1. The additional documents
Textiles and apparel add three document categories to the ordinary set.
Fibre content and labelling documentation.
Origin documentation that supports rules of origin, since apparel rules are usually value-based.
Safety and chemical compliance documentation.
2. The ordinary set
Commercial invoice.
Packing list, with the sizes and colours broken out.
Bill of lading.
Certificate of origin.
3. The origin question
Apparel rules of origin under free trade agreements are typically strict.
Under most agreements, the rule is a change in tariff classification at the chapter or heading level, combined with a value test where the fabric is imported.
The practical consequence: apparel made in China from imported fabric may not qualify under an agreement requiring a change from fabric.
The certificate of origin records the criterion, and the analysis behind it has to be done.
4. The fibre content documentation
Most destinations require the fibre composition to be declared on the label and to be accurate.
The exporter’s documentation: the composition specification, and where the destination requires, test reports supporting the declared composition.
Misdeclared fibre content is a common enforcement target.
5. The care labelling
Requirements vary by destination.
The United States requires care labelling under the FTC rules.
The European Union has a harmonised care labelling system.
China has its own standard for domestic products.
The importer adapts the label; the exporter supplies the composition and care information.
6. The chemical compliance
Textiles are subject to restricted substance regimes in many destinations.
European Union
REACH restrictions on azo dyes, and the general restricted substances list.
United States
California Proposition 65 for certain substances.
Flammability standards for apparel, which are enforceable.
General
OEKO-TEX or an equivalent certification is increasingly expected by buyers.
7. The flammability question
The United States enforces flammability standards for apparel, and the importer needs test documentation.
The exporter supplies test reports from an acceptable laboratory.
8. The quota and safeguard question
Some destinations apply quotas or safeguards to textile imports, typically on a country-specific basis.
The documents: the quota certificate or the export licence where the quota regime applies.
The regime changes, and it should be checked per market at the time of the order rather than assumed.
9. Common errors
Fibre content misdeclared
An enforcement target.
Care label not compliant
Refused at retail or at import.
No restricted substance compliance
Increasingly checked.
No test reports
The importer cannot evidence compliance.
Assuming the export certificate supports the origin claim
The analysis has to be done.
10. Closing view
Textiles is a category where the trade documents are straightforward and the product compliance documentation is not.
The exporters who manage it supply their buyers with composition, care and test documentation as a standard package rather than on request.
*This article is based on destination textile labelling, chemical and flammability requirements and on free trade agreement rules of origin for apparel. Exporters should confirm requirements with the destination authority and their buyer.*