Most of a garment label for Germany is set by EU law. Article 16(3) of Regulation (EU) No 1007/2011 requires labelling or marking in the official language or languages of the Member State where the product is made available to the consumer, unless that Member State provides otherwise. The German Textilkennzeichnungsgesetz requires the fibre-composition declaration to be in German and permits additional languages.
This is the label brief for German-market apparel: which instrument governs what, what the fibre declaration has to say, what care labelling is and is not, and which records have to survive the shipment. [1] [2]
Which rule governs a textile label in Germany?
Two instruments, working together.
Regulation (EU) No 1007/2011 sets the EU-wide rules on textile fibre names, on the labelling and marking of fibre composition, and on labelling products that contain non-textile parts of animal origin. It requires fibre composition to be indicated whenever a textile product is made available on the market, ordinarily by label or marking, and allows accompanying commercial documents in the specified business-to-business and public-contract cases. Labelling and marking must be durable, legible, visible and accessible, with a label securely attached. [2]
The Textilkennzeichnungsgesetz of 15 February 2016 is the German implementing act. It states in its opening section that it applies in addition to Regulation (EU) No 1007/2011 and regulates that regulation's implementation in Germany. It also carries the national provision that the EU regulation leaves to member states: the language. [1]
The EU regulation sets the composition requirements and the general language rule. For Germany, the declaration must be in German, and additional languages may be used alongside it.
| Question | Instrument | Where it is settled |
|---|---|---|
| Which fibre names may be used | Regulation (EU) No 1007/2011 | EU-wide, harmonised list |
| Whether a label is required at all | Regulation (EU) No 1007/2011 | Generally required when the product is made available, subject to the exceptions in Article 17 |
| Which language the declaration is in | Regulation (EU) No 1007/2011 and Textilkennzeichnungsgesetz | German, for the German market |
| Whether care symbols are required | Neither | Not a fibre-labelling requirement |
| How long the supporting records are kept | Textilkennzeichnungsgesetz | Two calendar years, by manufacturer or importer |
Does the fibre composition have to be in German?
For consumer-facing labelling, yes. The German act requires textile products to be labelled or marked in German to indicate their fibre composition, in accordance with the relevant articles of the EU regulation. In the specified business-to-business and public-contract cases, accompanying commercial documents may replace or supplement the label or marking. Further languages are expressly permitted in addition, so a multilingual label is fine as long as the German version is there and correct. [1]
The EU regulation reaches the same place by a different route: it requires labelling in the official language or languages of the member state where the product is made available to the consumer, unless that member state provides otherwise. Germany has legislated on the point rather than departing from it. [2]
The practical consequence for a range shipping across several EU destinations is that the label set is planned per destination. Where the same physical garment goes to Germany and elsewhere, the label can carry the languages required for each destination or the packing can separate destination versions. Both approaches must meet the language rules that apply where the product is made available to the consumer.
What counts as fibre composition, component by component
The declaration is about materials, not about what the garment is called. A multi-fibre product normally lists its constituent fibres with percentages in descending order, subject to the specified rules for ‘other fibres’, hard-to-state compositions and fibres not listed in Annex I. A product made of more than one textile component, where those components have different fibre contents, needs the content of each component stated, with limited exceptions for minor parts. Where a product contains non-textile parts of animal origin, the prescribed indication must be used. [2]
The regulation also governs how the information appears: fibre composition descriptions are given on packaging, labels and markings, and in catalogues and trade literature, in a way that is easily legible, visible and clear, in uniform print as regards size, style and font. A trade mark may sit immediately before or after the description; other information is displayed separately. [2]
This is where a bill of materials earns its keep. A padded jacket is rarely one composition. Shell, lining, filling, rib, pocketing, a contrast panel and a woven badge can each be different, and the label check follows the actual construction and the applicable rules for components and excluded items.
Two rules in the EU regulation do most of the work of deciding what actually has to appear, and a bill of materials is checked against both. Annex VII is headed "Items not to be taken into account for the determination of fibre composition", and applies through Article 19(2) when composition is determined under Articles 7, 8 and 9. It is not a general exemption from Article 11's duty to declare each differently composed textile component. For textile products other than the specific products listed separately in Annex VII, the excluded items include base or underlying fabrics, stiffenings and reinforcements, interlinings and canvas backings, stitching and assembly threads unless they replace the warp or weft, fillings without an insulating function and, subject to Article 11(2), linings. Separately, a component need not have its own statement only where it is not a main lining and represents less than 30 per cent of the total weight of the textile product.
So the table below is a check to run against those rules, not a list of statements a garment will carry.
| Component on the tech pack | What the label check has to answer |
|---|---|
| Shell fabric | Confirmed composition against the approved fabric, not the development sample |
| Lining | Different composition, so does it need its own statement |
| Filling or wadding | If it has a different fibre content, check whether a component statement is required; filling without an insulating function is excluded from composition determination under Annex VII |
| Rib, cuff, waistband | Often a different blend from the body |
| Contrast panels and pocketing | If their fibre content differs, check whether a component statement is required; the 30 per cent exception also requires that the component is not a main lining |
| Interlinings, stiffenings, assembly threads | Excluded from composition determination under Annex VII; an assembly thread is not excluded where it replaces the warp or weft |
| Leather or fur trim, horn or bone buttons | Triggers the non-textile animal origin indication |
| Woven labels and badges | Excluded from composition determination under Annex VII |
Is care labelling a legal requirement in Germany?
Not under the textile fibre regulation. That instrument is about fibre names, fibre composition and non-textile parts of animal origin. Care instructions sit outside its scope; the regulation only anticipates a possible future harmonised care-labelling system as something to be examined. [2]
Retailer specifications may require care labelling. Where care instructions are supplied, they should be accurate and suitable for the product.
Where care instructions are supplied, wash tests, dimensional stability and colourfastness results can support the care copy. The wider garment labelling and care-label guide sets out how the care brief is built.
Who carries the labelling responsibility?
Under the EU regulation, when placing a textile product on the market the manufacturer ensures the supply of the label or marking and the accuracy of the information on it. Where there is no manufacturer established in the EU, the importer takes on that responsibility. Distributors carry obligations of their own when they make products available. [2]
The German act tracks that structure. It sets out the obligation of manufacturers and importers to apply the labelling and to ensure the information is accurate, so that the product's fibre composition matches what is declared, and a separate obligation on distributors making products available to ensure the labelling is there. It applies the fibre-composition requirements to textile products offered for sale by electronic means, but does not apply Article 12 of the EU regulation in that context. [1]
For an export house shipping to a German importer, responsibility for supplying the label and for its accuracy sits with the importer if the manufacturer is not established in the Union. Where the manufacturer is established in the Union, it sits with that manufacturer. The importer will still need reliable composition and artwork information from the supplier.
One useful provision for the business-to-business stage: the German act allows the labelling or marking to be replaced or supplemented by accompanying commercial documents where the products are supplied to economic operators in the supply chain, or to fulfil a public contract. Bulk fabric moving between operators is not the same problem as a garment on a rail. [1]
What records sit behind the declaration
The German act requires manufacturers and importers to keep records of the facts on which the labelling or marking of the fibre composition is based, for two calendar years. The period runs from the end of the calendar year in which the last of the products covered by those records was placed on the market. Distributors keep their equivalent records for as long as the products are made available. [1]
That is a documentation duty that continues after the goods are placed on the market. In practice, the file behind a fibre declaration should be assembled while the order is running, when the mill invoice, the blend sheet and the composition test are all in reach.
| Record | Why it supports the declaration | When to capture it |
|---|---|---|
| Approved fabric specification | States the blend the label is based on | At fabric approval |
| Mill invoice or delivery note | Ties the blend to the goods actually received | On fabric receipt |
| Composition test report | Independent confirmation of the declared blend | Before bulk artwork release |
| Trim and component register | Identifies parts with a different content, and animal-origin parts | At bill of materials sign-off |
| Approved label artwork and physical proof | Shows what was actually declared | Before bulk |
Where the label goes wrong between sample and bulk
A label can become inaccurate when a change happens after approval and does not reach the artwork.
A lining is substituted when the original is unavailable. A rib is re-specified for a better recovery. A filling weight changes and the filling type changes with it. A leather patch is added at the buyer's request three weeks before shipment, which introduces the animal-origin indication onto artwork that was signed off without it. Each of these is a normal production event; none of them announces itself as a labelling problem.
Two controls handle most of it. Freeze the declaration only after bulk material approvals are stable, and route any post-approval material change through the same person who owns the label brief. On a German programme, add a third: confirm the German wording is on the artwork that actually went to the label supplier, and not only on the version that circulated for comment.
The Germany import guide sets out the wider document set a German programme carries, including the audit and certification records that sit alongside the label file.
FAQ
Must the fibre composition be in German for the German market? For consumer-facing labelling, yes. The German textile labelling act requires textile products to be labelled or marked in German to indicate their fibre composition. Other languages may be added alongside it. In the specified business-to-business and public-contract cases, accompanying commercial documents may replace or supplement the label or marking.
Does a care label satisfy German textile labelling law? A care label satisfies the textile requirements only if it also carries the required fibre-composition information and, where applicable, the indication for non-textile parts of animal origin. Care instructions themselves fall outside those textile rules, though retailers may require them in their own specifications.
Who is legally responsible for the label on an imported garment? The manufacturer placing the product on the EU market, or the importer where there is no EU manufacturer, with separate obligations on distributors. In practice the importer relies on the supplier's artwork and test file.
How long do the supporting records have to be kept? Two calendar years for manufacturers and importers, counted from the end of the calendar year in which the last product covered by those records was placed on the market.
Does every component of a garment need its own composition statement? Where a product has more than one textile component with different fibre contents, the content of each is stated, subject to the exception for a component that is not a main lining and represents less than 30 per cent of the product’s total weight. Also apply the rules for excluded items when determining fibre composition. Map the components from the bill of materials before releasing artwork.
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