This is the third blog post in the beginners guide series on importing from China. In this post I will discuss an outline on importing textiles, fashion or clothing from China. Before you get started with this blog post I highly recommend that you check out my general but extensive guide on compliance and certification when importing from China HERE.
Importing textiles from China doesn’t have such strict regulations as for example electronics. However there are still a few things you’ll have to consider. This guide covers some of the following products:
Product examples:
- T-Shirts
- Shorts
- Pullovers
- Cardigans
- Outdoor Wear
- Coats
- Towels
- Trousers
- & similar items
There are 2 main regulations that you have to comply with, both for the US and Europe.
In the US we have the CPSC (Consumer Products Safety Commission) and the CPSIA (Consumer Product Safety Improvement Act). In Europe you have REACH and the GPSD (General Product Safety Directive). A few other things have to be considered such as Oektotex, dye or color fastness tests and others. So lets have a look at details:
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GENERAL UNITED STATES TEXTILE IMPORT REQUIREMENTS
As I mentioned, for the US we mainly have to comply with the CPSC & the CPSIA.
What are those? The CPSC (Consumer Product Safety Commission) regulates substances in consumer products. It maintains a list of mandatory standards and restricted chemicals. The U.S. Consumer Product Safety Commission Improvement Act (CPSIA) expanded and introduced new certification requirements for consumer goods imported into the United States for consumption, warehousing or for distribution in commerce. These certificates are required to accompany all imports. However, it is the responsibility of the shipper (importer) to comply with the requirements.
On top of that you may need a Childrens Product Certificate (CPC). For every child’s product you need to have a CPC. Certification means the issuance of a written Children’s Product Certificate (CPC) in which the manufacturer or importer certifies that its children’s product complies with all applicable children’s product safety rules. You as the importer must issue the certificate. However it is recommended that you have third party evidence that your product complies with all standards and laws.
The certificate does not need to be filed anywhere however it must “accompany” the shipment and must be presented at any time upon request to the CPSC.
What does that mean? When your shipment leaves China it is best you have the CPC ready and in soft copy so that you can present it upon request. It doesn’t cost anything but you need to make sure that you comply with all laws.
Textile, wearing apparel and flat goods generally require very specific information or documentation to properly classify and process for entry. The generic names and percentages by weight of the constituent fibers present in the textile
fiber product, exclusive of permissive ornamentation, in amounts greater than five percent must be listed on labels and Commercial Invoice. Constituent fibers must be listed in order of
predominance by weight. Any fiber or fibers present in amounts of five percent or less must be designated as “other fiber” or “other fibers” and must appear last in this list.
A commercial invoice is required for each shipment of textile fiber products worth more than $500. Commercial invoices for textile fiber products that are subject to the Act’s labeling requirements must contain the information mentioned below in “labeling requirements” as well as the information normally required on invoices. Regulations and pamphlets containing the text of the Textile Fiber Products Identification Act may be obtained from the Federal Trade Commission, Washington, DC 20580. Pursuant to Section 204 of the Agricultural Act of 1956, imported textiles and Textile products may, in addition to labeling requirements, also be subject to quota, visa, export-license or other entry requirements, including declarations that identify the fabricated components.
CHEMICAL REQUIREMENTS UNITED STATES
DECLARATION OF CONFORMITY California Prop65
California Prop65 – Lead Declaration of Conformity California Prop65 – Phatalate Declaration of Conformity
Labeling – Meet General labeling requirements
(see below)
LABELLING REQUIREMENTS UNITED STATES
The following labelling requirements are necessary for the United States on your imported product:
- The name of the manufacturer (you or your supplier), or the name or identification
number issued by the Federal Trade Commission of the person(s) marketing or
handling the textile fiber product. A word trademark, used as a house mark, that is
registered with the United States Patent Office may be used on labels in lieu of the
name otherwise required if the owner of such trademark furnishes a copy of the
Patent Office registration to the Federal Trade Commission (FTC) prior to use. - The name of the country where the product was processed or manufactured (e.g.
Made in China). To be printed or applied - For own-brand products, add name and address of your company
- Item number and item description in local language
- Instruction manual in local language and in adequate translation
- National trademark of a packaging recovery organization ()
- UPC bar code or Third Party Seller Identification (e.g. Amazon’s FNSKU)
- International care symbols on product (e.g. washing instructions)
- Material mix (e.g. 60% Polyester / 40% Wool…)
GENERAL EUROPEAN UNION TEXTILE PRODUCTS IMPORT REQUIREMENTS
It is recommended that you have a supplier who can both supply a REACH certificate as well as color fastness (TKG) & AZO-DYE test reports. Color fastness & AZO-DYE
is not required by law but you’ll want to have a product that doesn’t dye all your other items when being washed. These tests are usually very cheap and are highly recommended. OEKOTEX is highly recommended.
OEKOTEX is an independent testing and certification system for textile products from all stages of production (fibres, yarns, fabrics, ready-to-use end products, including accessories) along the textile value chain.
The label, ‘Confidence in Textiles’ of the product-related Oeko-Tex Standard 100 (textiles tested for harmful substances) is supplemented by the certification of
environmentally friendly production facilities according to Oeko-Tex Standard 1000 and by the product label Oeko-Tex Standard 100plus for products tested for harmful
substances from environmentally friendly production.
CHEMICAL REQUIREMENTS EUROPEAN UNION FOR TEXTILES
SVHC according to REACH Recommended < 0.1%
PAH’s REQUIRED Declaration of Conformity
Textile Labelling Act (TKG) – Declaration of Conformity (EC-DOC)
Prohibition of Chemicals Ordinance
(ChemVerbV) – Declaration of Conformity (EC-DOC)
LABELLING REQUIREMENTS EUROPEAN UNION FOR TEXTILES
The following labelling requirements are necessary for the European Union on your imported textile product:
- Brand / Name and address of the manufacturer or importer
- For own-brand products, add name and address of your company
- Item number and item description in local language
- Instruction manual in local language and in adequate translation
- National trademark of a packaging recovery organization (e.g. WEEE)
- EAN and EAN bar code
- International care symbols on product (e.g. washing instructions)
- Material mix (e.g. 60% Polyester / 40% Wool…)
PRODUCT REQUIREMENT PROFILE / TECHNICAL FILE FOR TEXTILES
A Product Requirement Profile (PRP) or sometimes also referred to as technical file would be the ideal situation to send to your supplier. What this file is is basically a document that includes all the necessary information that your supplier needs to comply with. Rather than sending a long email with regulations and compliance laws you could send this PRP as an overview to your supplier. I have prepared a fully comprehensive Profile Requirement Profile for all products (including household products) that I send to my suppliers. These are available for purchase from me here at the bottom of this page.
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CERTIFICATIONS
So now that you know what kinds of regulations you need to comply with you need to decide whether you go for full certification or self-declarations. You are probably asking what’s the difference?
A full certification is basically issued by a third-party testing laboratory such as INTERTEK, QIMA, TUV, SGS or others. It’s the best insurance for your product that you can get.
Obviously these cost money and in some cases thousands of $. The second option is to self-declare your product.
Meaning you issue the “certificate” yourself. I would only recommend doing that if you know what you are doing.
On top of that if you self-declare you blindly trust your supplier (if they do not have certificates in the first place). There are self-declaration templates for almost any regulation. E.g. for the CPSC or the REACH certificate you can self-declare with a pre-made template. I urge you to understand what you are importing and what the potential risks of your products are. For example a heater with 2000Watt has a much higher risk to import than a salad bowl. The heater can be tipped by a child and potentially burn down the house if there isn’t a safety switch (or tip over switch in this case). A salad bowl can’t really cause much damage. I think you get the picture.
FULL CERTIFICATION:
Having a full certification on a product is the best and safest way to go. What does that actually mean? Lets look at an example: You want to import kids t-shirts. You’ll want to avoid issues with Amazon or local authorities (depending on which channel you sell). You’ll also want to avoid any product quality issues such as chemicals inside the fabric that would give a child a rash. So ideally you’ll want a supplier with a OEKOTEX or similar certification for your specific product. You may also want a Children’s Product Certificate (CPC) for the US or a REACH certificate for the EU which tests different kind of chemicals that are harmful to the human body.
If possible find a manufacturer who has a fully certified product. Those are likely suppliers who work with large western retailers. Having said that if say the material used for your t-shirt has not been tested with the particular color that you want but on other solos I’d be fine with it. If you want to make sure that you comply or satisfy authorities you may ask the supplier to issue a Letter of Guarantee that the entire product has been manufacturerd according to standard or regulation “X”. But satisfying authorities should not be your eventual goal. Your evenutal goal should be to import a safe and reliable product that lasts and delivers good reviews or sales.
A full certification is quite expensive and therfore not often found. Yet some markets like Germay demand full certification especially from retailers. If you are an online seller and your exposure to the authorities is minimal you could start by meeting only minimum requirements (CE, FCC for example).
SELF-DECLARATIONS
In some cases it doesn’t make sense to fully certify a product because your quantities are low or the product is so cheap that the certification cost don’t justify certifying it. In that case you may ask the supplier to issue a self-declaration which is in some cases accepted by authorities. Please note that you can issue a self-declaration based on applicable laws but you need to make sure that your supplier fulfils these requirements.
Meaning if the supplier doesn’t have any certificates or testing done for the product you need, you need to make sure trough other ways that the product is safe to import. For example if the specific product I want hasn’t been tested or certified by the supplier BUT he may have a certificate or test report for a critical component used in your very product it would partly satisfy me. On top of that I would also feel much safer if the supplier has history importing to 1st world countries (e.g. Germany, UK, US etc.). But if my supplier has no certificate, test report and only experience selling to countries like Ethiopia, Thailand or Colombia for example I wouldn’t go ahead. Why? Because these countries (no offense) have very low quality requirements. I think you get the point.
You would at least need to be compliant with basic requirements like raw material being certified or tested and according to regulations. However most countries in Europe only allow CE, REACH or RohS self-declarations for several items, mainly low voltage or battery powered products. Check with your supplier what he can offer you.
INSPECTIONS
I can’t stress enough how important inspections are. Irrelevant of your product category, you will want your goods to be inspected to avoid a high rate of returns, defects or not compliant manufactured products. Pre-Shipment inspections can save you a lot of troubles and are well worth the investment. The inspectors will not only test the product but they will also make sure that all is compliant with laws and regulations.
I’ve written on the subject of inspections previously here. If you want to book an inspection online I always recommend working with QIMA.
PRODUCT LIABILITY INSURANCE
I also recommend once you import electronics in larger quantities that you contact your local insurance company and have a product liability insurance on your products. This is to protect yourself from any unforeseeable issues. I recommend that you check out a local provider in your country. Even you may have manufactured a product to the best of your knowledge something can go wrong or someone mishandled the product but you may not proof it. More on product liability insurance HERE.
SUMMARY
So what kind of certifications do you actually need for sure? Thats difficult to say as it depends on the product and ideally you will want the supplier to provide you all of the above. But realistically that never happens. In most cases suppliers do not even have a CPSC or a REACH certification which is actually easily obtainable. If you are starting out I can only recommend to have a supplier who has the minimum requirements.
REACH for example is also easily obtainable these days and if a supplier doesn’t even have a self-declaration or certification for incoming raw materials look elsewhere. Unfortunately each product has different regulations however above general guidelines give you an idea what to look for. Again, the best thing would be to prepare a technical file (or product requirement profile – PRP) that you can send your supplier. It’s also essential that you learn about regulations and compliance in general. I’ve created an online education course for this very reason where you can learn everything about regulations as well as certifications for your specific product (inducing household products) here:
