National Trading Standards – Leather Goods

This guidance is for England, Scotland & Wales

Any consumer product made of leather – for example, clothing, shoes, bags, belts, furniture, soft furnishings, and even equine equipment, such as saddles and bridles – is subject to controls on the chemicals that may be present as a result of the tanning process. Chemicals such as azo dyes, chromium VI and dimethyl fumarate (DMF) have previously been found to be present in leather goods and are now restricted under regulations due to the health hazards they pose to consumers.

If you are not the manufacturer or importer, you should check with your supplier that the products comply with the Regulations. This could involve asking to see test certificates, or auditing your suppliers if you are a large retailer. If you are a manufacturer or importer, you would normally be expected to have tested your products to ensure that they comply.

The legislation

EU Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) regulates the use of azo dyes, chromium VI and dimethyl fumarate (DMF).

Anyone who supplies consumer leather products intended to come into direct and prolonged contact with the skin, and that may contain any of these chemicals, will be affected by the Regulation. Examples are as follows:

  • clothing
  • hats
  • footwear
  • gloves
  • wristwatch straps
  • handbags
  • purses
  • toys containing leather
  • furniture
  • soft furnishings
  • equine equipment, such as saddles and bridles

Azo dyes, chromium VI & dimethyl fumarate

Azo dyes are organic compounds. Azo dyes are used to treat textiles, leather articles and some foods. Some – such as dinitroanline orange, ortho nitroaniline orange, or pigment orange 1, 2, and 5 – are mutagenic and carcinogenic. Azo dyes derived from benzidine are carcinogens.

Tanning is the process of making raw hides or skins into leather. The majority of leathers used in furniture, gloves and footwear are tanned using chromium salts. Contact with the skin can cause burns and contact-dermatitis allergic reactions, which appear as reddening of the skin, itching and rashes.

Chromium VI is a skin sensitiser; future reactions can be caused when only a very small amount is in contact with the skin. There are also dangers from ingestion. This is a particularly important hazard to assess for young children’s toys or clothing where there is a risk of mouthing. Studies have shown the ingestion of chromium VI may affect the liver, kidneys and the immune system.

DMF is used as a biocide in leather products, such as furniture or shoes, to prevent growths of mould during storage or transport in a humid climate. DMF has been found to be an allergic sensitiser at very low concentrations, producing an eczema reaction that is difficult to treat. Concentrations as low as 1ppm may produce allergic reactions.

Azo dyes in products

Azo dyes, which may release one or more listed aromatic amines above 30 mg/kg (0.003% by weight), must not be used in articles that may come into direct and prolonged contact with the human skin or oral cavity – for example:

  • clothing
  • hats
  • footwear
  • gloves
  • wristwatch straps
  • handbags
  • purses / wallets (including those worn around the neck)
  • briefcases
  • purses
  • leather toys and toys that include leather garments

Leather articles must not be placed on the market unless they conform to these requirements.

Chromium VI in products

Leather articles or articles containing leather parts coming into contact with the skin must not be placed on the market where they contain chromium VI in concentrations equal to or greater than 3 mg/kg (0.0003% by weight) of the total dry weight of the leather.

Dimethyl fumarate in products

Leather products containing the biocide DMF in concentrations greater than 0.1 mg/kg must not be placed on the market.

Second-hand leather goods

For products sold second-hand, the General Product Safety Regulations 2005 apply. These require goods supplied to be safe so the restrictions will still apply.

What should I do to make sure I comply?

If you are not the manufacturer or importer you should check with your supplier that the products comply with the Regulations. This could involve asking to see test certificates, or auditing your suppliers if you are a large retailer. How much you need to do depends on a number of circumstances – for example, the size of your business – but doing nothing will not be sufficient.

If you are a manufacturer or importer, you would normally be expected to have tested your products to ensure that they comply. It is recommended that a reputable test house should carry out any testing, such as one accredited by the United Kingdom Accreditation Service (UKAS).

Penalties

Failure to comply with trading standards law can lead to enforcement action and to sanctions, which may include a fine and/or imprisonment.

Key legislation

General Product Safety Regulations 2005

EU Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) 

REACH Enforcement Regulations 2008

PLEASE NOTE

The information is intended for guidance only; only the courts can give you an authoritative interpretation of the law.

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National Trading Standards – Labelling of textiles

This guidance is for England, Scotland & Wales

The Textile Products (Labelling and Fibre Composition) Regulations 2012 require all textile products to carry a label indicating the fibre content, either on the item or the packaging. If a product consists of two or more components with different fibre contents, the content of each must be shown. Only certain names can be used for textile fibres and these are listed in the Regulations along with a list of products that are not required to bear fibre content.

There is a general obligation to state the full fibre composition of textile products.

What is a textile product?

A textile product can be defined in any of the following ways:

  • raw, semi-worked, worked, semi-manufactured, manufactured, semi-made up or made up products composed of textile fibres
  • products containing at least 80% by weight of textile fibres (including furniture, umbrella and sunshade coverings)
  • textile parts of carpets, mattresses and camping goods
  • textiles incorporated in, and forming an integral part of, other products where textile parts are specified

How should the product be labelled?

All items must carry a label indicating the fibre content, either on the item or the packaging.

The label should be durable, easily legible, visible and accessible. If the product is supplied to a wholesaler the indication may be contained within business documents – the invoice, for example. A textile product consisting of two or more fibres accounting for 85% of the finished product should be marked with the fibre followed by a percentage – for example, ‘cotton 80%, polyester 15%, nylon 5%’.

If a product consists of two or more components with different fibre contents – for example, a jacket with a lining – the content of each must be shown. Any decorative matter that makes up 7% or less of the product is excluded from the indication of fibre content. The word ‘pure’ should only be used where the garment is made up of only one fibre. The word ‘silk’ cannot be used to describe the texture of any other fibre – for example, ‘silk acetate’ is not permitted. Only certain names can be used for textile fibres and these are listed in annex I of EU Regulation (EU) No 1007/2011 on textile fibre names and related labelling and marking of the fibre composition of textile products(see link in ‘Key legislation’ below). This list may be updated as new technology produces new fibres.

If you are using, buying or selling a fibre product with a name that does not appear on this list, contact your local trading standards service for advice.

There are special provisions that relate to the required method of labelling of corsetry products, etch-printed and embroidered textiles, velvet and plush textiles (or textiles resembling velvet or plush), and floor coverings and carpets where the backing and pile are composed of different fibres.

Textile products in sold in multipacks – such as floorcloths, cleaning cloths, handkerchiefs, bun nets and hair nets, wash-gloves, face flannels, etc – of the same type and fibre composition may have inclusive rather than individual labelling. The full list of products to which this allowance may be applied can be found in annex VI of EU Regulation (EU) No 1007/2011.

Annex VII of EU Regulation (EU) No 1007/2011 contains information on textile product components that are not taken into account in determining fibre compositions.

Fur & other animal parts

Consumers must be made aware when textile products contain parts of animal origin, such as fur, leather, bone, etc.

The use of non-textile parts of animal origin must be clearly labelled or marked using the phrase ‘contains non-textile parts of animal origin’. The label can contain further information on the parts of animal origin – such as mink fur or lambskin – but the mandatory phrase must always be used.

This also means that any mis-labelling – for example, labelling real fur as faux fur – is an offence.

Additionally, it is an offence to sell, import or export cat and dog fur, and products containing such fur. Similar provisions apply to the marketing of seal fur (these are enforced by Her Majesty’s Revenue and Customs (HMRC) rather than trading standards services).

Advertisements, catalogues & e-commerce

Where products are advertised in such a way that they can be ordered by reference solely to the description in the advertisement, the Regulations require an indication of fibre content to appear in the advertisement. Advertisements include catalogues, the internet, circulars, price lists and trade literature.

Products that do not have to bear a fibre content indication

  • air-supported structures
  • animal clothing
  • artificial flowers
  • book covers
  • buttons and buckles
  • certain types of cordage, rope and string intended as components in other items
  • disposable articles (except wadding)
  • egg cosies
  • flags and banners
  • funeral products
  • gaiters
  • labels and badges
  • make-up cases
  • mobile phone and portable media player covers (with a surface area less than 160 cm²)
  • muffs
  • old made up textile products
  • oven gloves and cloths
  • packaging (not new and sold as such – for example, used potato sacks)
  • painted canvas
  • pin cushions
  • protective requisites of sport (except gloves)
  • saddlery
  • safety items (for example, life jackets, parachutes)
  • sails
  • shoe cleaning cases
  • sleeve protectors
  • sleeve supporting arm bands
  • slide fasteners
  • spectacle, cigarette and cigar, lighter and comb cases
  • stuffed pan holders
  • table mats having several components and a surface area not exceeding 500 cm²
  • tapestries, including materials for their production
  • tea and coffee cosies
  • textile parts of footwear
  • textile products for base and underlying fabrics and stiffening
  • tobacco pouches
  • toilet cases
  • toys
  • travel goods
  • watch straps

Further information

The Department for Business, Energy and Industrial Strategy has produced more detailed guidance on the requirements: Textile labelling regulations: Guidance on the Textile Products (Labelling and Fibre Composition) Regulations 2012.

Other legislation

In addition to the specific textile legislation, the Consumer Protection from Unfair Trading Regulations 2008 prohibit misleading actions and omissions when describing products and services, as well as misleading prices.

Penalties

Failure to comply with trading standards law can lead to enforcement action and to sanctions, which may include a fine and/or imprisonment.

Key legislation

Cat and Dog Fur (Control of Import, Export and Placing on the Market) Regulations 2008

Consumer Protection from Unfair Trading Regulations 2008

Seal Products Regulations 2010

EU Regulation (EU) No 1007/2011 on textile fibre names and related labelling and marking of the fibre composition of textile products

Textile Products (Labelling and Fibre Composition) Regulations 2012

PLEASE NOTE

The information is intended for guidance only; only the courts can give you an authoritative interpretation of the law.

If you've enjoyed reading this, please share it: