COMPLIANCE DEEP DIVE
The EU Textile Labelling Regulation and the DPP: Fibre-Composition Rules, Testing and the Planned Revision
Regulation (EU) No 1007/2011, the Textile Labelling Regulation (TLR), has applied since 8 May 2012. Textile products made available on the EU market must carry a label or a marking that states their fibre composition, using only the fibre names listed in the regulation, by percentage of weight in descending order. The same composition must be clearly visible to the consumer before the purchase, including online, and the label or marking must be 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. Market surveillance authorities test products against the stated composition, and since 23 July 2026 a designated Union testing facility for textiles in Athens is available to them.
This guide covers what the TLR requires today, how compliance is checked and penalised, what the new testing facility may and may not do, how fibre composition connects to the Digital Product Passport (DPP), and where the planned revision of the TLR stands on 16 October 2026. The short version: the composition data you already manage for the label is data that the Commission names as possible DPP content where relevant, but no DPP is required for textiles yet and nothing in today's law lets a QR code replace the label.
8 May 2012
The date from which Regulation (EU) No 1007/2011 applies (Article 28). Its rules apply whenever a textile product is made available on the EU market.
3 %
The manufacturing tolerance permitted between the fibre composition stated on the label or marking and the result of a laboratory analysis (Article 20(3)).
23 Jul 2026
Entry into force of Commission Implementing Decision (EU) 2026/1481, which designates a Union testing facility for textiles in Athens (Article 3 of the Decision).
1. What the Textile Labelling Regulation requires today
The TLR applies to textile products when they are made available on the Union market, and to certain products that it treats in the same way as textile products (Article 2(1) and (2)). Its starting point is Article 4: textile products may only be made available on the market if they are labelled, marked or accompanied with commercial documents in compliance with the regulation. Its rules concern fibre names, the labelling or marking of the fibre composition, the indication of non-textile parts of animal origin, and how the composition is determined by analysis (Article 1). The Commission's review page states that the current labelling rules "are limited to the fibre composition of textile products"; care, size and origin information are not TLR requirements today.
| Rule | What it means for a garment | Provision |
|---|---|---|
| Fibre names | Only the fibre names listed in Annex I may be used to describe the fibre composition on labels and markings. Each name is reserved for fibres that match its description in Annex I and may not be used for other fibres, on its own, as a root or as an adjective. The consolidated Annex I has 50 numbered entries; the latest, polyacrylate, was added by Delegated Regulation (EU) 2018/122. | Article 5; Annex I |
| Descending order | The label or marking states the name and percentage by weight of all constituent fibres in descending order. A fibre of up to 5 % of the total weight, or fibres that together account for up to 15 %, may be designated as "other fibres" with their total percentage where they cannot easily be stated at the time of manufacture. Fibres not yet listed in Annex I may also be designated that way. | Article 9(1), (2) and (5) |
| 100 %, pure, all | Only products exclusively composed of the same fibre may be labelled or marked as 100 %, pure or all. Up to 2 % by weight of extraneous fibres, or up to 5 % for a product that has undergone a carding process, is allowed if it is technically unavoidable in good manufacturing practice and not added as a matter of routine. | Article 7 |
| Decorative and antistatic fibres | Visible, isolable, purely decorative fibres of up to 7 % of the weight of the finished product, and metallic fibres and other fibres incorporated to obtain an antistatic effect of up to 2 %, do not have to be taken into account in the composition. | Article 10(1) and (2) |
| Several components | A product with two or more components of different fibre content states the fibre content of each component. This is not compulsory for a component only if it is not a main lining and represents less than 30 % of the total weight of the product; both conditions must be met. | Article 11(1) and (2) |
| Animal-origin parts | Products containing non-textile parts of animal origin carry the phrase "Contains non-textile parts of animal origin" on the labelling or marking whenever they are made available on the market. | Article 12(1) |
| Exceptions | No fibre-composition labelling is required for the products listed in Annex V, among them watch straps of textile materials, labels and badges, and old made-up textile products where explicitly stated to be such. This exemption does not apply where a trade mark or the name of the undertaking contains an Annex I fibre name, on its own or as a root or as an adjective, or a name liable to be confused with one. Products listed in Annex VI of the same type and fibre composition may carry an inclusive labelling. | Article 17(2) and (3); Annexes V and VI |
| Outside the scope | Textile products contracted out to home workers or independent firms working on supplied materials without the property being transferred for consideration, and customised products made up by self-employed tailors. | Article 2(3) and (4) |
The obligation sits with the company that places the product on the market. The manufacturer ensures the supply of the label or marking and the accuracy of the information on it; where the manufacturer is not established in the Union, the importer does (Article 15(1)). A distributor is considered a manufacturer where it "places a product on the market under his name or trademark, attaches the label himself or modifies the content of the label" (Article 15(2)). For a fashion brand selling under its own name, on that wording, the label's accuracy is its own responsibility, whoever produced the garment. Other distributors must ensure that the products they sell bear the labelling or marking the regulation prescribes (Article 15(3)).
2. Label or marking, the language rule and online sales
Article 14(1) is the core sentence: "Textile products shall be labelled or marked to give an indication of their fibre composition whenever they are made available on the market." The labelling and marking must be "durable, easily legible, visible and accessible and, in the case of a label, securely attached". The regulation allows two forms. Labelling means attaching a label to the product; marking means indicating the required information directly on the product "by way of sewing, embroidering, printing, embossing or any other technology of application" (Article 3(1)(g) and (h)). On that wording, a code that only links to the information elsewhere does not indicate the information on the product; the Commission's review page notes that "only physical labels are currently foreseen".
Between businesses, labels or markings may be replaced or supplemented by accompanying commercial documents when products are supplied to economic operators within the supply chain (Article 14(2)). Those documents must state the fibre names and composition clearly; abbreviations are allowed only as a mechanised processing code or where defined in international standards and explained in the same document (Article 14(3)). That replacement is limited to supplies within the supply chain and to deliveries ordered by contracting authorities; for products sold to consumers, the label or marking cannot be replaced by commercial documents.
Article 16(1) extends the composition beyond the label. When a textile product is made available on the market, the composition descriptions must be indicated in catalogues and trade literature, on packaging, labels and markings in a manner that is easily legible, visible and clear, in print uniform in size, style and font. The information must be "clearly visible to the consumer before the purchase, including in cases where the purchase is made by electronic means". On that wording, every product page in your webshop and on marketplaces needs the composition before checkout; see our online-selling guide for the wider online duties. Trade marks or the company name may appear immediately before or after the composition, and other information must always be displayed separately (Article 16(2)); no information may be confusable with the fibre names and composition descriptions (Article 15(4)).
The language rule is in Article 16(3): the labelling or marking must be in the official language or languages of the Member State on whose territory the products are made available to the consumer, "unless the Member State concerned provides otherwise". A brand selling in several countries therefore needs the composition in each country's official language or languages, or must check what that Member State allows instead.
3. How compliance is checked, and who sets the penalties
Market surveillance authorities check whether the fibre composition of textile products conforms with the information supplied (Article 18). The TLR sets the method of that check in detail:
| Step | Rule | Provision |
|---|---|---|
| Test method | The checks follow the methods for quantitative analysis in Annex VIII, or harmonised standards to be introduced in that Annex. | Article 19(1); Annex VIII |
| What is left out | Items listed in Annex VII are not counted, among them non-textile parts, selvedges, labels and badges, buttons and buckles covered with textile materials, and certain processing products. | Article 19(2); Annex VII |
| Calculation | The composition is determined by applying the agreed allowance in Annex IX to the anhydrous mass of each fibre, after removing the Annex VII items. | Article 19(3); Annex IX |
| Mixtures without an EU method | The laboratory determines the composition and states the result, the method used and its degree of accuracy in the analysis report. | Article 19(4) |
| Extraneous fibres | Extraneous fibres need not be indicated below 2 % of total weight, or 5 % for carded products, if technically unavoidable in good manufacturing practice and not added as a matter of routine. | Article 20(2) |
| Manufacturing tolerance | 3 % between the stated composition and the analysis result, in relation to the total weight of fibres shown on the label or marking; it also applies to fibres designated as other fibres. | Article 20(3) |
The TLR also appears twice in the EU market surveillance regulation, Regulation (EU) 2019/1020. It is item 40 in Annex I, the list of Union harmonisation legislation to which that regulation applies, except where the TLR contains specific provisions with the same objective that regulate particular aspects of market surveillance and enforcement in a more specific manner (Article 2(1)). The TLR's own rules on how fibre-composition checks are carried out are in its Articles 18 to 20. This gives the authorities the general toolbox of Regulation (EU) 2019/1020, for example the powers to require documents and data on compliance, to acquire product samples, including under a cover identity, and, where the economic operator fails to take appropriate corrective action or the non-compliance or the risk persists, to prohibit or restrict the making available of a product or order its withdrawal or recall (Article 14(4), points (a), (h) and (j)).
It is also item 17 in Annex II, headed "List of Union harmonisation legislation without provisions on penalties". The TLR itself contains no penalty provision. Article 41 of Regulation (EU) 2019/1020 fills that gap: Member States lay down the rules on penalties for infringements of the legislation listed in Annex II that imposes obligations on economic operators, and those penalties must be effective, proportionate and dissuasive. Penalty levels can therefore differ by country; our penalties and market surveillance guide explains how national enforcement works.
4. The new Union testing facility for textiles
Commission Implementing Decision (EU) 2026/1481 of 2 July 2026, published in the Official Journal on 3 July 2026, designates the Directorate-General for the General Chemical State Laboratory of Greece's Independent Authority for Public Revenue, in Athens, as a Union testing facility for textiles (Article 1). The Decision entered into force on the twentieth day following its publication (Article 3), that is on 23 July 2026. The laboratory was selected after a call for expression of interest covering two categories, machinery and textiles (recitals 2 to 5), the procedure laid down for public testing facilities of Member States in Article 1(1) of Implementing Regulation (EU) 2022/1267. The designation is to be reviewed by 23 July 2031 and every five years thereafter (Article 2 of the Decision); where a facility fails to comply with the conditions and requirements, the Commission, after consulting the Network, shall, where appropriate, withdraw the designation (Article 2(3) of Implementing Regulation (EU) 2022/1267).
What a Union testing facility may do is set by Article 21 of Regulation (EU) 2019/1020. Its services are provided "solely to market surveillance authorities, the Network, the Commission and other government or intergovernmental entities" (Article 21(5)). Within its area of competence it carries out testing of products at the request of market surveillance authorities, the Network or the Commission, provides independent technical or scientific advice at the request of the Network, and develops new techniques and methods of analysis (Article 21(6)). Union testing facilities must be accredited (Article 21(3)), and their designation does not affect the freedom of authorities to choose other testing facilities (Article 21(4)).
Two practical consequences follow from that wording. A brand cannot commission tests from the facility; it works for authorities. And the Decision designates it for the category of textiles without listing the legal acts or tests concerned; nothing in the Decision or in Article 21(6) gives it a role in certifying products or verifying marketing claims. For your own compliance evidence, you still rely on your own or your suppliers' laboratory reports.
5. How fibre composition connects to the Digital Product Passport
There is no DPP requirement for textiles yet. Textile-specific DPP requirements will be set by an ESPR delegated act; the Commission's textile apparel DPP page gives, in its indicative timeline, Q4 2027 as the planned adoption of the ESPR delegated act for textiles, and the Publications Office records show no such act as of 16 October 2026. For the timing, see our DPP readiness checklist.
The ESPR already provides for the link. Recital 32 of Regulation (EU) 2024/1781 says that it should be possible for the passport to be used for providing information pursuant to other Union law, and Annex III lists, among the elements from which a delegated act selects the passport data, "information required under Article 7(2), point (b), and Article 7(5) or by other Union law applicable to the relevant product group" (point (a)). The Commission's page on textile apparel and the DPP lists, among the ancillary information the passport may include depending on the final delegated act, "Fibre composition (as required under the Textile Labelling Regulation), where relevant for the DPP". Whether and how fibre composition becomes a DPP field is therefore open until the delegated act is adopted.
Two conclusions hold on today's texts. First, the DPP does not replace the TLR label or marking: the TLR contains no provision allowing that, so under today's texts a passport would come in addition to the label or marking, not instead of it. Second, the composition you put on the label, on your product pages and in your commercial documents is the same data a passport may carry if the delegated act includes it. Keeping one master composition record per product and component, from which the label, the webshop and later the DPP are fed, avoids three versions of the truth. That is good practice, not a legal requirement.
6. The planned revision: where it stands
Status on 16 October 2026
As of 16 October 2026, the Commission has not adopted or published a proposal to revise the TLR. Its Have Your Say initiative 13872, "Textile labelling rules (revision)", lists a proposal for a regulation as planned for the second quarter of 2026 and still upcoming; the Commission's review page, last updated on 12 January 2026, also refers to "the planned proposed revision of this regulation by the second quarter of 2026". The Publications Office index of 2026 Commission proposals, checked on 16 October 2026, contains no proposal on textile labelling, and the TLR has not been amended since Delegated Regulation (EU) 2018/122 (corrigenda to individual language versions aside). Until a revision is adopted and applies, the rules described above remain the law.
The initiative summary on Have Your Say describes the aim as "introducing comprehensive requirements on the physical and digital labelling of textiles and related products". A call for evidence was open from 3 August to 30 September 2023, a public consultation ran from 19 December 2023 to 15 April 2024, and a validation workshop with stakeholders took place on 18 October 2024 (Commission review page). The call for evidence, which does not prejudge the Commission's final decision, sets out the options: revising and updating the fibre identification rules, digital labelling "building on the proposed architecture for the Digital Product Passport", language-independent symbols or codes, and a sustainability and circularity label. It also names further labelling domains to be explored, including origin, EU-wide uniform size, care labelling, allergenic substances, leather and fur authenticity, flammability, organic or bio-origin and socially responsible production, with sub-options on whether they would be voluntary or mandatory. Footwear is excluded, as its labelling is governed by Directive 94/11/EC.
The Study on DPP content for textile apparel products under ESPR (May 2026), which supports the ESPR textile delegated act, also refers to the revision. It is a non-binding external study prepared for the Joint Research Centre (JRC), listed by the JRC with the date 13 May 2026 and watermarked as a draft, and its contents "do not necessarily reflect the position or opinion of the European Commission". Its section 5.1 lists care instructions, origin (the place of making-up), size and the composition of non-textile parts as under consideration for the revision, in each case with "basic mandatory information on the physical label, supplementary voluntary information on the digital label, hosted on the DPP". That is a description of options under study, not a proposal.
7. What to do now
Build one composition record per product. For each article and each component, record the Annex I fibre names, the percentages by weight in descending order, which component is the main lining, and whether non-textile parts of animal origin are present (Articles 5, 9, 11 and 12). Feed the label or marking, the product pages, the catalogues and the commercial documents from that record, so that the same composition appears everywhere (Articles 14 and 16).
Check the names and the claims. Remove fibre names that are not in Annex I, any information that can be confused with fibre names, and 100 %, pure or all where the product is not composed exclusively of the same fibre; place trade marks or company names that contain or resemble a fibre name immediately before or after the composition (Articles 5, 7, 15(4) and 16(2)).
Keep the test evidence. Hold laboratory reports that state the method used, ideally the Annex VIII methods, and compare results against the 3 % manufacturing tolerance (Articles 19 and 20). Authorities may require compliance documents and data and acquire samples, including under a cover identity (Regulation (EU) 2019/1020, Article 14(4)).
DPP AUDIT
The same composition data feeds your label, your shop and, possibly later, your passport.
Fibre composition must already be correct on the label or marking, on every product page and in your commercial documents, and the Commission lists it as possible DPP content where relevant. In a DPP audit we check how that data is recorded per product and per component and where it falls short of the Textile Labelling Regulation. Under NDA.
Start Your DPP AuditFix online and language gaps. Show the composition on every product page before checkout (Article 16(1)), and provide the label or marking in the official language or languages of each Member State where you sell to consumers, unless that Member State provides otherwise (Article 16(3)).
Do not plan a digital-only label. A QR code or a future DPP may add information, but under today's TLR the composition must be on a label or a marking. Follow Have Your Say initiative 13872 and the ESPR textile delegated act, and review your labelling once either is published.
Frequently asked questions
Can a QR code or the Digital Product Passport replace the fibre-composition label?
Do we have to show the fibre composition in our webshop?
In which language must the label be?
Can our brand send products to the new EU testing facility in Athens?
Does fibre composition already have to be in a Digital Product Passport?
Sources
- Textile Labelling RegulationRegulation (EU) No 1007/2011 of the European Parliament and of the Council of 27 September 2011 on textile fibre names and related labelling and marking of the fibre composition of textile products and repealing Council Directive 73/44/EEC and Directives 96/73/EC and 2008/121/EC of the European Parliament and of the Council, consolidated version of 15 February 2018 (incorporating the Addendum of 21 December 2011, Delegated Regulations (EU) No 286/2012 and (EU) 2018/122, Council Regulation (EU) No 517/2013 and the corrigendum of 18 September 2015). Articles 1 to 5, 7, 9 to 12, 14 to 20 and 28; Annexes I, V, VI, VII, VIII and IX. CELEX 02011R1007-20180215 ↗ CELEX 32011R1007 ↗
- Market surveillance regulationRegulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 on market surveillance and compliance of products and amending Directive 2004/42/EC and Regulations (EC) No 765/2008 and (EU) No 305/2011, consolidated version of 12 August 2026. Articles 2, 14, 21 and 41; Annex I, item 40; Annex II, item 17. CELEX 02019R1020-20260812 ↗
- Union testing facility for textilesCommission Implementing Decision (EU) 2026/1481 of 2 July 2026 designating a Union testing facility for textiles in accordance with Regulation (EU) 2019/1020 of the European Parliament and of the Council (OJ L, 3.7.2026). Recitals 2 to 7, Articles 1 to 3. CELEX 32026D1481 ↗ Commission Implementing Regulation (EU) 2022/1267 of 20 July 2022 specifying the procedures for the designation of Union testing facilities for the purposes of market surveillance and verification of product compliance in accordance with Regulation (EU) 2019/1020 of the European Parliament and of the Council. Articles 1 and 2. CELEX 32022R1267 ↗
- Ecodesign regulation (ESPR)Regulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC. Recital 32, Article 7, Annex III. CELEX 32024R1781 ↗
- Commission pagesEuropean Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs: "Review of Regulation (EU) 1007/2011" single-market-economy.ec.europa.eu ↗ and "Textile Apparel and the Digital Product Passport (DPP)" single-market-economy.ec.europa.eu ↗.
- Have Your Say initiative 13872European Commission, Have Your Say: "Textile labelling rules (revision)" (initiative 13872), including the call for evidence for an evaluation and impact assessment, Ref. Ares(2023)5383786 of 3 August 2023. ec.europa.eu ↗
- External study prepared for the JRC — proposed DPP data content (draft)González-Torres, M., Arcipowska, A.: "Study on DPP content for textile apparel products under ESPR", JRC Science for Policy Report, external study prepared for the Joint Research Centre, 2026 (listed by the JRC with the date 13 May 2026 and watermarked as a draft). Section 5.1. susproc.jrc.ec.europa.eu ↗
Regulation (EU) No 1007/2011 (consolidated version of 15 February 2018), Regulation (EU) 2019/1020 (consolidated version of 12 August 2026), Implementing Decision (EU) 2026/1481, Implementing Regulation (EU) 2022/1267 and Regulation (EU) 2024/1781 were read in the versions published by the EU Publications Office (EUR-Lex); the Publications Office records show no Commission proposal to revise Regulation (EU) No 1007/2011 and no ESPR delegated act for textiles as of 16.10.2026. The Commission, Have Your Say and JRC pages were accessed on 16.10.2026. This is general information, not legal, financial or investment advice.