the files 
received are in a more complete form. Memb er States authorities also believe that 
creating guidance would clarify the require ments and necessary elements of the 
application and thereby shorten the time of  the application process. These could 
result in some time savings; however, the s cale of these cost savings is uncertain and 
cannot yet be quantified.  
5.3.7. Costs and Benefits of Option 3 
Option 3 involves a combined regulatory/ non-regulatory approach in which a new 
regulation would contain provi sions currently included in Directive 96/74/EC and in 
which the quantification/test methods w ould be transferred to the domain of 
standardisation (by CEN). 
 
EN 37   EN The key uncertainty with Option 3 is whet her a fibre with a new name could be 
placed on the market during the period when the test method was being converted to a standard. Two potential cases have been  identified. In both cases, the time 
considered for the adoption of the standards by CEN is based on the Unique Acceptance Process as explained in Section 5.2.3: 
– Case A : the work by CEN takes 12 months, but the fibre could be marketed 
during this period; and 
– Case B : the work by CEN to adopt a standard would take 12 months and the fibre 
could not be marketed during this period. 
Industry 
The impact of Option 3 on industry will depe nd critically on which Scenario applies: 
– under Case A , there could be some reduction in the administrative cost savings 
obtained under Option 2, as industry might need to respond to the CEN enquiry 
process. However, as the test method will have been agreed beforehand (Step 3), this additional cost is likely to be minimal. Otherwise, the time savings under 
Option 3.1 will be the same as Option 2.1, Option 3.2 the same as Option 2.2 etc, as industry will not be undertaking any other administrative activity during the 
period of conversion of the test method to a standard, but the benefits would be 
the same as for Option 2; and  
– under Case B , there could also be some reducti on in administrative cost savings. 
The main cost to industry will be the 12 m onth delay in marketing the fibre, which 
would result in the loss of benefits asso ciated with replacing the Directives with 
Regulation(s).  
CIRFS/BISFA indicates that the main be nefit of transferring test methods to 
standards is that there would be a regular revision of th e standards every five years 
by CEN; this would enable prescribed test methods to keep pace with the change in 
test methods in the textile industry. Howeve r, industry is not in agreement with the 
transfer of test methods to the standardisa tion process if this implies further analysis 
by the CEN working groups, further requirement s on testing and further delays in the 
time to bring the fibre to the market. 
Consumers 
Option 3 would not change the overall benefi ts to consumers compared to Option 1. 
Under Case A, the benefits to consumers fr om faster placing of new fibres on the EU 
market under Option 3 would be identical to those under Option 2. Under Case B, there would be a 12 month delay in placing new fibres in the markets, so benefits to 
consumers from this would also be delayed 12 moths compared to Option 2. 
Public Authorities 
There will be costs for CEN and for the 30 National Standardisation Bodies, as all 
CEN members are required to implement the standard (once approved) as their 
national standard. CEN was not  able to provide informa tion so far on the scale of 
these costs.  
 
EN 38   EN Once a test method has been approved by JRC,  there could be costs associated with 
putting the test method into the standard template and editing the document at the 
secretariat and CEN level, prior to the Un ique Acceptance Process. At this point, 
there will also be translation costs. In some countries (the UK, for example), the 
costs for members of CEN Committees an d Working Groups to attend meetings are 
financed partly by Government and partly  by their respective companies, who pay 
their salaries and top up any expenses in curred. Central costs would be borne by 
CEN and the National Standards Body which holds the secretariat of the committee 
or working group.  
It is not expected that there are direct costs to Member State Governments from the 
formal adoption of a European Standard in this domain since the production costs 
should be borne by CEN and the national me mber bodies. The EN standards are also 
translated compulsorily into the official languages: English (by BSI), French (by AFNOR) and German (by DIN). It is up to the other National Standardisation Bodies 
(and not Member States) to translate th e EN standard into their own national 
languages. It is difficult to quantify cost s as it depends on the complexity of the 
standard.  
All CEN standards are reviewed regularly (a  maximum of five year intervals) to 
ensure that they are still up-to-date and of use to indus try and for public enforcement 
purposes. The updating allows for new develo pments to be taken into account, 
changes to regulations, improvements to be made, etc. For example, if any problems are identified with a standard, CEN indicates  that these can be addressed within a 
six-month to one year time period.  
5.4. Impact on Small and Medium Enterprises 
With regard to the potential impacts of the policy options on SMEs, as noted earlier, 
recent applications for new fibre names have been submitted by both large and small firms. CIRFS/BISFA did not consider that there was a difference in expertise 
between SMEs and large firms in making applications for a new fibre name; this process is only undertaken occasionally by any firm, so that none have developed particular experience. However, recent cases show that the application files 
submitted by SMEs have taken longer periods (up to 24 months) than large companies, to complete their applic ations with the re quired information. 
The key difference appears to be that for SMEs the viability of the whole business 
may be more dependent on the time it take s a certain fibre to go to market. For a 
large company, the development of a new fi bre may often be carried out within a 
separate business unit and it appears easier to  accommodate the event of failure or 
time delay. It may therefore be particularly important for SMEs to reduce the time between investment in a new fibre and the ability to market it under a new name. The 
benefits of all the options that result in a reduction in the time taken will therefore be of particular importance for SMEs. 
5.5. Impact on Innovation 
A major potential benefit of reducing the tim e it takes between the submission of an 
application to the Commission and the moment  the new fibre name can be put in the 
market is in supporting innovation. Accord ing to the opinions expressed by the 
 
EN 39   EN industry and the Member States repres entatives, speeding up the process of 
introducing a new fibre name leads to more  new fibres being brought to the market. 
Table 5.18 below indicates the potential be nefits, assuming that three new fibre 
names are adopted per year. The additional potential benefit in terms of revenue 
ranges from €10 million to over €200 million  over ten years.  
Table 5.18: Potential Additional Benefit ov er Ten Years from Increasing the Rate of 
Adoption of New Fibre Names 
Revenue per Fibre  
per year Revenue from One 
New Fibre/year  Revenue from Three 
New Fibres/year Potential Increase in 
Revenue 
€100,000 € 5,110,314 € 15,330,943 € 10,220,629 
€2 million € 102,206,288 € 306,618,863 € 204,412,575 
Discounted at 4% over ten years  
5.6. International context 
The new regulation does not imply any change  compared to existing legislation in 
respect to trade and third countries. Non-EU producers ex porting new fibres to the 
EU are subject to the same requirements as  EU manufacturers, needing to submit an 
application for a new fibre name when nece ssary. On the other hand, if EU producers 
intend to export into third countries, they need to comply with the legislation in the 
country of destiny.  
On the other hand, in spite of ongoing discussi ons at ISO level, there are substantial 
differences in the philosophy for granting ne w fibre names in diffe rent countries of 
the world. This is the reason why in this domain as well as in many other domains of 
ISO activities agreements are not always po ssible rapidly and may take many years. 
Public authorities in the EU  often introduce modifications in the proposed names and 
definitions (as described under point 4.1 above). Other countries follow less strict approaches which result on the one hand on the approval of fibre names close to 
brand names (according to the opinion of EU  Member States representatives and of 
the Commission services) and on the other ha nd on the approval of definitions that 
are not correct providing consumers with information that is not totally exact. 
6. CONCLUSIONS 
6.1. Changing the three Directives on Textile  Names into one Regulation (Option 
2.1) 
The results of the analysis show that ch anging the three Textile Names Directives 
into one Regulation brings benefits to the economic operators and to the public 
administrations, in particul ar the EU Member States. 
The Regulation will allow putting a new fibre name in the market 12 months before 
the time needed under the current situation,  as a result of the fact that the 
transposition of the Directives introduci ng new fibre names will no longer be needed. 
The benefits for the industry may be substa ntial if the benefits of reducing delay by 
one year would be equivalent to one y ear’s revenue, which is estimated to be 
between € 100,000 and € 2 million per fibre. 
 
EN 40   EN Furthermore, it appears that the benefits are more important to small and medium 
enterprises due to the fact that the viabi lity of a SME business will be enhanced by 
time savings in putting new fibres in the market. 
In addition, according to the opinions e xpressed by industry and Member States 
representatives, it is likely that speedi ng up the process of in troducing a new fibre 
name leads to more new fibres being brought to the market, result ing in considerable 
potential additional benefits for industry. These may be between around €10 million and €200 million over a 10 years period if th ree new fibres were adopted per year. 
With respect to the public authorities, the mo re significant gains expected result from 
cost savings for Member States from no longer having to transpose amendments to Directives. 
According to information provided in th e regulatory impact assessment by the UK 
for the last amendment of the UK textiles legislation
23, the costs of amending current 
national legislation to implement an amended Directive are around £700,000 (around 
€1 million). Even assuming that these cost s may be lower in most Member States, 
the benefits would be considerable. 
6.2. Providing further guidance to applican ts for a new fibre name (Option 2.2) 
Companies do not submit applications on a re gular basis for a new generic name and, 
as such, they are always going to be relatively inexperienced in preparing an 
application file. Further guidance is certain ly more important for SMEs which do not 
possess the same technical and fina ncial resources as large firms do. 
Providing an annex to the Re gulation containing a more  developed guidance on the 
technical requirements of an application fi le brings a potential reduction of 3 to 12 
months in the time needed to assess the application by public authorities. This 
reduction has the potential to save co sts to industry of between €37,500 and 
€300,000. 
Additional benefits for industry are to be expected from a further reduction in the 
time taken to achieve revenue. These benefits  may be significant, in particular when 
a reduction of 12 months is considered, reaching around € 2 million per fibre in the 
scenario where they are estimated as the e quivalent of the loss of a one year revenue 
for the more successful fibres. 
Time savings resulting from the submission of a more complete application file are 
to be expected for public authorities, in cluding Commission serv ices and experts in 
the Member States, involved in the assessment of applications for a new textile fibre 
name. 
The inclusion in the regulati on of an annex containing guida nce to applicants gathers 
the support of stakeholders and Member States. 
                                                 
23 DTI (2006): Full Regulatory Impact Assessment, The Textile Products (Indications of Fibre 
Content) (Amendment and Consolidation of Sc hedules of Textile Names and Allowances) 
Regulations 2006 , UK Department for Trade and Industry, 13th December 2006.  
 
EN 41   EN 6.3. Creating a network of recognis ed laboratories (Option 2.3) 
The creation of a network of recognise d laboratories looks for achieving two 
objectives: 
– To encourage applicants for new textile fibre names to make use of recognised 
competent laboratories in orde r to ensure that the application file is close to 
completeness; 
– Making official the informal European Network of National Experts on Textile 
Labelling, which assists the JRC in the t echnical assessment of application files, 
in order to facilitate and clarify the organisation and working relations of the 
informal network. 
The analysis indicates that industry could obtain total administra tive and testing cost 
savings per fibre between €47,500 and €600,000 a nd additional bene fits that could 
reach €2.5 million resulting from a reduction of 15 months in the time needed to assess the application, in th e scenario where those benefits are estimated as the 
equivalent of the loss of a one year revenue for the more successful fibres. 
However, the Commission services w ill always need to produce their own 
assessment to submit to the Member States authorities in the framework of the legal 
procedure to adopt a new fibre name. The r ecognised laboratory report can not have 
a legal status avoiding the mentioned assessment. This is particularly the case when a ring trial is needed and, in any case, the name proposed for the fibre and the 
definition of the fibre have to be approved within the comitology procedure. Therefore, the use of recognised laborat ories by applicants for new fibre names 
should remain on a voluntary basis. In addition, the JRC could not fulfil the role of a recognised laboratory because it will be called to produce the technical assessment 
on behalf of the Commission services and needs therefore to avoid any potential 
conflict of interest. 
It is estimated that the improvement of th e quality of the applications resulting from 
its submission to a competent laboratory before the official presentation to the Commission could reduce by 25% the costs i nvolved with the technical examination 
by the Commission services, representing around € 75,000 per fibre. 
However, it was not possible to assess at this stage the potential costs for Member 
States of participating in the creation of  such network of recognised laboratories. 
These costs may be low if the laboratorie s to include in th e network are those 
benefiting already from official accredit ation to fulfil the tasks required by the 
examination of an application for a new textile fibre name. Laboratories with the 
technical capabilities and experience in th is domain already exist in numerous 
Member States; therefore, this solution doe s not oblige Member States to incur in 
additional costs to create new laboratori es or buy new laboratory equipments. In 
addition, the current needs of the JRC with  the organisation of the fibre assessment 
process, including possible ring trials, do not require 27 laboratories. Therefore, it is 
not crucial that all Member States indi cate at least one recognised laboratory. In 
conclusion, the participation in the netw ork should be established on a voluntary 
basis. Member States should have the possi bility to indicate r ecognised laboratories 
at any point in time. The evaluation to be carried out within a pe riod of 3 to 5 years 
 
EN 42   EN after the entering into force of the Regul ation should assess the results of this 
solution. 
6.4. Providing further guidance and creating a network of recognised laboratories 
(Option 2.4) 
This option provides to industry total admini strative and testing co st savings per fibre 
between €47,500 and €600,000, identical to th ose obtained with option 2.3. On the 
other hand, putting together an annex with guidance for applicants, which will also 
inform laboratories on the tasks to be  fulfilled, and a network of recognised 
laboratories has the potential to further save time and thus achieve additional benefits 
from bringing the new fibre na me earlier to the market.  
Choosing option 2.4 needs to take into cons ideration the constr aints described in 
section 6.3, namely the voluntary basis for using laboratories by industry and for the 
participation in a possible official network.  
6.5. Testing methods transferred to the do main of standardisation (Option 3) 
The key issue surrounding the current regulatory framework, for both public 
authorities and industry, is the time taken between the initial application for a new 
fibre and its legal adoption across the EU, in particular with resp ect to the technical 
examination and the transposition of the amendments into national legislation. 
Transferring testing methods to  the domain of standardisat ion is an option only if it 
does not compromise the time gained w ith the possible changes to the current 
legislation examined in Options 2.1 to 2.4. 
On the other hand, Option 3 does not appear to bring additional financial benefits 
when compared to Options 2.1 to 2.4. 
Member States and industry agree that pa ssing the testing methods to standardisation 
instead of including them in the legislati on has the advantages of allowing routine 
revisions carried out by the European Committee for Standardisation (CEN) every 5 years. 
However, it needs to be taken into cons ideration that CEN is  an independent body. 
For the purposes of this report it was assumed that the lighter CEN procedure 
(Unique Acceptance Process), which takes around 12 months, could be adopted with 
respect to textile fibre testing methods . But the debates that took place with 
stakeholders and Member States represen tatives have shown that cases where CEN 
members may require a full examination with in the classical CEN procedure to adopt 
standards can not be excluded. This proced ure may take 3 to 5 years. Industry and 
Member States oppose changes that may impl y the risk of increas ing the time needed 
to bring a new textile fibre to the market. 
In addition, the CEN standardisation proce ss implies costs. Unfo rtunately, it was not 
possible to obtain estimates from CEN on th e potential costs that could be associated 
with the textile fibr e testing methods. A part of t hose costs is supported often by a 
Commission financ ial contribution. 
It is therefore planned not to involve sta ndardisation in the process of adoption of 
testing methods for textile fibres at this stage. Further contacts with CEN, Member 
 
EN 43   EN States and stakeholders should be deve loped during the implementation of the 
foreseen regulation to assess the feasibility of a future taken up by standardisation of 
the textile fibre testing methods. The legal possibilities of involvi ng CEN in the fibre 
analysis procedure at a very early stage will be examined as well as the possibility of 
ensuring that a standard may be adopted by CEN within a timeframe that does not 
exceed the time period needed to assess the request for a new fibre name. This 
assessment should be consider ed together with the report on the implementation of 
the foreseen regulation after 3 to 5 years of entering into force. 
7. MONITORING  AND  EVALUATION 
The proposal, once adopted, is going to be implemented in close cooperation with all 
stakeholders concerned. To this en d, the Committee and the Working Group on 
Textile Names and Labelling have provided for a valuable forum in the past and 
would be used in the future. 
Evaluation of the policy will look into the ability of the regulatory environment for 
textile products to encourage fibre innovation. In particular, the evaluation will focus on the effectiveness of the new regulation to simplify the procedure to adapt EU 
legislation and speed up the process to add a new fibre name to its  technical annexes. 
After three/five years of entry into fo rce, the Commission, in cooperation with 
Member States and stakeholders, will assess: 
– The number of amendments to add new fibre names to the regulation; 
– The completeness of the information s ubmitted in the technical files of the 
applications for new fibre names; 
– The number of applicants which made us e of recognised laboratories to examine 
and complete the technical file; 
– The time needed to examine the applica tions submitted in accordance with the 
new rules. 
The Commission will make the results of  this evaluation publicly available.  
Further discussions with CEN will take place in the framework of the meetings of the 
Working Group on Textile Names and Labelling to gather information to assess whether standardisation would be an appropriate approach in the future. 
 
EN 44   EN ANNEX 1 – Summary of consultation responses  
Summary of Responses by Competent Authorities 
General Questions 
(1) Only a few applications for new textile fibr e names have been made per year over the 
last five years. What is your view on the likely numbers in the future - e.g. two per 
year over the next three years, incr easing to five a y ear thereafter?  
If the Directives are adjuste d, more new fibres probably will  be adopted in future. Final 
structure and philosophy are impor tant for another fibre names. 
The rate of applications for new textile fibr e names per year might be the same in the 
future as it was duri ng last five years. 
The numbers may slightly increase 
Not more than three per year 
Three per year over one year and probab ly two or three per year thereafter 
One application every two years 
It is hard to asses, but co uld rise to three per year 
No, it won’t be more than before 
Probably no more than 2 per year 
(2) How often do companies approach you as a Member State Competent Authority with 
an application for a new fibre name? (Please tick the answer that applies to you)  
Yes  0 No  10 
(3) Has a company have ever requested that you provide it with a pr eliminary designation 
for a new fibre name so that they can mark et a fibre while the application for a new 
name is being considered? (Please tick the answer that applies to you)  
 Yes No 
Have your received a request for a preliminary designation? 0 10 
Was a preliminary designation provided? 0 10 
Did the company market the fibre under this preliminary name? 0 10 
(4) What do you see as the key bottlenecks with in the current procedures for reviewing 
and granting approval to an a pplication for a new fibre name? 
Long time for evaluation and development of proper analytical method are main reasons 
for long duration of adopting of a new text ile name. If new analytical methods are 
prepared (e.g. as EN standard) more types of fi bers will be analysed in future. It’s very 
important for adopting of new materials. All steps of evaluati on of new fibre are 
necessary but the long time and of course c onsequent administrative  delays are issues. 
Too long and complicated administrative procedure. 
The quality of applications. L ack of appropriate test methods . The procedure is slow and 
 
EN 45   EN cumbersome. 
Verification and validation of methods for quan tification of new fibres in mixtures with 
other fibres. Lack of time lim it to release of official de cision of European Commission 
Too long method validation period. 
The agreement between the representatives fo r establishing the name , the definition, the 
properties if the new fibre and all the othe r information necessary for identifying the 
new fibre and making different  from the existing fibres. 
We haven’t received any request  for designation of new fibre. 
Technical approval / Valid ation of test methods. 
The verification of the proposed method is the most problematic point in the procedure. 
It needs a long time and sometime  very special instruments. 
(5) What are the key issues that your Member State faces in transposing amendments to 
the current Directive into your national legislation? 
For adopting of a new agenda it’s generally important to translate all details properly 
using equivalent technical terminology. Adopti ng of new legislation as “Regulation” is 
legislatively easier and can be issued duri ng short time on nationa l level. Testing (or 
measuring) methods generally are not very suit able for Directive. EN standard is more 
practical. 
Too many amendments in relevant national legislation, high admini strative burden, short 
time limit for the transposition and implementation. 
We try to make it as simple as possible 
The procedure is not complicated. 
The considerable time period required between the date of application of the regulation 
draft and the approval of it. 
We have to transpose the amendment of the Directive with the amendment of the 
national Rules, which transpose the directive into national legislation 
Amendments need to be implem ented into domestic law. We have made provision in our 
law that the relevant annexes to the Dire ctives (annex I and II ) listing new textile 
product names and test methods take effect in national law as they are amended from 
time to time. If there are amendments to th e Directive text other than the relevant 
Annexes we will need to make implementing regulations and provide an impact assessment of the costs to business and the public sector of the amendments to Parliament for consideration along with the re gulations. We need to provide up to date 
information on the current regulatory pos ition and do so by means of updating our 
relevant government website as necessary to make stakeholders, including 
manufacturers and enforcement aut horities aware of the changes.  
(6) How long does transposition generally take and what is the administrative burden? 
Time taken for 
transposition (months) • About a year 
• 6 -9 months 
• 3-6 months 
• At least 3-4 months, sometimes more 
• Approximately 1 month 
• 12 months 
 
EN 46   EN • 9-12 months 
• 3 -4 months 
• 6 months 
Administrative 
burden (person-days) • 1-2 hours a day/ a person/a year 
• 1 - 2 days/one person (in addition to legislative control 
activities) 
• 20 days 
• It is difficult to answer precisely this question  
• One person is responsible for this  work. It is complicated to 
define accurately how long it takes 
• It depends on the amendment (20 -100 persons per day) 
• 10 days  
If amendments are to annex I and II, then as indicated in answer 
to 5, such amendments take effect in domestic law immediately they come into force as provi ded under current legislation.  
If new implementing regulations are required, then depending 
on whether a 12 week consultation period is required relating to 
the method of implementation etc, transposition could take upwards of 25 weeks. The government also wishes to allow for a 12 week period for business to adapt to the new provisions before they come into for ce where this is possible.  
The administrative burden lies in consulting with stakeholders, 
drawing up a consultation document, drafting regulations, impact assessment, considering consultation responses, amending draft regulations, making and laying regulations before Parliament together w ith supplementary memoranda and 
transposition notes. This could be up to 10 person days. 
Guidance on Developing Application Files 
One of the options being considered by the Commission is for more formal guidance on the 
contents of an application file  to be developed. This guidance would then be in cluded in the 
revised legislation as an Annex, providing a clear indication of wh at is required of these files 
for decision making purposes.  
(7) In what percentage of cases do you consider that applicants  have provided inadequate 
information within their application files? 
We do know 
No experiences in this field 
In most cases 
We haven’t before received any appli cation files so it’s hard to predicate 
As I guess it take around 30% 
Not more than 5% 
We don’t have any experience yet 
50-75% 
 
EN 47   EN (8) In your experience, what aspects of appli cations would benefit the most from such 
guidance?  
Guide for producers describing procedures of adopting of new fibers would be helpful 
and supporting. All information would be collected  before starting of legislation process. 
Following steps then can be faster.  
No experience in this field. 
The applications would already contain all relevant pieces of  information if guidance is 
followed. 
Requirement of providing quantification method s of new fibres in mixtures with other 
fibres. Requirement of provi ding proper new fibre samples to finalised procedure for 
verification and validat ion of new methods. 
It would clarify the requiremen ts, what are the necessary elements of the application. A 
detailed explanation is needed that the quality of application will be appropriate. 
Will shorten the time of the procedure for the application. 
Fibre identification – chemical formula,  differences from the existing fibres. 
Identification and quantitative analysis methods  for representative mixt ures of fibres of 
the new fibre and the existing ones. 
Advices regarding fibre destination a nd impact assessment on the consumer. 
Methods of analysis and identification. 
(9) Do you believe that the existence of formal application guidance would speed up the 
approvals process? 
Yes  9 No  0 
(10) Do you think it would also result in cost sa vings? If so, what costs would be reduced 
and by how much?  
Yes  9 No  0 
What costs would be 
reduced? • Travelling cost (for exampl e for meetings of Working 
Group on Textile Names and Labelling – possibly e-mail 
communication)  
• Processing costs 
• Particularly work of the Commission and JRC 
• The costs of validation and examination 
• Cost of JRC in Ispra 
• The costs for evaluation by an accredited laboratory of the 
proposed methods 
• The costs for expert meetings. 
• Reduced meetings 
What would the value 
of the cost saving be? • It is difficult to answer precisely this question 
• Considerable  
• It is difficult to answer precisely at this stage 
• It’s difficult to predict 
• We don’t have any experience. 
 
 
EN 48   EN Network of Notified Laboratories 
The Commission is also considering an op tion which would involve the creation of a 
European Network of Notified Laboratories who would either prepare application files on 
behalf of applicants or review  the files before submission.  
(11) What advantages do you think the creati on of such a Network would bring? 
• unification of approach of all authorities 
• better information exchange 
• cooperation 
• unification of analytical procedures 
• contact with new materials 
• improved service to producers of new mate rials on national and international level 
Higher quality of applications, shorter pro cessing time and reduced processing costs. 
Not applicable. We do not have any competen t laboratories availabl e in our country.  
In general terms, it would create competence and speed up the processes 
I’m not sure that the creation of su ch network would bring advantages. 
Applicants would have access to the list of  laboratories ready to review the method 
before submission 
The applicant will know whom he may contact.  
It will establish the minimum equipment require d by a laboratory in or der to be able to 
perform the tests for textile fibres compos ition labelling, which w ill assure good market 
surveillance. 
The method validation test could be accomp lished in the network of laboratories. 
Well and clearly prepared technical files. 
None - not enough work to go round 
(12) What disadvantages would it have?  
No disadvantages. 
The laboratories have to allocate significan t resources for this cooperation. It may be 
costly and time-consuming. 
It would cause extra costs for MS. According to the requirements of the framework 
decision on marketing of product it won’t be an easy or cheap pro cedure to achieve a 
notification.  
Additional expenses for the creation of such network a nd for the notification of 
accredited laboratories. Notificat ion criteria are not clear. 
Procedure of laboratory notific ation would have to be deve loped which is probably time 
consuming 
At the first sight, there are no elements which present disadvantages. 
The Notified Bodies should be  designated by the Member  State. The criteria for 
designating of Notified Body should be clearly  prescribed (the accreditation for EN ISO 
17025); if not the question of competency  of such laboratories would arise. 
Laboratories would have differe nt approaches – variable c onsistency of applications 
would result. There should only be one labor atory and JRC Ispra is the obvious choice. 
 
EN 49   EN (13) How many of the labs in your country do you believe have adequate skills and 
expertise to act as an acc redited “notified” lab? 
No laboratories for the time being 
Two to three  
At present only one lab has adequate skills  to act as an accredited “notified” lab 
It depends on what will be their tasks. In our country, there are max. 2 labs 
One laboratory 
Three  
One accredited laboratory 
Max two. At the moment ther e is no accredited laboratory 
Not many as applications are no longer simple fibres. Identif ication and analysis methods 
can be very advanced, e.g. thermal analysis , NMR, etc. There are maybe two or three 
experts in the whole country. 
 
European Standards passed to CEN  
One of the options being considered by the Commission is for test methods agreed by the 
Committee on Textile Labelling to  be passed to CEN for adop tion as harmonised European 
standards. 
(14) What advantages do you think su ch an approach would have? 
Main advantage is separation of analytic al methods from the Directives. New EN 
standard must be more flexible and cha nges could be adapted easily by TC group. Final 
adoption of revised EN standard s (in future) to national versio ns is ordinary procedure. 
Using harmonised European standards is the simplest way to confirm that important 
requirements provided by the rele vant directives are fulfilled 
Many experts already particip ate in the CEN standardisation work in this field. 
Therefore it would be natural to combine this work with the work related to the 
directives. 
I’m not sure that it would bring advantages 
Harmonization of these standards is  an advantage for laboratories 
Laboratories of all Member States would ha ve access to proper analytical methods from 
European Standards when they need to quantify new fibre 
Passing the testing methods into European stan dards will have the advantage of assuring 
the transparency and uniformity of testing procedures all over Europe 
List of harmonised standards 
It is easier to update an EN standard than  to amend the directive or regulation. CEN has 
an existing structure in TC 248 (Textiles) to cope with this requirement. Test labs would find it easier to get acc reditation to ISO 17025 for an EN  standard than for methods 
published elsewhere. 
 
 
EN 50   EN (15) What disadvantages would such an approach have? 
We do not know 
No disadvantages 
It is not sure that this  will speed up the process 
According the time which is needed for CEN to adopt a new standard (as I know, 1-2 
years), there is a big question how could the market surveillance authority work without 
available standards? If the test methods s hould be first agreed by the committee and then 
sent to CEN, this will prolong the whole procedure. 
In the case where CEN is responsible for el aborating the testing methods, the approval 
time of the standard will be too long and will  delay the finalization of the technical file 
for the new fibre 
CEN needs about 1 year for adoption and public ation of methods in form of European 
Standards 
Preparation of the standard is also a very long procedure. In reality it takes 2 – 3 years, if 
you include the procedure for preparation of mandate from the Commission to CEN 
(voting procedures from Member States to  confirm the mandate and the notification 
procedures under the directive 98/34 should be included), which will take at least additional year. It will take at least 3-4 year from appli cation for a new fibre name to 
publishing new standard in OJ 
No obvious ones 
 
 
EN 51   EN REVISION OF LEGISLATION ON TEXTILE FIBRE NAMES AND LABELLING  
Summary of Responses by CEN 
1. What are the key steps involved at th e CEN level in adopting a standard? 
There are two cases to  take into account: 
1) The existing methods have been already integrated within th e series of ISO 1833, 
widely used in the whole world. It is no us e to create something new but to adopt the 
series of ISO 1833 as EN ISO standards.  If some slight differences may be 
found between one part of ISO 1833 standard and one method in the Directive text, they 
can be easily overcome. 
2) If a new method, validated by the JRC, is proposed to CEN, it can be forwarded 
directly to a UAP enquiry (Unique Acceptan ce Procedure) provided it is written in the 
EN format. 
The key step is the public e nquiry: all the CEN countries are required to vote and the 
standard needs at least72% of approval. The n, it is translated in the official languages: 
English, French, German and published. 
Any new work item is first agreed by the Technical Committee and member states. The 
committee or, in this case, one of its Work ing Groups produces a draft standard which 
is then issued to member states for vot ing on. Following agreement the draft is 
translated and then published as a formal European Standard. The full CEN time scale 
for the full process is a 3 year time cycle.  
The key steps from approval of the new work item are as follows: 
1. Approval of the new work item by the relevant technical committee 
2. Working group prepares a draft 3. Draft circulated for five m onths enquiry (public comment) 
4. Comments collated and resolved. 5. Document circulated fo r 2 months final vote. 
6. Final corrections/publication  The normal (default) timescale for producing a European standard (from an outline 
proposal) is 36 months. CEN national members have a further six months to implement 
the standard and withdraw any conflicting standards. 
Starting the work 
A proposal for a European Standard may co me from any interested party. Most are 
presented by the National Standards Bodi es and, where European legislation is 
concerned, the European Commission (EC) and the European Free Trade Association 
(EFTA). 
Taking into account the time re quired and the resources avai lable, the appropriate CEN 
Technical Committee makes a decision on th e adoption of the proposal. An adopted 
standardization project is allo cated to one of the Working Groups for the drafting of the 
 
EN 52   EN standard. Working Groups respond to the Technical Committee. 
If the proposal is for a new field of standard ization activity, a decisi on is first made by 
the CEN Technical Board, who then sends the work to a new or existing Technical 
Committee. 
One of the values of CEN is that, once a st andardization project has been adopted, the 
National Standards Bodies put all national act ivity within the scope of the project on 
hold. No new projects are initiat ed, nor are revisions of exis ting standards undertaken at 
a national level. This obligation is called ’sta ndstill’ and allows efforts to be focused on 
European harmonization. 
Public comment  
Once the draft of a European Standard is pr epared, it is released for public comment, a 
process known in CEN as the ‘CEN Enqui ry’. During the public commenting stage, 
everyone who has an interest (e.g. manufacturers, public au thorities, consumers, etc.) 
may comment on the draft. These views are collated by the Nationa l Standards Bodies 
and analyzed by the CEN Technical Committee. 
Adoption by weighted vote 
Taking into account the comments resulting fr om the CEN enquiry, a final version is 
drafted which is then submitted to the CE N members for a weighted formal voting.  
1 European Standard = 30 national standards  
After ratification by CEN, each of the Nati onal Standards Bodies adopts the European 
Standard as an identical na tional standard and withdraws any national standards which 
conflict with the new European Standard. Hence one European Standard becomes the 
national standard in the 30 member countries of CEN. 
For example, the European Standard on toy safety, EN 71, has been adopted as NF EN 
71 by AFNOR in France and as EVS EN 71 by EVS in Estonia. These standards are 
made available by the National Standards Body in each country. 
2. As an estimate, how long would it take CEN to adopt a test method as an EU 
standard? What are the factors which could a ffect this? For instance, would it take a 
shorter period of the time if the standard  has been verified by a notified/approved 
national laboratory?  
With the UAP procedure, it will take approximately 8 months. 
The factor which could affect this is a ne gative vote: then, the test method would have 
to be discussed again and impr oved within the CEN working group. 
For this directive, there is no notified national laboratory. We believe that the JRC can 
act as the reference laboratory in order to perform a consistent and structured work for 
validating the method .The aim of the JRC is to check the new methods through inter 
laboratory trials, as already done by the tech nical working group working with the JRC. 
I am uncertain of the role of a notified /approved national laboratory in verifying 
standards as I cannot accept this would be a cceptable to CEN. If it were the Laboratory 
of the Joint Research Council then yes, the method could be agreed in a shorter time 
frame as detailed below but it could not be  accepted verbatim wit hout going through the 
CEN approval process. 
Once a draft standard has been  agreed it would take approximately 7/8 months to 
be made available for purchase as an EU Standard. This comprises of one month for 
formal editing etc., 3 months for translati ng, final editing and printing, and 3/4 months 
 
EN 53   EN for final formal voting by member states. 
It is envisaged that a method approved by JRC (which also involves CEN/TC 248/WG 
30 members) will be subject to a much faster production schedule. T he "approved 
method" will be circulated (subject to TC agreement) to a 3-months UAP. Under the 
UAP procedure only editorial comments are accepted, hence there will be no delay 
resolving technical comments. 
0 Receipt of text from JRC 
 + 1 month (editing and placing in template)  +3.5 months (processing and translation by CEN)  +3 (or 5 months) UAP (72% approval required)  +1 month ratification  +2 months (DAV available followi ng processing and translation) 
Total – 10.5 months 
CEN national members have a further six months to implemen t the standard and 
withdraw any conf licting standards 
Adopting a validated test method as a European  standard is a stra ightforward process, 
taking it for granted that the validated test  method was elaborated by different parties 
and that there is consensus on the test method. From the moment CEN receives the text, 
up to publication by the CEN/Management Centre , it can take as little as 9-10 months. 
This includes preliminary administrative processing, a two month translation time, a 
three month voting time (shortened UAP pro cedure) and finally the ratification and 
publication. 
It is taken for granted that, for example JRC is to be considered as a competent 
laboratory (or in your wording a “notif ied/approved national laboratory”). 
3. Under one of the scenarios being considered, it is assumed that the marketing of a 
fibre with a new fibre name will be possible as soon as the amendment to the regulation is published and before the agreed test methods are adopted as a European Standard by CEN. In theory, this should shorten the ti me and procedure of adopting a new name. 
What are your views on the possible implic ations of this for CEN and the overall 
process?  
No problem with this, we do not see any implication as both procedures move 
forward side by side and th ere should not be a big gap of time between them.  
Provided CEN are involved at the start of th e process there should be no problems but if 
CEN are only brought in when a new fibre na me has been agreed then it delays will 
occur as any new test method being produced  as a standard would need to go through 
the formal CEN process of approval whic h would take a minimum of 7/8 moths as 
detailed above.  
Do not see a great problem but obviously th e earlier CEN members are involved in the 
process the better.  
CEN is a platform where experts are sitti ng around the table to come to consensus. 
Many textile experts work in CEN and having th em involved at an early stage facilitates 
 
EN 54   EN the standardisation process and eff ectively shorten the overall process.  
4. Can you provide an estimate of the cost imp lications of transferring this responsibility 
to CEN? Please feel free to provide estimates from other standards adopted by CEN (which may or may not be related to textiles) or alternatively, provide an indication of 
how many man-days and staff are normally  involved in the process of adopting a 
standard. 
We have no idea of the CEN cost s, please ask them directly.  
Sorry I am not able to give you any cost implications as these will vary from one 
country to another. In the UK members of CEN Committees a nd Working Groups are 
financed partially by Government to attend meetings and by their respective companies 
who pay their salaries and top up any expens es incurred. Central costs would be borne 
by CEN and the National Standards Body who ho lds the secretariat of the committee or 
working group. These expenses would cove r editing, translating and publishing costs.  
There will obviously be produc tion costs for CEN and for the 30 national member 
bodies, as all CEN members are required to implement the standard (once approved) as 
their national standard, irrespective of wh ether they are in favour of it or not. 
It is difficult to quantify costs as it depends  on the complexity of the standard. However, 
in terms of staff involvement, once the me thod has been approved by JRC, there could 
be costs associated with templating and ed iting the document at the secretariat and CEN 
level, prior to UAP. At this point th ere will also be translation costs. 
If approved by CEN members, there will also  be production and tran slation costs at the 
national level.  
As the work gets transferred to CEN, it is mainly the CEN system (i.e. the 
CEN/Management system with its 30 nationa l members) which has to bear the costs. 
All processes in CEN are streamlined for st andard setting. Therefore, and because of 
economies of scale (> 1000 European standa rds are published each year), it is much 
more efficient to use the standardisation Route.  
5. Is it reasonable to assume that the formal  adoption of a European Standard by CEN 
would automatically result in costs to Member  States (for instance, when such standards 
are translated into national standards or codes of practice)? If not, what are the 
considerations taken into account by Member States. 
The EN standards are mandatory translated in  the official language s: English (by BSI), 
French ( by AFNOR) and German ( by DIN) . It is up to  the other National 
Standardisation Bodies (and not Member States ) to translate the EN standard into their 
own national languages.  
See 4 above. In theory there would be no cost s to Member States but only organisations 
and companies working within Member States . There would also be costs to users of 
the standards who would need to purchas e them from their National Standards body.  
There are no additional costs to Member States since th e production costs are borne by 
CEN and the national member bodies.  
Transferring the work to CEN will imply cost savings for the European and national 
authorities for the simple reason that the wo rk is done inside th e CEN structures. The 
additional costs are to be carried by the CEN System and the national standardisation 
bodies. It is difficult to calcul ate, on a scientific basis, how high these additional costs 
will be for CEN. At the same time, it is difficult to measure the cost savings for the 
 
EN 55   EN European and national authorities.  
Referring to European standards also cont ributes to the Commission’s SLIM-policy 
(Simplification of Le gislation policy, see 
http://ec.europa.eu/internal_mar ket/simplification/index_en.htm  )  
6. Some industry stakeholders have indicate d that one benefit of translating test 
methods into standards is that this allows for peri odic updating of the test method. What 
do you consider would be the benefits (and  costs) of such updating, and who would 
benefit? 
The methods are technical and must follow the st ate of the art and ther efore, have to be 
updated. That is the aim of the systematic review of EN standa rds and it is a key 
advantage.  
The future regulation should be in compliance with the new approach; that is to 
say, written as a legislative text, with re ference to EN standards for the technical 
applications. 
Having been deeply involved in the devel opment and publication of national, European 
and International standards for over 30 years there is a definite benefit of a period 
review and update as necessary. Within CEN any standard is reviewed on a 5 yearly 
time scale. The updating allows for new devel opments to be taken into account, changes 
to regulations i.e. use of chemicals, improve ments to be made etc. These would benefit 
all users of a standard from producers thr ough to the consumer. It is doubtful whether 
there would be any cost savings. 
All CEN standards are reviewed regularly (a ma ximum of five year intervals) to ensure 
that they are still up-to-date and of use to industry. NSBs may propose 
amendments/revisions to an ex isting standard at any time. 
European standards have to be reviewed, at le ast every five years. This ensures that the 
standard is a “stat of the art” document, up to date for the economic operators, European 
authorities and national market surveillance authorities. Updating European legislation 
(Regulations and Directives) is a much “heav ier” process and, as a consequence, much 
more expensive. 
 
EN 56   EN REVISION OF LEGISLATION ON TEXTILE FIBRE NAMES AND LABELLING  
Summary of Responses by Industry (Fibre Manufacturers Association)  
Q1 - The questions below are intende d to provide an indication of the scale and focus of 
research and development  of textile fibres for your or ganisation. Please give your best 
estimate or forecast; more detail or explan ation can be provided in the box below. 
In the last five years :    
How many new fibres has your organisation placed on the global market?  1-10 
How many new fibres has your organi sation placed on the EU market?   
How many of the new fibres placed on th e EU market were classified under 
existing fibre names?    
How many of the new fibr es placed on the EU market require a new fibre 
name as, for chemical or processing reasons, they should not be classified 
under the existing groups?   
In the next five years:   
How new many new fibres does your organisation expect to place on the 
global market?   
How new many new fibres does your organi sation expect to place on the EU 
market?   
How many of the new fibres to be pl aced on the EU market do you expect to 
classify under existing fibre names?   
How many of the new fibres to be pl aced on the EU market do you expect to 
apply for new textile fibre names?   
With regard the scale of R&D , this may vary by company but all companies regardless 
of size are involved in R&D in one form or another. As an illustration, while some of 
the companies which have recently put ne w fibres through the ap provals process are 
large companies, others are much smaller. Hence, it is the case that small companies 
may be interested in R&D as much as big companies.  
In general 90 - 95% of a companies R&D activities are focussed on improvements and 
developments on existing fibres. Only 5 - 10% of R&D activities are likely to result in a 
fibre requiring a new generic name. It is th e case that if 10 - 20% of the R&D activities 
of a company is successful, that can  be considered a good situation.  
Between five new fibres a pplying for new generic names have been pl aced on the 
global market in the last five years. Als o, most companies do not discriminate between 
global and EU markets. It is, however, the case that some fibres may be sold on an 
overseas market (e.g. US) and not in the EU. For instance, Melamine  is a new fibre 
which is currently going through the EU a pprovals process (~18 m onths to-date). This 
 
EN 57   EN fibre name was, however, adopted by BISFA over 10 15 years ago and is only currently 
being put forward to the Commission (by an American-based company). During this 
time, it has been sold in the US and has been marketed in the EU in only small 
quantities.  
To date, there is no case where a fibre na me has been rejected  by the Commission. 
However, there have been two recent cases where an application has been rejected by 
BISFA. One case was for a bamboo fibre and they concluded it was just a variation of a 
viscose fibre process.  
 
Q2 - What are the key factors determining th e rate of development  of new fibres? Some 
examples are provided below; please rank these f actors (from 1 - 5) with the most important 
numbered 1. Feel free to identify other factor s and/or provide more de tail or explanation in 
the box below. 
Maintaining a competitive advantage over other fibre producers   4 
Company size and/or budget allocated to the development of fibres  5 
Advances in research and developm ent by laboratories - know-how  3 
Market/consumer demand for new fibres   2 
Wider commercial and strategic cons iderations (e.g. patent rights)  1 
Other (please specify)   
 
 
Q3 - Could you provide an indication of the time  currently taken, once a new fibre is 
developed, before it can be placed on the EU ma rket for production or commercial purposes - 
differentiating between the time taken for “new” fibres which should be given new fibre 
names  under the Textiles Directives, and “other new” fibres whic h can be classified under the 
existing groups? 
Time taken for “new” fibres 
requiring new fibre names Tick  Time taken for “other new” 
fibres Tick  
<1 year  <1 year x 
1-2 years   1-2 years   
2-3 years x 2-3 years  
3-4 years  3-4 years  
4-5 years   4-5 years   
 
EN 58   EN 5 years   5 years   
 
Obviously, a new fibre can be placed on the market immediately if it is using an 
existing fibre name; however, BISFA is awar e of some applications for a new generic 
name which have taken four years. A faster  process has taken 18 months. On average, 
two to three years would be a good a ssumption. BISFA would, however, like the 
procedure to take one year.  
 
EN 59   EN Q4 - Could you provide your best estimate of the total costs per new fibre  to your 
organisation of obtaining approval to market a fi bre in the EU with a new name in line with 
the Textiles Directives? 
Cost to organisation  Tick 
<€10,000  
€10,000 - €99,999  
€100,000 - €249,999  
€250,000 - €499,999  
€500,000 - €999,999  
€1 million and above  x 
 
BISFA estimates that three staff are alwa ys present from any given company at 
meetings and submissions relating to a new fi bre. Assuming that these three staff work 
full time on a given fibre from the start of th e project through the 2 - 3 years it takes to 
get approval, the man-day costs alone will be  expected to be greater than €1 million.  
 
Q5 - Listed below are some of the actions th at you may take in order to comply with the 
Textiles Directives. Please indi cate which of these actions is  relevant to your organisation 
(using the YES and NO boxes). For those which ar e relevant, provide th e estimated costs in 
Euros (€) of each action; alte rnatively, you can rank these actions (from 1 - 8) with most 
significant - in terms of cost - numbered 1. 
 Yes No Cost/Rank
Identifying whether a new fibre can/cannot be classified into 
any of the existing groups    
Contacting and getting support fr om the relevant European 
industry federations, consumer organisations and industry in 
general before launching an application     
Providing proof of consumer relevance of a new fibre     
Obtaining evidence of innovative elements of an application 
(e.g. patents, etc).    
Laboratory and scientific stud ies for the definition of, and 
testing methods for, a new fibre name    
Preparing an application file for a new textile name    
 
EN 60   EN Please add others as relevant (please specify) 
BISFA reckons that the costs of these variou s activities would have to be estimated on 
the basis of the number of man-days spent by people in the organi sation on each step. 
Some steps (e.g. providing proof of consumer  relevance of a new fibre) will not be 
relevant, however, as companies would in a ny case put the fibre on the market to test 
commercial relevance. In effect, it is part of the baseline cost.  
Q6 - Please provide further information on the administrative burden  associated with the 
requirements of the current Textiles Directiv es for your organisation. For example, how many 
full-time staff (or alternatively person-days)  do you employ/spend obtaining approval for new 
fibre names under the Textiles Directives? 
No. of full-time staff Tick  No. of person-days  Tick  
<1 person   <1 day/year   
1-3 people  x <20 days/year (~1 month)  
2-5 people   1 - 2 months/year  
5-10 people  2 - 3 months/year  
10-20 people   3 - 6 months/year  
>20 people ( please specify )  6 - 12 months/year  
 
Other administrative costs (including unquantifiable costs) :  
Around 1-3 people are actively i nvolved in the application pr ocedure on a part or full-
time for as long as the procedure takes.  
 
Q7 - Please provide your best estimate of the pe rcentage of the total costs of compliance with 
the Textiles Directives (indicated  in Q4) which relate to admi nistrative burden or costs, as 
opposed to testing costs, for instance.  
% of Costs Relating to Administration Tick 
<15%   
15 - 25%  
25- 50%  
50 - 75% x 
 
EN 61   EN 75 - 90%  
90 - 100%  
 
Q8 - One of the aims of revision of the Textile s Directives would be to reduce the amount of 
time it takes to process an application for a new textile name. Could you please provide an 
indication of what benefits to your organisati on might result from speeding up the application 
process? Please indicate the size of the likely benefits and indicate whic h is likely to be the 
most important? 
 Yes No Value/Rank 
Reduced personnel time in s upporting an application 
through the process    
Increases in the number of new fibres brought to market    
Increases in innovation    
Benefits from getting a new fibre onto the market more 
quickly     
Increases in investment in new fibre technologies     
Increased market demand for new fibres    
Other (please specify)    
Please describe what these benefits w ould mean to your company. For example, 
indicate the potential magnitude  of cost savings in terms of reduced personnel time or 
the value of any time to market benefits. 
The main benefit of speeding up the proce ss is the support which is given to the 
marketing strategy of the company which has applied for the fibre name. For instance, 
for the melamine fibre (currently going th rough the process), the company involved is 
not involved in the manufacture of any othe r fibre. The whole business is, therefore, 
dependent on the success of this fibre. While  for other companies, this may not be the 
case, but whole business units or sections may be dependent on the time it takes a certain fibre to go to market. Speeding up th e process, therefore, enables the company 
to strengthen its position overall. 
Q9 - The decision making process for justifyi ng the addition of a new fibre name to the 
Textiles Directive requires applicants to subm it a file with an application for a new fibre 
name. One of the reasons for approval taking so long is because these files sometimes contain 
insufficient information to allow for assessment of whether the case for a new fibre name is 
adequate. There is currently some guidance on file contents on the Commission website and 
improved guidance is being developed.  
 
EN 62   EN Please indicate whethe r you believe that the provision of clearer and more detailed 
guidance  would result in a reduction in time delays  (explaining why). 
Yes  
No  Why would it result in a reduction in time delays?  
BISFA does some work with companie s in the area of providing guidance 
and, indeed, the initial guidan ce produced by the Commission was 
developed by BISFA. BISFA considers the current guidance to be quite clear; but like any other type of guida nce, there is always scope to provide 
further support whether by the Co mmission or BISFA. Overall, BISFA 
considers that the Commission (or the slow process) cannot be blamed on 
unclear guidance. The reality is that  companies do not apply everyday for a 
new generic name so they are genera lly always going to be inexperienced 
in putting it into practice (without some help). 
If clearer and more detailed guidance would resu lt in a reduction in time delays, this may also 
reduce the costs that your company currently incurs in seeing an application through the 
approvals process. Please provide your best esti mate of the potential pe rcentage reduction in 
time and costs that your company might expect to realise. 
% Reduction in Time Delays Tick % Reduction in Costs Tick 
<15%   <15%   
15 - 25%  15 - 25%  
25- 50%  25- 50%  
50 - 75%  50 - 75%  
75 - 90%  75 - 90%  
90 - 100%  90 - 100%  
Q10 - If the new application guidelines were to be made binding ; for instance, by including 
them as a technical annex to a Regulation – to allow updating and amendment, in the same 
way as updating to add new fibre names – do you think this would a) reduce the time and costs to your organisation of preparing a file; b) speed up the approval process by the 
authorities? See above  
Reduce the time and costs to your 
organisation? Speed up the approval process by the 
authorities? 
Yes  Yes  
No  No  
 
Q11 - Could you provide information on the extent  to which delays in introducing new fibre 
names results in lost revenue a nd profits to your organisation? 
 
EN 63   EN The amount of revenue lost by delays is in general difficult to quantify and will depend 
on the company and its strategic view of th e market. Most companies will only apply 
for a new generic name where its suits thei r market strategy and know-how. You have 
to look and see if the market is accepting the products being put on the market and if 
customers are willing to accept the changes or  indeed, price mark-up. If these market 
conditions are not met, there may be benefits  of marketing under an existing fibre name. 
As a proxy, a few factors can be considered . For some new fibres which were given 
new generic names recently, sales have been in the region of €10 million to €50 million (depending on timing and other business factors). 
This also depends on whether it is a specialit y fibre or a commodity fibre. Most fibres 
with new generic names start off as speciality fibres and the hope of every company is 
that it can one day become a commodity fibr e. A whole new business unit can be a spin-
off as a result of this movement. 
Speciality fibre can differ in cost from a comm odity fibre by a factor of 2 to 10 times 
more. However, a direct comparison cannot be made between their market prices 
because SF are produced under special conditions and in lower quantities so the price per kilogram needs to be seen in the context of the quantity produced.  
 
Q12 - The current Textiles Directives contain lo ng lists of test methods; in many cases these 
are very similar to methods used in releva nt standards. The Comm ission has discussed a 
simple transfer of testing methods in the Directives to European standards (EN).  What 
do you think the impacts of such a change would be?  
The main advantage of such a change is th at there would be a re gular revision of the 
standards every five years by CEN - so as to  keep pace with the rapid change in test 
methods in the textile industry. This is better than the current situation where no 
changes are made after a test method is incl uded in a Directive. In practice, it may well 
be that every five years, CEN just conclude that there is no need for revision for a test method but at least someone is looking at it.  
 
Q13 - Another option involves an app lication file being accompanied by a report from an 
accredited national laboratory  (or “notified laboratory”). Th e aim would be to have an 
independent review before the application file is submitted, thereby improving file quality, reducing the need for further testing (and ring trials if possible) and increasing the overall 
speed of the process. 
Do you believe that such “notifie d” independent labora tories could take on the assessment of 
technical files? 
BISFA is currently encouraging members to ma ke use of such laboratories in preparing 
their application.  
How much you believe this w ould cost your organisation? 
 
EN 64   EN No extra costs to companies. The main advantage is that the Commission does not 
spend valuable time and money repe ating work already done by industry.  
Would it have any wider impacts on the application process (positive and negative)? 
 
 
Q14 - What do you think would be the overall effects of the proposed changes to your 
customers, and which changes do you believ e would be of the most benefit to your 
customers? 
 The basic effect will be that consumer s have access to useful information on the 
textiles and their properties, as  intended by the Directive. 
 
Q15 - Finally, if you feel that we have missed anything important, or would like to comment 
on any of the issues raised by this questionnaire, please let us know (and continue on a 
separate sheet if necessary). 
Three new fibre names have been is sued in the last five years:  
• Elastomultiester  
• Polylactide  
• Elastolefin  
Fibres which are currently work in progress include:  
• Melamine: BISFA have adopted melamine as a fibre name 10 15 years ago - but the 
step was not made to the Commission. They  made the step for a new generic name 
18 months ago but it has been marketed  in the EU in minor quantities. 
• Primethylene ester (PTT) (application in US as well)   
• Propylamide composite  
Some companies have informed BISFA that they will be coming forward with new 
applications for new generic names. There are two companies which may come up with 
new applications but not yet.  
Overall, some of the companies that appl y for a new generic name are big companies 
while others are small companies but important players like or much smaller companies (SME). Hence, it is the case that R&D efforts are not limited to big companies (or size/budget). Also, most res earch efforts (90 - 95 %) by companies are 
on existing fibres, rather than  looking for new fibres.  
It is possible that a new fibre name could indirectly result in  a higher margin - even if a 
new generic name is not used for direct ma rketing (i.e. brand names); however, there 
are other considerations (e.g. market strategy and market know-how) on whether u 
have to put a new fibre or just go with an  existing fibre. Overall, applying for a new 
fibre is a purely business a nd marketing strategy/decision. 
 
EN 65   EN For the recent fibres:  
• Melamine Fibre : the company that owns it does not manufacture any other fibre. 
They are depending on this fibre for opening this business line;  
• The same is true for elastolefin . They have a separate section dealing with this fibre 
and the success of that division depends on this fibre.  
• For polyactide , the main application is in packagi ng - only a minor part is for fibre 
applications; 
• For Primethylene ester  (PTT) , the company is a big one. One of their raw materials 
is PTT - the dependence is a bit minor.  
• For elastomultiester , it is one of the many products of the company. It is a speciality 
fibre in a huge portfolio.  
• For Propylamide composite : the company considers this a speciality and is a 
breakthrough innovation for their key busin ess. Of major strategic importance.  
 
EN 66   EN QUESTIONS FOR BISFA  
1) How frequently does BISFA make a fibre a pplication on behalf of one of its members 
versus the member company making the applica tion itself? In your opinion, what generally 
determines the extent to which a company uses BISFA in making a fibre application? 
Principally applications fo r new generic names to the EU Commission are done by 
the companies concerned. If they have gone through the adoption procedure at BISFA (normal case),they make reference to that. The credibility of an application is 
very much supported through prior adoption at  BISFA (rules for generic names for 
fibres were originally developed by BISFA, a standardisation organisation now existing for 72 years) 
2) Do all member companies approach BISFA with  their proposed applic ation prior to making 
the application with the Commission? Or is BI SFA sometimes approached at the same time as 
a company makes its application to the Commission? 
it is the normal situation that companies  (also non-members) first approach BISFA 
for adoption and after that the EU Commission 
3) It is our understanding that companies make  applications for a new fibre name to the 
BISFA Secretariat which then submits this to the Standards for Fibres and Textiles Committee. 
approaching the BISFA secretariat already  includes guiding in formation for the 
applicant by the Secret ary General of BISFA 
a) Does a company have to wait until the SFT m eets before its proposal is put forward to the 
BISFA Policy Committee?  
applications can be put forward either to the SFT or to the Policy Committee, which 
means to groups meeting in total 4 times a year (spread along the year).This is adequate, taking into consideration the befo re mentioned initial guiding step by the 
Secretary General 
b) Is it general procedure for the SFT to then put a working group in place to prepare an application proposal together with the company? 
The installation of an ad hoc  meeting working group depends on the need resulting 
from discussions at the SFT or Policy comm ittee for more details, for clarification, 
for analytical results .If there is no need ,no working group will be installed 
c) How long does it usually take for final approva l to be given to an application by BISFA? 
Usually it takes no longer than half a year,  of course with some exemptions to this 
rule 
4) What advantages does taking an applicati on through BISFA have for companies? Does it 
speed up the time taken to get an application through the EU procedure? Does it reduce the 
likelihood of MS objections? Does it  affect testing requirements? 
 
EN 67   EN it is above all in a case of adoption that the fibres indus try (BISFA represents > 90% 
of the European man made fibers industry) is confirming the need for a new generic 
name, and it supports the credib ility of the applicant if competing companies come to 
that (consensus) conclusion. Testing results ar e part of the application at BISFA, so 
are a base for subsequent adoption by Commission/MS 
5) Does BISFA and its member companies alwa ys approach the Commission with regard to 
an application or do companies also make th e application through a Member State competent 
authority? 
There are no recent cases of applications through MS competent authorities 
6) Are applications generally made at the same  time in the EU and in the US, or are they 
made first in the US or made first in the EU? What generally determines the decision by 
companies regarding which country they  approach first w ith a new fibre? 
all situations occur. One aspect is rela ted to the main market to be addressed 
7) If companies tend to make an  application in the US first, do they take any further steps 
prior to making an application in the EU? E .g. carry out more/differe nt testing, prepare 
different information for their application, etc. 
to prepare for application in Europe th ey usually approach BISFA. Procedures in 
US and Europe are quite different: in te rms of naming (EU: stricter technical 
name),definition (EU: only verifiable and quantifiable definitions) and testing (EU: 
strict results related to definitions).The process in EU generally is more extensive, more quantified (and longer)  
8) Only a few applications have been made per year in the recent past, does BISFA see the 
number as increasing in the future? If so, what is the expected trend in terms of numbers per 
year (e.g. two per year over the next three y ears, increasing to five  a year thereafter)? 
difficult to predict, but 2/year seems realistic 
9) How long on average does the current process take once an application has been made to 
the European Commission? What aspects of th e current process does BISFA believe could be 
speeded up? 
varies between 2 and 4 years. Recent sugge stions made by DG Enterprise seem 
adequate to speed up. Especially the aspect of  testing mentioned is crucial to speed 
up:if the applicant shows convin cing test results, a decision should be based on that 
without further testing by the Commission or  MS (training of MS labs could be 
organised after adoption and publication) 
10) In your experience, what is considered as  sufficient proof of commercial relevance in 
making an application to the EU? Where an application for a new fibre is rejected, in your experience, what implications doe s this have for a fibre which ha s proven to be commercially 
relevant? 
 
EN 68   EN a presence in the markets by some tonnage , presence at fairs and other marketing 
efforts should be shown. If  an application is rejected it does not mean the product 
has no marketing future or pow er. It only means that the innovation did not show the 
need to communicate to the market the need for creation of a new fiber family 
11) Do companies make use of their ability to approach MS to gain preliminary designations 
for fibre names in order to be able to market them while the application for a new fibre name 
is being considered? If so, wh ich MS authorities are approach ed most often? Also, do MS 
authorities undertake thei r own testing or checks  prior to agreeing to  grant a preliminary 
designation to fibre? 
cases are known for UK, Italy and France. We  are not aware of testing done for that 
by Member States 
12) Minutes of meetings of the Committ ee and Working Groups on Textile Names and 
Labelling suggest that some of the more recen t textiles are challenging the content of Annex 
1. For example, it has been suggested that deve lopments in fibre technology means that a new 
family of fibres (i.e. composite fibres) may need to be added to the families currently listed in the Directive. It has also been suggested that  there may be a need to create sub-categories 
under the generic headings to make  distinctions between fibres th at deliver new properties but 
which cannot be given anew fibre name due to  their chemical properties or processing 
method. 
Do you believe these issues are likely to become more important in the future? If so, please 
comment on their likely importance. 
Yes, we believe that new technologies li ke composite fibers are serious candidates 
for new generic names. The acceptance of generic names should consider new emerging technologies, respectiv ely generic names are a t ool for this and they are 
satisfying a consumers need to create awar eness of innovative fibre technologies in 
the textile market 
13) What are the commercial and economic adva ntages of gaining a new fibre name? Are 
there any examples that BISFA can provide? 
a new fibre name is related to an innovative technology, so it supports a marketing 
approach based on uniqueness with commercial and economic advantages. Especially the EU fibers industry depe nds on specialisation and a corresponding 
creation of awareness in the market. In fa ct all recent new fibre names can be taken 
as examples 
14) What is the economic value of a reduction in the time take n to gain approval for a new 
fibre name?  
As time is money, a reduction of time (and correspondingly costs) contributes 
positively 
15) What advantages would there be in having test methods agreed for the different fibre 
types converted into standards overseen by CEN? 
one positive aspect is that testing met hods could undergo routine revisions (all 5 
 
EN 69   EN years?) 
16) Would there be advantages to companies in  being able to approach a notified body (or a 
network of such bodies) to develop a nd carry out the necessary testing?  
the application at BISFA already includes that testing is conducted (respectively 
verified) by preferably 2 notified bodies (recognised testing houses).This should 
remain an important base referring to the credibility of the application 
17) Would the development of clearer and more precise guideline s on what should be 
included in a dossier and what is required for approval of an application reduce the time and 
costs involved to companies? 
the guidelines are sufficiently clear, but our  experience is that some guiding (like 
through the preliminary guiding mentioned with  the Secretary General of BISFA) is 
helpful 
18) Are there other industry a ssociations or companies who you believe should be consulted 
for this study? 
we are not aware of further associations involved in detail 
 
Note: Please consider that the aspect of harmonisation of generic names (at ISO 
level, see standard ISO 2076) still is a problem. The actual situation is that at ISO parallel names are adopted (US and EU nam es) due to a lack of harmonisation 
Number of people per fibre development is not dependent on company size but on the 
fibre technology to be developed and marketing strategy involved, lets say a large project with 5-10,a smaller project with 2-5 staff 
I would prefer to state that per fibre  applying for a new generic name during the 
period of application 1-3 people are directly  involved with the Textiles Directive 
 
EN 70   EN REVISION OF LEGISLATION ON TEXTILE FIBRE NAMES AND LABELLING  
Summary of Responses by Industry (Fibre Users) 
Q1 - How many new fibres which could be classified under exis ting names in EU legislation 
has your organisation used in the last five year s? How many new fibres th at required the fibre 
producer to obtain a new name under EU legislati on has your organisation used in the last five 
years? 
  Number over the last 5 years 
Number of new fibr es classified under 
existing names  10 
Number of new fibres requiring new 
names under EU legislation 20 
 
Q2 - What are the key factors determining the ra te of uptake of new textile fibres? Do these 
vary for fibres which can be classified unde r existing names and those which require new 
names? 
New technical fabrics 
High-Tech garments 
Personal Protective Equipment Fashion 
 
Q3 - How long does it take for a textile fibre (initia lly made available for “market testing 
purposes”) to be placed on the EU market fo r production or commercial  purposes - please 
distinguish between the time taken for “new” fibres (which require a new name under the 
Textiles Directives) and “other” new fibres wh ich can be classified under the existing groups? 
Time taken for “new” fibres 
requiring a new name  TickTime taken for “other” new 
fibres Tick  
<1 year  <1 year  
1-2 years  1-2 years X 
2-3 years X 2-3 years  
3-4 years  3-4 years  
4-5 years  4-5 years  
5 years  5 years  
 
EN 71   EN  
Q4 - Do you believe that a simplification of th e Textiles Directives wi th the aim of reducing 
the time taken to approve a fi bre would result in a reductio n in costs incurred by your 
organisation? Please provide a reason for your answer.  
Yes X 
No  Please provide further comments here. 
 
Please provide your best estimate of the potential reduction in co sts to your organisation (as a 
percentage) that would arise from the shorter time frames. 
% Reduction in time delays Tick % Reduction in costs Tick
<15%  X <15%   
15 - 25%  15 - 25% X 
25- 50%  25- 50%  
50 - 75%  50 - 75%  
75 - 90%  75 - 90%  
90 - 100%  90 - 100%  
 
Q5 - Could you provide further information on th e extent to which delays in introducing new 
fibres results in lost revenue and profits to your organisation? 
As laboratory testing centre a shorter time to  classify new fibres could be useful to 
provide a better service to textile companies in order to fill in the composition label. 
 
 Q6 - Have delays in the approval of a particular fibre (or fibres ) resulted in your organisation:  
  YES/NO
a) resorting to alternative fibres to develop a particular product (or 
products)   YES 
b) losing the opportunity to develop a particular product (or products)  YES 
c) losing significant investment in  research and development  YES 
d) refusing to purchase a fibre wh ich you were previously intending to 
use   NO 
 
EN 72   EN e) being unable to sell a fibre or  product for which you had a potential 
customer  YES 
f) incurring significant costs due to  delays in bringing new textile 
products to market  YES 
g) other (please specify)    
Please provide further details. Any availa ble data on the costs associated with the 
above actions would be welcomed.  
 
Q7 - Finally, if you feel that we have missed anything important , or would like to comment on 
any of the issues raised by this questionnaire,  please let us know (and continue on a separate 
sheet if necessary).  
 
 
EN 73   EN REVISION OF LEGISLATION ON TEXTILE FIBRE NAMES AND LABELLING  
Summary of Response by  Consumer Association 
Q1 - Is your organisation awar e of the EU requirements on te xtile names and labelling? 
 Yes  yes 
No  
 
Q2 - If yes, what are the main benefits of the requirements for consumers? 
Flame retardants, Bioc ides, Organic cotton 
 
 Q3 - Do you believe that a simplification of the Textiles Directives, to reduce the time taken 
to approve a fibre, would result in additional be nefits for consumers? Please provide a reason 
for your answer.  
Yes X 
No  Please provide further comments here. 
 
 
Q4 - The options for streamlining the procedures in the Textiles Directives are listed below. 
Please indicate what imp act, if any, you think these would have on consumers. 
Impacts  
Option Positive Negative No 
impact 
Changing the Directive to  a Regulation, so that 
national legislation does not need to be adapted X   
Clearer and more detail ed guidance to industry 
applicants X   
Transfer of fibre testing methods to European 
standards X   
Independent review by an accredited national 
laboratory before an application is submitted X   
 
 
EN 74   EN Q5 - Finally, if you feel that we have missed anything important , or would like to comment on 
any of the issues raised by this questionnaire,  please let us know (and continue on a separate 
sheet if necessary).  
 
 
EN 75   EN ANNEX 2 - Comparison of activities for preparation, assessment and approval of an application to  a new textile fibre name, acco rding to the 
regulatory and the regulatory+non-regulator y (standardisation) approaches examined  
Table I: Comparison of Activities for Streamlining Current Process  
No Policy Change –  
Current Process  Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
No additional provisions Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
Contents of Application File  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Laboratories recognised byMS  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Contents of Application File + 
Laboratories recognised by MS  
Step 0: Preparation of Application  
• Company uses in-house 
capabilities or hires a Lab to undertake testing or develop new 
test methods  
• Application is prepared setting out 
justification for a new generic 
name and proposed methods for 
identification and quantification: 
• Chemistry 
• Process 
• Consumer relevance 
• Identification & 
quantification methods 
 Step 0: Preparation of Application 
• Company uses in-house 
capabilities or hires a Lab to undertake testing or develop 
new test methods  
• Application is prepared setting 
out justification for a new 
generic name and proposed 
methods for identification and 
quantification: 
• Chemistry 
• Process 
• Consumer relevance 
• Identification & 
quantification 
methods 
 Step 0: Preparation of Application  
• Company uses in-house 
capabilities or hires a Lab to undertake testing or develop 
new test methods  
• Application is prepared setting 
out justification for a new 
generic name and proposed 
methods for identification and 
quantification: 
• Chemistry 
• Process 
• Consumer relevance 
• Identification & 
quantification 
methods 
 Step 0: Preparation of Application 
• Company uses in-house 
capabilities or hires a Lab to undertake testing or develop new 
test methods 
• Application is prepared setting out 
justification for a new generic 
name and proposed methods for 
identification and quantification 
including: 
• Chemistry 
• Process 
• Consumer relevance 
• Identification & 
quantification methods 
• Network Lab checks the test 
method  
 Step 0: Preparation of Application 
• Company uses in-house capabilities 
or hires a Lab to undertake testing or develop new test methods 
• Application is prepared setting out 
justification for a new generic name and proposed methods for 
identification and quantification 
including: 
• Chemistry 
• Process 
• Consumer relevance 
• Identification & 
quantification methods 
• Network Lab checks the test method  
 
 
EN 76   EN Table I: Comparison of Activities for Streamlining Current Process  
No Policy Change –  
Current Process  Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
No additional provisions Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
Contents of Application File  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Laboratories recognised byMS  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Contents of Application File + 
Laboratories recognised by MS  
Step 1: Submission of Application 
• Application is made to 
Commission or to a MS National Authority 
 Step 1 : Submission of application 
 
• Application is made to 
Commission or MS National 
Authority  
• Application includes proposals 
for new test methods or 
correction factors as appropriate  
•  Step 1 : Submission of Application 
 
• Application is made to 
Commission or MS National 
Authority  
• Application includes proposals 
for new test methods or 
correction factors as appropriate  
•  Step 1: Submission of Application 
• Application (including validation 
report by network lab is made to Commission or MS National 
Authority 
• Application includes proposals for 
new test methods or correction 
factors as appropriate accompanied 
by a report from a recognised 
national laboratory  Step 1: Submission of Application 
• Application (including validation 
report by network lab) is made to Commission or MS National 
Authority 
• Application includes proposals for 
new test methods or correction 
factors as appropriate accompanied 
by a report from a recognised 
national laboratory  
Step 2 : Assessment and Initial 
Review of Application by DG 
Enterprise 
• Commission decision on whether 
to convene WG or request more 
info Step 2 : Assessment and Initial Review of Application by DG 
Enterprise 
• Commission decision on 
whether to convene WG or 
request more info  Step 2 : Assessment and Initial Review of Application by DG 
Enterprise 
• Commission decision on 
whether to convene WG or 
request more info  Step 2 : Assessment and Initial Review of Application by DG 
Enterprise 
• Commission decision on whether 
to convene WG or request more info Step 2 : Assessment and Initial Review 
of Application by DG Enterprise 
• Commission decision on whether to 
convene WG or request more info  
 
EN 77   EN Table I: Comparison of Activities for Streamlining Current Process  
No Policy Change –  
Current Process  Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
No additional provisions Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
Contents of Application File  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Laboratories recognised byMS  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Contents of Application File + 
Laboratories recognised by MS  
Step 3a: Technical Examination of 
Application 
• Commission convenes Working 
Group on Textile Labelling 
• File discussed at WG meeting 
• Additional information requests 
made to applicant where 
necessary 
• Clarifications from applicant 
• JRC carries out tests to check 
definition and whether suggested test methods are sufficient 
• Applicant must provide any 
additional information requested by WG Step 3a: Technical Examination of 
Application 
• Commission convenes Working 
Group on Textile Labelling 
• File discussed at WG meeting 
• Additional information requests 
made to applicant where 
necessary 
• Clarifications from applicant 
• JRC carries out tests to check 
definition and whether suggested test methods are 
sufficient 
• Applicant must provide any 
additional information requested 
by WG  Step 3a: Technical Examination of 
Application 
• Commission convenes Working 
Group on Textile Labelling 
• File discussed at WG meeting 
• Limited information requests 
made to applicant where 
necessary  
• JRC carries out tests to check 
definition and whether 
suggested test methods are sufficient 
• Applicant must provide any 
additional information requested 
by WG Step 3a: Technical Examination of 
Application 
• Commission convenes Working 
Group on Textile Labelling 
• File discussed at WG meeting 
• Very limited additional 
information requests made to 
applicant 
• JRC carries out tests to check 
definition and whether suggested 
methods are sufficient 
• Applicant must provide any 
additional information requested 
by WG Step 3a: Technical Examination of 
Application 
• Commission convenes Working 
Group on Textile Labelling 
• File discussed at WG meeting 
• Very limited information requests 
made to applicant where necessary 
• JRC carries out tests to check 
definition and whether suggested 
methods are sufficient 
• Applicant must provide any 
additional information requested by 
WG 
 
EN 78   EN Table I: Comparison of Activities for Streamlining Current Process  
No Policy Change –  
Current Process  Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
No additional provisions Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
Contents of Application File  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Laboratories recognised byMS  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Contents of Application File + 
Laboratories recognised by MS  
Step 3b: JRC organises ring trials  
• JRC organises ring trials where 
there is a need to validate findings 
• Uses network of labs 
• Checks repeatability of tests and 
validity of tests for different 
combinations of fibres Step 3b: JRC organises ring trials  
• JRC organises ring trials where 
there is a need to validate 
findings 
• Uses network of labs 
• Checks repeatability of tests and 
validity of tests for different 
combinations of fibres Step 3b: JRC organises ring trials  
• JRC organises ring trials where 
there is a need to validate 
findings – sub-set of cases 
• Uses network of labs 
• Checks repeatability of tests and 
validity of tests for different 
combinations of fibres Step 3b: JRC organises ring trials  
• JRC organises ring trials where 
there is a need to validate findings 
– sub-set of cases; 
• Uses network of labs 
• Checks repeatability of tests and 
validity of tests for different 
combinations of fibres Step 3b: JRC organises ring trials  
• JRC organises ring trials where there 
is a need to validate findings – sub-
set of cases 
• Uses network of labs 
• Checks repeatability of tests and 
validity of tests for different 
combinations of fibres 
Step 3c/3d: Report on Technical 
Examination and discussion with 
National Experts  
• Results of technical examination 
& ring trials submitted to COM,  
• COM prepares proposal to amend 
the Directive Step 3c/3d: Report on Technical 
Examination and discussion with 
National Experts  
• Results of technical examination 
& ring trials submitted to COM  
• COM prepares proposal to 
amend the Directive  Step 3c/3d Report on Technical 
Examination and discussion with 
National Experts  
• Results of technical examination 
& ring trials submitted to COM 
• COM prepares proposal to 
amend the Directive Step 3c/3d: Report on Technical 
Examination and discussion with 
National Experts  
• Results of technical examination & 
ring trials submitted to COM  
• COM prepares proposal to amend 
the Directive Step 3c/3d: Report on Technical 
Examination and discussion with 
National Experts  
• Results of technical examination & 
ring trials submitted to COM 
• COM prepares proposal to amend the 
Directive 
Step 4: Preparation of Draft 
Proposals  
• Commission tables draft 
amendments to Committee on 
Textile Names and Labelling  
• Amendments agreed or referred to 
written procedure Step 4: Preparation of Draft 
Proposals  
• Commission tables draft 
amendments to Committee on 
Textile Names and Labelling  
• Amendments agreed or referred 
to written procedure Step 4: Preparation of Draft 
Proposals  
• Commission tables draft 
amendments to Committee on 
Textile Names and Labelling  
• Amendments agreed or referred 
to written procedure Step 4: Preparation of Draft 
Proposals  
• Commission tables draft 
amendments to Committee on 
Textile Names and Labelling  
• Amendments agreed or referred to 
written procedure Step 4: Preparation of Draft Proposals  
• Commission tables draft amendments 
to Committee on Textile Names and 
Labelling  
• Amendments agreed or referred to 
written procedure 
 
EN 79   EN Table I: Comparison of Activities for Streamlining Current Process  
No Policy Change –  
Current Process  Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
No additional provisions Regulatory (Option 2) and/or 
Non-regulatory Approach (Option 
3) – 
Contents of Application File  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Laboratories recognised byMS  Regulatory (Option 2) and/or Non-
regulatory Approach (Option 3) – 
Contents of Application File + 
Laboratories recognised by MS  
Step 5a: Directive Amended  
• Submission to scrutiny of EU 
Parliamentary  
• Adoption by COM 
• Publication in OJ Step 5a: Regulation Amended  
• Submission to scrutiny of EU 
Parliamentary  
• Adoption by COM 
• Publication in OJ  
• Immediate marketing of new 
fibre possible  
• Test method passed to CEN to 
become an EU standard  
(Option 3 only)  Step 5a: Regulation Amended  
• Submission to scrutiny of EU 
Parliamentary  
• Adoption by COM 
• Publication in OJ  
• Immediate marketing of new 
fibre possible  
• Test method passed to CEN to 
become an EU standard  
(Option 3 only)  Step 5a: Regulation Amended  
• Submission to scrutiny of EU 
Parliamentary  
• Adoption by COM 
• Publication in OJ  
• Immediate marketing of new fibre 
possible  
• Test method passed to CEN to 
become an EU standard  (Option 
3 only)  Step 5a: Regulation Amended  
• Submission to scrutiny of EU 
Parliamentary  
• Adoption by COM 
• Publication in OJ  
• Immediate marketing of new fibre 
possible  
• Test method passed to CEN to 
become an EU standard  (Option 3 
only)  
Step 5b: CEN Adopts Standard  
• Not applicable  
 Step 5b: CEN Adopts Standard  
• Adoption  of Test Methods as 
European Standard by CEN 
(Option 3 only)  Step 5b: CEN Adopts Standard  
• Adoption  of Test Methods as 
European Standard by CEN 
(Option 3 only)  Step 5b: CEN Adopts Standard  
• Adoption  of Test Methods as 
European Standard by CEN 
(Option 3 only)  Step 5b: CEN Adopts Standard  
• Adoption  of Test Methods as 
European Standard by CEN (Option 
3 only)  
Step 5c: MS Transposition  
• Transposition of Directive by MS  Step 5c: MS Transposition  
• No transposition required  
MS introduce EU standard into 
national standards in conformity 
with EN (Option 3 only) Step 5c: MS Transposition  
• No transposition required  
MS introduce EU standard into 
national standards in conformity 
with EN (Option 3 only) Step 5c: MS Transposition  
• No transposition required  
MS introduce EU standard into 
national standards in conformity with 
EN (Option 3 only) Step 5c: MS Transposition  
• No transposition required  
MS introduce EU standard into national 
standards in conformity with EN (Option 
3 only) 
Changes from Option 1are underlined  
Changes which apply only to Option 3 are in Italics  
 
EN 80   EN ANNEX 3 Steps Involved in Adopting a Standard  
A proposal for a European Standard may come  from any interested party, such as the 
European Commission (EC), the European Fr ee Trade Association (EFTA) and National 
Standards Bodies (NSB). There are two pro cesses for adopting European standards:  
– the ‘classical’ process, which generally takes up to 36 months to complete; and  
– the shorter Unique Acceptance Process (UAP), which takes 8 - 12 months.  
The ‘Classical’ Process 
The key steps involved in the ‘cla ssical’ process are as follows: 
1. Approval of the new work item by the relevant CEN technical committee24 : Taking 
into account the time required and the resources available, the appropriate CEN Technical 
Committee makes a decision on the adoption of the proposal. If the proposal is for a new field 
of standardisation activity, a decision is fi rst made by the CEN Technical Board, which then 
sends the work to a new or ex isting Technical Committee. An a dopted standardisation project 
is allocated to one of the Working Groups (whi ch reports to the Technical Committee) for the 
drafting of the standard. 
2. Working group prepares a draft standard : This includes preliminary administrative 
processing (e.g. formal editing and placing the proposal text in a template and translation into 
English, French and German). 
3. Draft standard is circ ulated for public comment : Once the draft of a European Standard 
is prepared, it is released fo r public comment, a process known in CEN as the ‘CEN Enquiry’. 
At this stage, everyone who has an interest (e .g. manufacturers, public au thorities, consumers, 
etc.) may comment on the draft. These views are collated by the National Standards Bodies 
and analysed by the CEN Technical Committee. 
4. Formal voting on final draft: After the comments collated from the CEN enquiry have 
been resolved, a final version of the standard is drafted, which is then submitted to the CEN 
Members for a weighted formal voting. All the CEN countries are requ ired to vote and the 
standard needs at least 72% of approval to go to the next stage. 
5. Ratification and publication of Standard : Final editorial corrections are then made and 
the standard is published as a formal European Sta ndard in the official languages (English, 
French, and German).  
The Unique Acceptance Procedure (UAP) 
The accelerated Unique Acceptance Procedure (UAP) is applied where there is a high 
likelihood of agreement on a standard. The UAP involves the following steps: 
1. Approval of the new work item by the relevant CEN technical committee : Any 
remaining uncertainties regarding the proposed  test method could be addressed through 
                                                 
24 Note that once a standardization project has been adopted (Step 1), the National Standards Bodies stop 
all national activity within the scope of the project. No new projects are initiated, nor are revisions of 
existing standards undertaken at a national level. This  obligation is called ’standstill’ and allows efforts 
to be focused on European harmonization. 
 
EN 81   EN formal and informal discussions between CE N and the test method proposer before the 
adoption process begins. The administrative procedures (e.g. formal editing and placing the proposal text in a template) take around four to six weeks and there is also a two month 
translation time into English, French and German. 
2. The formal voting
25 on the proposed test method starts . This formal vote normally lasts 
five months, but can be shortened to three months. 
3. The standard will then be finalised, ratified and published, as in the ‘classical’ process. This 
could take around four to eight weeks. 
At best, the UAP procedure can take 8 - 9 months, and in gene ral, 10 - 12 months, from 
receipt of a proposal to publica tion and availability of a European standard. The factor which 
could affect this is a negative vote: then, the test method woul d have to be discussed again 
and improved within the CEN working group. 
Adoption as national standard : After publication by CEN, each of the National Standards 
Bodies adopts the European Standard as an identical national standa rd and withdraws any 
national standards which conflict with the ne w European Standard. Hence one European 
Standard becomes the national standard in the 30 member countries of CEN. These standards 
are made available by the National Standards B ody in each country (generally for a fee). CEN 
national members have six months to implemen t the European standard and withdraw any 
conflicting national standards.  
                                                 
25 The vote actually combines the CE N-Enquiry and formal vote stage of  the “classical process” in one 
single step. In practise, this allows only editorial comments on the draft standard, as technical issues 
will have been resolved prior to the start of the vote on the test method 
 
EN 82   EN ANNEX 4 - Steps Involved in the Adoption  a New Fibre Name in EU legislation  
Step 0: Preparation of Application : This is the stage at which a company prepares an 
application for a new generic name. In genera l, applications for new generic names are 
prepared by the companies concerned using in-house or external laboratories. Some 
companies also go through an adoption proce dure at BISFA, prior to approaching the 
Commission. BISFA represents over 90% of the European man made fibres industry and it is, 
therefore, considered that the cr edibility of an application is enhanced if competing companies 
come to a consensus regarding th e validity of an application. The costs of this step are not 
quantified in the impact assessment as it takes place before an application is made. However, 
policy options which introduce a network of r ecognised national laboratories may impact on 
the length of this step and therefore introduce ad ditional costs within it . These additional costs 
are included in the analysis. 
Step 1: Submission of Application:  This is the stage at which a written application (and 
technical file) for an amendment of the Tex tiles Directives is sent to the European 
Commission. The application could be sent to the respective authority of an EU Member 
State, but this has not yet happened in practice. The application sets out the justification for a 
new generic name based on (a) chemistry; (b) pr ocess; (c) consumer relevance and provides a 
definition and identification and quantification methods. 
Step 2: Assessment and Initial Review of Application:  This is the stage at which the 
application file is initially examined by the Co mmission services with the aim of determining 
whether a new name is justified on the basis that the fibre cannot be classified into any of the 
existing groups. The amendment process will onl y be initiated where an amendment of the 
Directives appears appropriate, in view of a n eed for consumer information and/or the proper 
functioning of the intern al market as well as to encourag e innovation by providing the fibre 
with a legal name for trading. 
The Directive does not specify a format for an  application from industry and, as such, 
applications initially submitted to the Comm ission may have incomplete and insufficient 
information to make an assessment as to whet her an application is justified. The Commission 
has, therefore, issued a set of non-legally binding guidelines26
 for potential applicants, which 
clarifies that an application can  only be considered if the information listed below is included:  
a) indication must be provided in which respec t the fibre is different  (and distinguishable) 
from existing fibres already listed in Annex I to Di rective 96/74/EC; 
b) following from above, an indication of the test methods for detecting the new fibre in 
mixtures (qualitative and quantitative test method required), taking into account Directives 
96/73/EC and 73/44/EEC; 
c) indication of present or future consumer relevance must be provi ded (and where possible, 
evidence of innovative elements (e.g. patents)); 
d) a proposal for a generic name; and 
                                                 
26 Application for a new fibre name: guidelines available from http://ec.europa.eu/enterprise/textile/ 
guidelines_applicants.htm  
 
EN 83   EN e) a proposal for an agreed allowance. 
If the Commission services consider that the application is sound, they launch the process for 
the technical examination. 
Step 3: Technical Examination of Application  The Commission services make the technical 
examination of an application (i.e. to valida te fibre name as well as the definition and 
analytical methods proposed by th e applicant, so that they can be officially established and 
used by Member States for market surveillance). 
Step 3a: Convening a Working Group: As soon as the Commission has examined a 
file and it appears likely that it is ind eed a new fibre, it convenes a meeting of the 
Working Group on Textiles Labelling (WG), made up of Member State experts and 
chaired by a Commission representative. Th e WG discusses whether the application 
is justified, the technical adequacy of the file and whether other information is needed from the applicant and gives it s opinion to the Commission on whether the 
application should proceed. Any comments or questions  the WG may raise, are 
referred to the applicant by the Commission. In  practice, all applic ations received to 
date have required additional data from the applicant.  
WG meetings are convened as necessary by the Commission when an application is 
received (usually in less than three mont hs since the application was submitted to the 
Commission services). The initial Working Group assessment (is it a new fibre? what 
additional data are needed to launch the testing?) is usually completed within 6 months, if the applican t holds all the required data a nd provides it to the Commission 
in a timely fashion. However, in some cas es applicants have taken up to 18 -20 
months to provide all the data, particul arly where further laboratory testing is 
required.
 
Step 3b: Joint Research Centre (JRC ) checks definition and test method: In theory, 
a single WG meeting should be sufficient for a decision to be made as to whether an 
application should proceed and thus for th e JRC of the Commission to initiate its 
work on validating the fibre definition and test methods. This involves a laboratory 
examination to check the fibre definition and testing to determine whether there is a test method that will allow Member States Competent Authorities to check that an 
article labelled with the fibre name ind eed contains it. The JRC usually requires 
around 10 months to undertake this work. If th e application file in cludes a definition 
and a sound testing method with supporting experimental data, the process can 
involve shorter checking of these by JRC. 
During this stage, the JRC convenes at leas t two meetings of a European network of 
national experts on textile la belling in order to share opinions and decisions on the 
work to be performed. The experts do not provide an official  opinion. Although some 
of the national experts participate in m eetings of the Working Group, there is no 
formal link between the groups. 
Step 3c: Ring Trial: There may be a need to organise a ‘ring trial’ to validate some 
correction factors and/or new methods in  order to evaluate  repeatability and 
reproducibility to ensure that  the proposed test method works in different laboratories 
and with different fibre mixtures. This involves around 10 (though sometimes fewer) 
 
EN 84   EN laboratories in Member States  carrying out tests. The ring  trial phase takes around six 
months (making 16 months in total for th e work of the JRC plus the ring trial). 
Step 3d: Discussion with National Experts : The report of the JRC, describing the 
work performed and the results obtained, is used as a basis to draft the proposals for 
amending Directives 96/74/EC and 96/73/EC . The report specifies which decisions 
were taken by consensus with National E xperts on the name, definition, methods and 
coefficients which should be added to the directives. 
Step 4: Preparation of Draft Proposals : At this stage, draft proposals to amend the Textiles 
Directives are prepared and submitted to th e Committee on Textile Names and Labelling for 
voting, following the so-called comitology rules.  After receiving a favourable opinion of the 
Committee, the proposal is submitted for scrutiny to the European Parliament. 
Step 5: Amendment of Direct ive and National Legislation : This stage involves: 
a) the proposals going through Eu ropean Parliament scrutiny; 
b) the amending Directives being adopted and published in the Offici al Journal (OJ); and 
c) Member States transposing the Di rectives into na tional legislation. 
European Parliament scrutiny takes a period of 4-6 months once all linguistic versions have 
been submitted to the Parliament. If there ar e no objections during this period, the amendment 
is adopted and published. Member States then have a further 12 months to transpose the 
amendments to the Directives into national law. 
 
EN 85   EN ANNEX 5 – Impact Assessment Board opinion of 9 September 2008  
Opinion  
Title  Impact Assessment on: Simplification of EU legislation in the 
field of textile names and labelling 
(draft version of 16 July 2008) 
Lead DG  DG ENTR 
1) Impact Assessment Board Opinion 
(A) Context 
EU legislation in the field of Textile Names and Labelling consists of three Directives – 
96/74/EC, 96/73/EC and 73/44/EEC. These Directives need to be adapted each time a new generic name for a novel fibre is to be  added to the technical annexes, it also 
requires all Member States to take action to transpose the amending Directives into 
national legislation. In the fr amework of the legislative simplification programme being 
undertaken by the European Co mmission, it is proposed to  revise EU legislation on 
Textile Names and Labelling in order to simp lify its adaptation to technical progress.  
(B) Positive aspects 
This draft IA report is of a good quality. It is well structured  with good use of tables and 
graphs to illustrate the presentation. Th e report provides a clear and focused problem 
definition and provides a good range of r ealistic options. Extensive stakeholder 
consultation has taken place.  
(C) Main recommendations for improvements 
The recommendations below are listed in order of de scending importance. Some more technical comments 
have been transmitted directly to the author. 
General recommendation: 
The report could be improved further by clarifying how the feasibility of the 
standardisation approach could be better assessed in the future and explaining 
more clearly the unsuitability of non-legislat ive and self-regulatory options. A brief 
clarification of some aspects related to crea ting a network of recognised laboratories 
and third country impacts is also recommended.  DG ENTR has already indicated it 
will take on board many of the detailed comments made by the Board.  
(1) The report should further clarify the approach to Option 3 (transfer of 
quantification methods to the domain of standardisation).  Due to the lack of 
information, which the report co rrectly identifies, there are presently major uncertainties 
related to this approach, which limit the possi bility of evaluating it in  detail. However the 
report also indicates that standardisation has important qualitative benefits (for instance, 
regular revision of standard s and unified approach) whic h were also emphasised by 
Member States (p.9). The report should ther efore explain in more  detail how it is 
 
EN 86   EN intended to gather the necessary information and to develop cooperation with the 
European Committee for Standardisation in or der to assess in future whether Option 3 
would be an appropriate approach. 
(2) The report should include a clearer explanation of why non-legislative and self-
regulatory options were discarded  including more informa tion on the preference of 
industry and Member States for a regulator y approach at Community level. A brief 
presentation of the general ob jectives of the Textile Name Directive in the Section of 
Objectives (which presently only states the ai ms of the revision process) would be useful. 
(3) The report should clarify some aspects related to creating a network of 
recognised laboratories  by explaining why the Joint Resear ch Centre can not assist the 
applicants in the preparation stage and be ing more specific whether the creation of a 
voluntary network of recognise d laboratories would imply additional cost to Member 
States (p.44).  
(4) Concerning third country impacts, the report should brie fly describe how the 
regulation applies to the export and import of textile products; and what are the principles 
for granting new fibre na mes in third countries.  
(D) Procedure and presentation  
It appears that all procedural requireme nts have been complied with. The executive 
summary should contain a clear presentation of the quantified benefits of the policy 
option. 
2) IAB scrutiny process 
Reference number 2008/ENTR/012 (simplification) 
Author DG ENTR G 4  
External expertise used No  
Date of Board Meeting Written Procedure 
Date of adoption of Opinion 9 September 2008