COMPLIANCE DEEP DIVE
‘Made in’ and the DPP: Country-of-Origin Rules for Clothing and Footwear Under EU Customs and Consumer Law, and What the Passport May Add
Where a garment comes from has four different legal answers. Customs decides origin with product-specific rules; a ‘Made in’ label is a voluntary claim judged by consumer law; the digital product passport may carry origin information, but no act says so yet; and France already requires the places of manufacture next to the price online.
Customs origin and a ‘Made in’ claim are different things: under EU law, neither authorises nor forbids the other. Below are the customs rules for clothing and footwear word for word, the test for claims, what the passport may add and the French rule.
Art. 60(2)
Union Customs Code: goods made in more than one country originate where their last substantial, economically justified processing took place (Article 169(2) of the new Code from 21 September 2027).
Making-up
Annex 22-01 primary rule (complete making-up) for knitted garments assembled from pieces (chapter 61) and for finished garments of chapter 62, except headings 6213 and 6214.
None
General EU duty to mark the country of origin on clothing or footwear (Textile Labelling Regulation, Directive 94/11/EC and GPSR checked on 20 October 2026).
Q3–Q4 2027
Indicative adoption of the ESPR delegated act for textiles, which will decide whether the passport carries origin information (Commission DPP timeline).
1. The short answer
| Question | Answer today | Legal basis and status |
|---|---|---|
| Where does a garment come from for customs? | From the country of its last substantial processing, applied through list rules per heading: for most garments, complete making-up; for footwear, a change of heading | Union Customs Code, Article 60(2); Delegated Regulation (EU) 2015/2446, Article 32 and Annex 22-01 (law) |
| Must clothing or footwear carry a ‘Made in’ label? | No general EU duty. A voluntary claim must not mislead the average consumer about geographical origin | Unfair Commercial Practices Directive, Article 6(1)(b) (law) |
| Will the passport show origin? | Not decided. ESPR Annex III contains no origin item; the Commission names origin information only as content the textile passport may include | ESPR Annex III (law); Commission textile-apparel page (indicative) |
| What does France require? | For textile, household-linen and footwear products in the French EPR scope sold online: the places of manufacture, close to the price and in characters of the same size | Code de l'environnement, Article L. 541-9-1-2, in force since 10 July 2026 (national law) |
Customs origin serves tariffs and other trade measures; it does not by itself authorise a ‘Made in’ claim, and EU customs law does not forbid one. The claim is judged under consumer law by whether it misleads, and national rules can add duties (section 5).
We do not give product-specific origin advice. The origin of a given style depends on its tariff heading and on where each production step took place; on application, customs authorities take "decisions relating to binding origin information (BOI decisions)" (Article 33(1) of the Union Customs Code), which are binding on the authorities and the holder (Article 33(2)); the new Code keeps them (Article 15(1) of Regulation (EU) 2026/2108).
2. Customs origin: the rules for clothing and footwear
Customs work with non-preferential origin for the Common Customs Tariff, for non-tariff trade measures and for "other Union measures relating to the origin of goods" (Union Customs Code, Article 59). Preferential origin, which decides whether a reduced duty under a trade agreement or a unilateral EU preference scheme applies, follows the rules laid down in each agreement or adopted for each unilateral scheme (Article 64(2), (3) and (5)) and is not covered here.
The core rule today is Article 60(2) of Regulation (EU) No 952/2013: "Goods the production of which involves more than one country or territory shall be deemed to originate in the country or territory where they underwent their last, substantial, economically-justified processing or working, in an undertaking equipped for that purpose, resulting in the manufacture of a new product or representing an important stage of manufacture". From 21 September 2027, Article 169(2) of the new Union Customs Code, Regulation (EU) 2026/2108, contains the same rule; its English text writes "last, substantial, economically justified processing or working" without the hyphen. The new Regulation entered into force on 20 September 2026 and applies from 21 September 2027 (Article 287(1) and (2)). Delegated acts adopted under the old Code continue to apply until the Commission repeals them under the new one (Article 284(1)).
The detailed rules for garments sit in Delegated Regulation (EU) 2015/2446. Under its Article 32, "Goods listed in Annex 22-01 shall be considered to have undergone their last substantial processing or working, resulting in the manufacture of a new product or representing an important stage of manufacture, in the country or territory in which the rules set out in that Annex are fulfilled or which is identified by those rules". Annex 22-01 sets those rules per HS 2022 heading, including chapters 61 and 62 for apparel, chapter 64 for footwear and, in chapter 42, leather apparel (ex 4203). The key term for garments is defined in introductory note 1.4: "The term ‘complete making-up’ used in the list means that all the operations following cutting of the fabric or knitting or crocheting of the fabric directly to shape have to be performed. However, making-up shall not necessarily be considered as incomplete where one or more finishing operations have not been carried out".
| Product group | Heading(s) | Rule (Annex 22-01, verbatim) | What it means in practice |
|---|---|---|---|
| Knitted or crocheted apparel and clothing accessories (chapter 61) | 6101 to 6117, split ex (a) | "obtained by sewing together or otherwise assembling, two or more pieces of knitted or crocheted fabric which have been either cut to form or obtained directly to form": "Complete making-up" | Origin where all operations after cutting, or after knitting or crocheting the fabric directly to shape, were performed |
| Knitted or crocheted apparel and clothing accessories (chapter 61) | 6101 to 6117, split ex (b) | Other: "Manufacture from yarn" | Origin where the article was manufactured starting from yarn |
| Apparel and clothing accessories, not knitted or crocheted (chapter 62) | 6201 to 6212 and 6215 to 6217 | "finished or complete": "Complete making-up"; "unfinished or incomplete": "Manufacture from yarn" | A finished garment takes its origin from the complete making-up; an unfinished one only from manufacture from yarn |
| Handkerchiefs, shawls, scarves, mufflers, mantillas, veils and the like (chapter 62) | 6213 and 6214 | Embroidered: "Manufacture from yarn" or "Manufacture from unembroidered fabric, provided the value of the unembroidered fabric used does not exceed 40 % of the ex-works price of the product"; other: "Manufacture from yarn" | Making up from imported fabric is not enough; for embroidered items, manufacture from unembroidered fabric is enough within the 40 % value limit |
| Leather apparel (chapter 42) | ex 4203 | "Articles of apparel of leather or of composition leather": "Complete making-up" | Same test as for finished garments |
| Footwear (chapter 64) | 6401 to 6405 | "CTH with the exclusion of assembly of uppers affixed to inner or to other sole components of heading 6406" | A change of heading confers origin, except where the shoe is made from uppers already affixed to inner or other sole components of heading 6406 |
| Fallback (chapters 42, 61, 62 and 64) | Chapter residual rule | "Where the country of origin cannot be determined by application of the primary rules, the country of origin of the goods shall be the country in which the major portion of the materials originated, as determined on the basis of the value of the materials" | Applies only where the primary rule gives no answer |
The Annex glossary defines CTH as "change to the heading in question from any other heading". Under introductory note 2.5, non-originating materials that do not satisfy such a tariff-shift rule are disregarded if their total value does not exceed 10 % of the ex-works price of the good, unless a chapter provides otherwise.
Some operations never confer origin. Article 34 of the Delegated Regulation lists what "shall not be considered as substantial, economically justified processing or working for the purposes of conferring origin", among them "changes of packing and the breaking-up and assembly of consignments" (point (c)), "putting up of goods in sets or ensembles or putting up for sale" (point (d)) and "affixing of marks, labels or other similar distinguishing signs on products or their packaging" (point (e)). It adds: "For goods covered by Annex 22-01, the Chapter residual rules for those goods shall apply".
In short: for most garments, the decisive step is the complete making-up (in chapter 61 where the garment is assembled from pieces, in chapter 62 where it is finished or complete); sewing in a label or repacking elsewhere does not confer origin. Our guide The New EU Customs Code and the Digital Product Passport covers the wider changes for importers.
3. ‘Made in’ claims: no EU marking duty, but no misleading
EU law contains no general duty to mark the country of origin on clothing or footwear. The Textile Labelling Regulation (EU) No 1007/2011 lays down rules on "the use of textile fibre names and related labelling and marking of fibre composition of textile products", on non-textile parts of animal origin and on fibre analysis (Article 1). Its review clause asked the Commission's report to examine "an origin labelling scheme aimed at providing consumers with accurate information on the country of origin and additional information ensuring full traceability of textile products" (Article 24(3)(a)); the Regulation, last consolidated on 15 February 2018, contains no such scheme.
For footwear, Directive 94/11/EC applies "to the labelling of the materials used in the main components of footwear for sale to the consumer" (Article 1(1)): the upper, the lining and sock, and the outersole (Article 1(2)). The General Product Safety Regulation (EU) 2023/988 requires a type, batch or serial number and the manufacturer's name and postal and electronic address (Article 9(5) and (6)), not a country of origin.
A change is planned, not proposed. In its 2023 call for evidence on the revision of the textile labelling rules, the Commission wrote: "Additional labelling domains will also be explored, such as origin (‘made in’)"; footwear was excluded from that review. The initiative's Have your say page still shows Commission adoption planned for the second quarter of 2026; no proposal had been published by 20 October 2026. Our guide The EU Textile Labelling Regulation and the DPP covers the revision.
A voluntary ‘Made in’ claim is a commercial practice under the Unfair Commercial Practices Directive 2005/29/EC. Under Article 6(1), a practice is misleading if it "contains false information and is therefore untruthful or in any way, including overall presentation, deceives or is likely to deceive the average consumer, even if the information is factually correct", in relation to one of the listed elements, and causes or is likely to cause a transactional decision the consumer would not have taken otherwise. Point (b) lists the product's "geographical or commercial origin".
That origin element has been in point (b) since the original 2005 text. Directive (EU) 2024/825 replaced point (b) to add environmental or social characteristics and circularity aspects (its Article 1(2)(a)); Member States apply the amendments from 27 September 2026 (its Article 4(1)), the date of the current consolidated text. The origin wording did not change.
Under the Directive, the test is the effect on the average consumer, including the overall presentation, not the customs rule. The Textile Labelling Regulation's recital 20 states the same aim: "When such indications are used, they should enable consumers to be fully aware of the origin of the products they purchase, so as to protect them against fraudulent, inaccurate or misleading claims of origin". Keeping claims consistent with documented production data is the practical safeguard (section 6).
4. The DPP: origin is possible, not confirmed
ESPR Annex III sets out the elements from which the delegated acts choose the passport data: they "shall specify what data are to or can be included in the digital product passport from among the following elements". Origin, country of origin or place of manufacture is not among the items (a) to (l). The nearest are (a) "information required under Article 7(2), point (b), and Article 7(5) or by other Union law applicable to the relevant product group", (d) "relevant commodity codes, such as a TARIC code as defined in Regulation (EEC) No 2658/87" and (i) "unique facility identifiers", which identify locations or buildings in a product's value chain (Article 2(33)); a site identifier is not a statement of origin.
The Commission's textile-apparel page (last modified 7 August 2026, English only) says: "Depending on the final requirements of the delegated act, information may include, beyond sustainability-related product information, documentation relevant for compliance and traceability, as well as ancillary information such as", and its list includes "Origin information". It adds: "The exact information requirements will be defined through the relevant delegated acts and supporting technical specifications". This is an indicative description, not a legal requirement.
The textile delegated act has not been adopted. The Commission's indicative DPP timeline (page updated on 15 October 2026) places adoption of the ESPR delegated acts for textiles in Q3–Q4 2027 and notes: "Following the adoption of ESPR delegated acts, economic operators will have a transition period of at least 18 months".
One Commission proposal would put origin into the passport in a narrow case. Article 28(4) of the proposed Public Procurement Act, COM(2026) 590 of 9 September 2026 (procedure 2026/0265(COD)), reads: "If required for applying requirements under Article 73(2), economic operators shall indicate the country of origin of the goods that compose their tender, incorporating it, where applicable, into the digital product passport of the goods pursuant to Regulation (EU) 2024/1781". Article 73(2) would allow public buyers, among other measures, to "require that the goods, services and works offered originate in the Union or be covered goods, services or works", the European preference. Origin would follow the customs rules: "The origin of goods shall be determined in accordance with Title II, Chapter 2, Section 1 of Regulation (EU) No 952/2013" (Article 74(2)), the non-preferential rules in section 2.
The passport entry is thus limited to European-preference cases. The proposal amends ESPR only by deleting Article 65 and Article 74(3)(b) (Article 147(1)); it does not add origin to Annex III. It would apply two years after its entry into force (Article 149). It exists in English only and is in the preparatory phase in Parliament; the Have your say feedback period is open (end date shown on 20 October 2026: 15 December 2026) and "is being extended every day until this adopted proposal is available in all EU languages".
5. France: places of manufacture next to the online price
France has gone further than EU law. Article 2 of Loi n° 2026-602 of 8 July 2026, published in the Journal officiel of 9 July 2026, inserted Article L. 541-9-1-2 into the Code de l'environnement. In the only official language, French, it reads: "Les lieux de fabrication du produit mentionné au 11° de l'article L. 541-10-1 vendu en ligne doivent être portés à la connaissance du consommateur de manière claire et lisible sur la plateforme numérique, en caractères d'une taille égale à celle de l'indication du prix et à proximité de celui-ci". In English (our translation): the places of manufacture of the product referred to in point 11° of Article L. 541-10-1 that is sold online must be brought to the consumer's attention clearly and legibly on the digital platform, in characters of the same size as the price and close to it.
Point 11° of Article L. 541-10-1 is the French extended-producer-responsibility category that the EU notification describes as the textiles, household linen and footwear sector (TLC). The official consolidated code shows the article in force since 10 July 2026; the law sets later dates only for other articles. Unlike Article L. 541-9-1-1 on ultra-fast fashion, inserted by the same law, Article L. 541-9-1-2 contains no exception for persons established in another EU or EEA State. It also does not say who must display the information; it requires the display on the digital platform.
The law says lieux de fabrication, places of manufacture, in the plural, and does not define the term or refer to the customs rules. During the EU notification procedure (TRIS 2025/0336/FR), the Commission described the draft provision as one that "requires information on the manufacturing origin of any garment or textile sold online", and the French authorities clarified that "forthcoming rules or administrative provisions will require the identification of origin regarding Member States, if the product originates from the EU, determined by Articles 59 to 63 of the Union Customs Code, Articles 31 onwards and Annex 22-01 of Delegated Regulation (EU) 2015/2446 and Articles 57 to 59 of Implementing Regulation (EU) 2015/2447". We found no later notification of such rules in TRIS (search of 20 October 2026).
The Commission has not assessed the origin rules France announced, but it objected to the display duty itself under EU platform law. On the origin provision, the comments part of its letter C(2025) 6710 final of 29 September 2025, which also delivered a detailed opinion, states that the Commission "is not able to verify whether and how the French authorities intend to ensure compliance with EU law and therefore reserves its opinion" until those rules are notified. In the detailed opinion itself, the Commission listed the provision among those that "further supplement the obligations on intermediary service providers, in particular online platforms, contrary to the full harmonisation effect of the DSA". Sweden also issued a detailed opinion. In its reaction of 15 April 2026 the Commission maintained its Digital Services Act concerns, which cover "the information to be displayed on their online interfaces", and kept to its assessment that the notified draft, "in its current form, is incompatible with Union law". It acknowledged receipt of the adopted text on 30 July 2026; TRIS shows no later Commission message (checked 20 October 2026).
6. What to do now
| Step | Why |
|---|---|
| Record, per style, where each production step takes place: spinning, weaving or knitting, dyeing and finishing, cutting, making-up or assembly | The Annex 22-01 rule for the heading decides which step counts; it cannot be applied without this data. |
| Determine the non-preferential origin per heading with your customs adviser or broker; consider BOI decisions for key lines | Origin depends on the heading and the actual process. BOI decisions bind the authorities and the holder (Union Customs Code, Article 33). |
| Keep any ‘Made in’ claim on labels, product pages and marketing consistent with that evidence | A practice that deceives the average consumer about geographical origin is misleading, even where the information is factually correct (UCPD, Article 6(1)(b)). |
| If you sell online in France, check that the places of manufacture appear next to the price, in the same character size | Code de l'environnement, Article L. 541-9-1-2, in force since 10 July 2026. |
| Reuse the same supplier and site mapping for the passport and for forced-labour due diligence | One source of production data serves origin evidence, possible passport content and the work described in our guide The EU Forced Labour Regulation. |
| Watch the textile delegated act and COM(2026) 590 | The act will decide whether the passport carries origin information (indicative adoption Q3–Q4 2027); the proposal would link origin and the passport in public procurement. |
DPP AUDIT
Map where each production step happens before the passport asks.
We map your supply chain per production step, so origin, forced-labour and DPP data come from one source. Under NDA.
Start Your DPP Audit7. Dates to watch
| Date | What | Source |
|---|---|---|
| 9 July 2026 | Loi n° 2026-602 of 8 July 2026 published | Journal officiel n°0159 |
| 10 July 2026 | Article L. 541-9-1-2 of the Code de l'environnement in force (places of manufacture online) | Official consolidated code (Légifrance data) |
| 20 September 2026 | New Union Customs Code, Regulation (EU) 2026/2108, enters into force | Regulation (EU) 2026/2108, Article 287(1) |
| 27 September 2026 | Amendments to the Unfair Commercial Practices Directive by Directive (EU) 2024/825 apply; the origin element in Article 6(1)(b) is unchanged | Directive (EU) 2024/825, Article 4(1) |
| 15 December 2026 at the earliest | End of the Have your say feedback period on COM(2026) 590 as shown on 20 October 2026; the eight-week period is extended every day until the proposal is available in all EU languages | Have your say, initiative 15492 |
| 21 September 2027 | Article 169 of the new Code applies in place of Article 60 of Regulation (EU) No 952/2013 | Regulation (EU) 2026/2108, Article 287(2) |
| Q3–Q4 2027 (indicative) | Adoption of the ESPR delegated act for textiles, which will decide whether the passport carries origin information | Commission DPP timeline |
Frequently asked questions
Can we write ‘Made in Italy’ if only the finishing is done in Italy?
Is there an EU duty to put the country of origin on clothing labels?
Will the DPP show where my clothes were made?
Does the new Customs Code change origin rules?
What does France require online?
Sources
- Union Customs CodeRegulation (EU) No 952/2013 of the European Parliament and of the Council of 9 October 2013 laying down the Union Customs Code (recast) (OJ L 269, 10.10.2013, p. 1), consolidated version of 12 December 2022. Articles 33, 59, 60 and 64. Repealed by Regulation (EU) 2026/2108 from 21 September 2027. CELEX 02013R0952-20221212 (consolidated) ↗
- The new Union Customs CodeRegulation (EU) 2026/2108 of the European Parliament and of the Council of 16 September 2026 establishing the Union Customs Code and the European Union Customs Authority, and repealing Regulation (EU) No 952/2013 (OJ L, 2026/2108, 19.9.2026). Articles 15, 169, 284 and 287. No corrigendum concerns the English version. CELEX 32026R2108 ↗
- Delegated Regulation (EU) 2015/2446Commission Delegated Regulation (EU) 2015/2446 of 28 July 2015 supplementing Regulation (EU) No 952/2013 of the European Parliament and of the Council as regards detailed rules concerning certain provisions of the Union Customs Code (OJ L 343, 29.12.2015, p. 1), consolidated version of 1 July 2026. Articles 32 and 34; Annex 22-01 (introductory notes 1.4, 2.5 and 3; chapters 42, 61, 62 and 64). CELEX 02015R2446-20260701 (consolidated) ↗
- Unfair Commercial Practices DirectiveDirective 2005/29/EC of the European Parliament and of the Council of 11 May 2005 concerning unfair business-to-consumer commercial practices in the internal market and amending Council Directive 84/450/EEC, Directives 97/7/EC, 98/27/EC and 2002/65/EC of the European Parliament and of the Council and Regulation (EC) No 2006/2004 of the European Parliament and of the Council (OJ L 149, 11.6.2005, p. 22), consolidated version of 27 September 2026 and original text. Article 6(1). CELEX 02005L0029-20260927 (consolidated) ↗ · CELEX 32005L0029 ↗
- Directive (EU) 2024/825Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information (OJ L, 2024/825, 6.3.2024). Articles 1(2)(a) and 4(1). CELEX 32024L0825 ↗
- 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 (OJ L 272, 18.10.2011, p. 1), consolidated version of 15 February 2018 and original text. Recital 20; Articles 1 and 24. CELEX 02011R1007-20180215 (consolidated) ↗ · CELEX 32011R1007 ↗
- Footwear labellingDirective 94/11/EC of the European Parliament and of the Council of 23 March 1994 on the approximation of the laws, regulations and administrative provisions of the Member States relating to labelling of the materials used in the main components of footwear for sale to the consumer (OJ L 100, 19.4.1994, p. 37), consolidated version of 1 July 2013. Article 1. CELEX 01994L0011-20130701 (consolidated) ↗
- General product safetyRegulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety, amending Regulation (EU) No 1025/2012 of the European Parliament and of the Council and Directive (EU) 2020/1828 of the European Parliament and the Council, and repealing Directive 2001/95/EC of the European Parliament and of the Council and Council Directive 87/357/EEC (OJ L 135, 23.5.2023). Article 9(5) and (6). CELEX 32023R0988 ↗
- ESPRRegulation (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 (OJ L, 2024/1781, 28.6.2024). Article 2(33); Annex III. CELEX 32024R1781 ↗
- COM(2026) 590 — proposalEuropean Commission, Proposal for a Regulation of the European Parliament and of the Council on public contracts and concessions, repealing Directives 2014/23/EU, 2014/24/EU and 2014/25/EU, and amending Regulations (EC) No 1370/2007, (EU) 2023/1542, (EU) 2024/1157, (EU) 2024/1252, (EU) 2024/1735, (EU) 2024/1781, (EU) 2024/2847, (EU) 2024/3110 and (EU) 2025/40, and Directives 2008/98/EC, (EU) 2019/882, (EU) 2022/2381, (EU) 2023/1791 and (EU) 2024/1760 (Public Procurement Act), COM(2026) 590 final, 9.9.2026, procedure 2026/0265(COD). Articles 28(4), 73(2), 74(2), 147(1) and 149. English only; not adopted. CELEX 52026PC0590 ↗ · Have your say, initiative 15492 ↗ · Legislative Observatory ↗
- European CommissionEuropean Commission, Textile Apparel and the Digital Product Passport (DPP), section Key requirements (last modified 7 August 2026), and Digital Product Passport page with the indicative DPP timeline (updated 15 October 2026). English only. Textile apparel page ↗ · DPP page ↗
- Textile labelling revision — planEuropean Commission, Have your say, initiative 13872, Textile labelling rules (revision): call for evidence for an impact assessment, Ares(2023)5383786 of 3 August 2023; Commission adoption planned for the second quarter of 2026. Have your say, initiative 13872 ↗
- France — national lawLoi n° 2026-602 du 8 juillet 2026 visant à réduire l'impact environnemental de l'industrie textile, Journal officiel de la République française n°0159 du 9 juillet 2026 (NOR TECX2407166L), Article 2, inserting Article L. 541-9-1-2 into the Code de l'environnement. Official in French only. Légifrance (ELI) ↗
- TRIS 2025/0336/FREuropean Commission, Technical Regulation Information System, notification 2025/0336/FR, Draft Law aimed at reducing the environmental impact of the textile industry: Commission detailed opinion and comments C(2025) 6710 final of 29 September 2025; Commission reaction TRIS/(2026) 1084 of 15 April 2026; acknowledgement of receipt of the final text of 30 July 2026. technical-regulation-information-system.ec.europa.eu ↗
The legal acts were read in their Official Journal versions and, where stated, in their consolidated versions published by the Publications Office of the European Union (EUR-Lex); consolidations are documentation tools without legal effect. The Publications Office records were searched for later consolidations, amendments and corrigenda on 20.10.2026. The Commission's textile-apparel and DPP pages and COM(2026) 590 exist in English only; the textile labelling call for evidence on Have your say exists in 24 languages. The French law is official only in French; it was read in the official Journal officiel and consolidated-code data published by the French legal information service (DILA). All sources were accessed on 20.10.2026. This is general information, not legal, financial or investment advice.