We are delighted that SUE BLACKER is here tonight to weigh in on the labelling theme of this week. Here Sue describes the different forms of labelling that need to be adhered to and considered at the Natural Fibre Company and at Blacker Yarns.
A rose by any other name?
Oh I wish it were so simple … I hope to shed a little light on the labels we use here at The Natural Fibre Company and Blacker Yarns.
Firstly, The Natural Fibre Company makes yarns using fibre mostly supplied by our customers, so we process each order individually, tracking it through the mill, in order to ensure that what goes in from a customer is what will go back to him or her. The labelling may simply be the name of the customer stuck to the inside of a cone if the yarn is going for knitting or weaving.
If, on the other hand, we have finished the yarn to weighed skeins or balls, we or our customer need to comply with trade descriptions and weights and measures legislation. Therefore the fibre composition (but sadly not the breed) is compulsory for the label, as is the weight: we always put c. 50g for prudence, since particularly woollen spun yarns will vary and all wool, mohair and alpaca also varies according to humidity. The weights are given in metric, but we do provide the yardage in both metric and imperial measures for convenience of those who work in yards and using older pattern designs.
It is not a requirement to include gauge/tension information, needle sizes or yardage/length (again prudently approximate) in the UK but all of these are helpful to knitters and crocheters and are expected by most people, particularly in the USA where many designs are specified by length.
There are also no requirements on the origin of the fibre nor the location of the processing, although of course most of our customers will include this information as part of their branding and marketing story.
Moving on to Blacker Yarns, all of the above requirements apply. In addition, when we are using British sourced wool, we are entitled to use the British Wool Marketing Board basic blue crook mark. This confirms that the yarn contains a minimum of 50% British wool. The higher levels of logo are only available if the wool has been purchased through BWMB’s marketing system, even when a supplier has an exemption certificate (We are working on this). This logo is also available to other wool producers so it is also possible for NFC customers to acquire it and then we can include it on the labelling. We cannot use ‘British Wool’ on our Falklands Blacker Swan and Lyonesse ranges, where instead we add the logo (a tuft of Tussac grass) of the Falkland Islands.
Because we make everything in Cornwall we are entitled to use the ‘Made in Cornwall’ logo, which confirms that the majority of the value added is done in Cornwall, though of course the raw materials may come from elsewhere – this is an important distinction in food labelling and it is good that our certification specifies “made in” and not just “Cornish”. Technically we could apply for a denomination of origin label for wool entirely sourced in Cornwall and then made into yarn in Cornwall, as has been done for Shetland Organic wool.
More and more people ask us not just where things are processed, but also where the original raw materials come from and we have a stock tracking system now almost fully complete so that we can identify the sources of all components of larger Blacker Yarns batches.
On environmental compliance, there are also REACH regulations which require our suppliers (not us as we are not sufficiently large-scale) to identify the sources and components of all chemical substances, such as detergents, oils and dyes, and we need to keep the current Manufacturer’s Safety Data Sheet (MSDS) for everything we use, and we generally also ensure we keep the information on all pesticides specified as having been used by our NFC customers. In addition, when we dispose of waste, such as the effluent from our scouring and dyeing, we have to receive a waste transfer note from our contractor for each load, as also for any other waste, which we try to minimise and of course we are able to sell on rejected fibre and other fibre arising from processing, to a shoddy merchant who can re-process it.
Finally, for Organic processing, there is an added layer of compliance to enable us to use the respected organic label. For this, there is everything already described above, together with a full description of all the administrative and physical processes undertaken to complete an order. All of this must be done in strict accordance with the manual, which in our case is managed by The Soil Association’s certification subsidiary, all itself accredited to the Global Organic Textile Standard (GOTS), currently on Version 4 and preparing an update to Version 5 on which consultation has just finished. Version 4 can be downloaded here.
Organic accreditation specifies in detail what husbandry should be undertaken to produce plant or animal fibre (mainly banning undesirable pesticides, genetic modifications, etc.) and then GOTS says exactly how it should be processed, packaged and labelled. Naturally, carcinogenic, poisonous and dangerous chemicals are prohibited, and artificial fibres are not accepted, although there are some rules about added fibre which mean, for example that, as long as the added fibre is not the same as the organic fibre, a product can be considered 95% organic or 70% organic. Thus organic wool can be mixed with non organic mohair or alpaca but not with non organic wool, as DNA testing would not be able to distinguish between the two types of wool (though it may be possible in the future with different breeds, in theory). However, the rules are changing on this and may be tougher in future, so that the 70% level may go and the current permissions for cellulosic fibre and recycled polymer fibre are being strengthened, though up to 10% specified types of nylon is permitted and even 25% for socks and sportswear at present. There are limit values for chemical residues in final products.
All organic processing must be kept separate from non-organic processing, with detailed cleaning procedures to ensure the risk of mixing organic and non organic fibre is minimised or eliminated. This is relatively easy for most of our machines and the floor, which can be vacuumed, washed or swept clean. For the carding machine, we put through a batch of organic fibre as a purge run. This purge run cannot itself be called organic, but it covers the carding wire with organic fibre ready for the organic customer wool to be carded. When we are processing we have signs at the entrance to show we are doing organic processing and signs at each part of the mill where organic processing is happening and we store organic fibre and yarn in labelled, separate areas, with covers.
Included in the standard are health and safety requirements and staff management standards and at the annual inspection a member of staff is interviewed to check on this. Every part of the process is scrutinised in detail at each inspection and in addition we are subject to random inspections. We have to list the products we make and all the people who supply us with the fibre and the other materials and chemicals used. Each dye has a different chemical composition, so each of them has to be individually approved and it is our responsibility to check this when purchasing.
Organic standards of husbandry vary and generally, European farmed wool is able to be accredited but not necessarily all wool from elsewhere, as ranching has a much lower level of farmer input and is done differently. So there are varying standards of organic. And in the UK, there are bodies other than the Soil Association (for example Demeter/Bio-dynamic or Organic Farmers and Growers) with slightly different standards. So when we receive wool for organic processing from farmers not with the Soil Association, we have to get it checked and approved individually by the Soil Association. Sadly the adverse publicity about the treatment of angora rabbits means that angora will not be permitted in GOTS 5, unless and until husbandry standards and inspection systems have been put in place, which is a shame for the caring producers.
The majority of this compliance is achieved by rigorous documentation, together with a certain amount of testing (such as on our scour effluent for pesticide residues), so the whole of the supply chain must co-operate to do this – if we did 100% testing the already significant costs would be prohibitive.
The Soil Association is currently consulting people about their views on organic standards and you can participate by visiting this link
At NFC and Blacker Yarns, we actually use almost entirely identical processes and chemicals for organic and non organic processing, which both keeps life simple and also ensures that we are applying the highest standards. We of course document every batch anyway, so our annual inspection and participation in setting and applying the standards (I sit on the Soil Association Textile Standards committee) means that we try to keep at the forefront in caring for the environment, our customers, our staff and our community.
There are other standards, such as Oekotex and the European organic Leaf label, the former being a testing system for harmful chemicals in finished goods, with various levels of requirements from babies/toys to outer garments or furnishings, and the latter applying to pre-packaged food but not applicable to textiles. Oh, and by the way, Fair Trade labelling does not apply to products sourced in Europe!
What a fascinating insight into the labelling regulations which apply to wool and textiles. Thank you so much, Sue.
Please weigh in on the labelling discussion – what kind of thing do you like to see on your wool product labels and ball-bands? Use #bethechangeforwool and #wovember2016 when you are talking about this on social media.