ETA: our petition has now been debated in the European Parliament, and we regret to share that our recommendations have not been adopted. In the interests of total transparency, here is the full text of the response we received:
1. Summary of petition
The petitioner proposes that a garment should not be described as ‘wool’ or ‘wool-rich’, unless its sheepwool content is higher than 50%. A garment with a sheep wool content between 20% and 50% should only be described with the term ‘wool mix’ or ‘wool blend’. The word “wool” should refer to sheep wool only, and there should be a clarification of trading standards to distinguish between different animal fibres (angora, alpaca, cashmere, etc.). When a garment’s fabric is composed of mixed fibres with a sheep wool content of less than 50%, the word “yarn” should be used in place of wool when describing its composition. Constituent fibres of a fabric should always be listed in proportionate, descending order on a garment label, and only the first two constituent fibres should be used in the product title, marketing, or description.
The petitioner considers that current EU textile regulations fail to adequately clarify the contents of textile products for end consumers. in the petitioner’s view, Regulation 1007/2011 on textile fibre names and related labelling and marking of the fibre composition of textile products (Article 8 and Annex III) is particularly destructive to the cachet value of wool. The fibre name ‘wool’ can be used to describe either fibre obtained from sheep or lamb fleece or a mixture of such fibres and certain fine animal hairs.
The petitioner asks to amend the Regulation in order to make it clearer for consumers of textiles.
Declared admissible on 4 April 2017. Information requested from Commission under Rule 216(6).
3. Commission Reply
The petitioner advocates the revision of the Textile Regulation to make the legislation clearer to end-consumers.
The regulation establishes the rules on textile fibre names as well as the conditions and rules for the compulsory labelling and marking of textile products. Under Article 5 of the Regulation, only the textile fibre names listed in Annex I are to be used for the description of fibre composition on labels and markings of textile products. Annex I sets out two groups of fibre names: Table 1 includes natural fibres, such as wool, silk, cotton and linen, while Table 2 includes man-made fibres such as viscose, nylon, polyester and elastane. In addition, the fibre names have to correspond to their descriptions as set out in the same Annex I.
The fibre name ‘wool’ is used for either a fibre obtained from sheep’s or lambs’ fleeces or for a mixture of the above fibres and the hairs of the following animals: alpaca, llama, camel, kashmir goat, angora goat, angora rabbit, vicuna, yak, guanaco, cashgora goat, beaver and otter.
According to Article 9 of the Textile Regulation, the label or marking shall indicate the name and percentage by weight of all constituent fibres in descending order with regard to multi-fibre textile products. Accordingly, indicating only two most important fibres, as proposed by the petitioner, is contrary to the Regulation.
The use of the terms, such as “wool rich”, “wool mix”, “wool blend” or “yarn”, instead of providing the comprehensive information on the fibre composition of textile products, could only result in consumers’ confusion.
Describing the whole product as ‘wool mix’ or ‘wool blend’ in case of a product with a sheep’s wool content of between 20% and 50%, as proposed by the petitioner, would prevent the consumers from benefiting from the current mandatory information about all constituent fibres. For example, when a product is composed of 70% of polyester and 30% of sheep’s wool, both fibres with their respective percentages have to be displayed on labels or markings, in line with the Regulation.
Similarly, the garment may be described as ‘wool’ only when it is composed of the wool fibre, corresponding to its definition. It is however not allowed to describe the garment as ‘wool’ when it is also composed of other fibre(s), even though one of these fibres is higher than 50%, as the petitioner proposes.
In order to take account of their specific features and qualities, the Textile Regulation made a clear distinction between wool (as provided for in item 1 of Annex I) and other particular fibres, such as alpaca, llama, camel, cashmere, mohair, angora and otter fibres (as provided for in item 2 of Annex I). Consequently, the Regulation prohibits the use of names such as angora wool, alpaca wool and cashmere wool for products containing exclusively sheep’s or lambs’ wool. Since angora, alpaca or cashmere wool is commonly more appreciated by consumers than sheep’s wool, businesses display willingly their presence on labels or markings.
The definition of “wool” and the rules concerning the description of wool products remained unchanged in substance when the Textile Regulation was adopted in 2011 and Directive 2008/121/EC repealed. Moreover, these rules have not been contested by stakeholders, including consumer and industry associations, on the occasion of the preparation of the Commission’s report on the3 application of the Textile Regulation and the discussions about possible revision of the legislation.
The Commission considers that the provisions of the Textile Regulation concerning the description of wool products are sufficiently clear, accurate and non-misleading. In contrast, the proposals presented by the petitioner would reduce the current level of labelling/marking requirements and subsequently they would fail to adequately display the composition of textile products to end consumers.
We are disappointed in this outcome, and – if we’re honest – a bit confused by the response. It is very clear to us that textile labelling and regulations are more complex than we might have ever imagined, and that in submitting our petition here to the European Parliament and to clarify our points exactly for a legal framework, we may have benefited from the expertise and advice of a legal practitioner. It’s obvious that in some places our aims as petitioners were not stated clearly enough for the context of an extremely technical legal discussion; for example I’m not sure where the part about only declaring the first two fibres used in a garment has come from (did I really say that anywhere??? I don’t think so!) and I’m still unclear about where we stand on use of the word “wool” in relation to describing otter fibres.
If anyone wishes to take up our cause, we are happy for you to do so and to learn from our experience of trying to get the below petition discussed in the European Parliament. We have benefited hugely from people who know far more than us about EU regulations, such as John Arbon, whose discussion of these Regulations was a major highlight in our Politics of Wool year, 2016, and discovered the limits of our knowledge about legal frameworks surrounding the labelling, buying and selling of wool.
In spite of the response we have received, we still feel that the word WOOL is often misused to describe or market textiles, and that the cachet value of WOOL is still all too often appropriated for misleading advertisements. The need to be scrupulous when examining the fibre contents of garments remains and, if there is anything positive to take from our correspondence with the European Parliament on the matter, it is that constituent fibres are legally supposed to be included on labels along with percentages. We would strongly urge everyone to continue to examine labels when buying textiles described as WOOL.
For posterity we will keep the petition below here, along with the names of those of you who gamely signed it; however we will also be closing the comments on this post, as we have no plans to further action this petition.
We the undersigned believe that:
1. In the world of contemporary fashion and retail, WOOL, together with the skills, crafts and labour involved in its production, is currently being devalued through widespread misuse of the words and qualities associated with it.
2. Consumers are being misled, and ignorance about WOOL is being promoted, through spurious branding, marketing and product descriptions.
We agree that:
1. A garment should not be described as ‘wool’ or turn up with the search-term ‘wool’ or ‘wool rich’ unless its sheep’s wool content is more than 50%.
2. A garment with a sheep’s wool content of between 20% and 50% should only be described with the term ‘wool mix’ or ‘wool blend’ (ie not ‘wool’ or ‘wool rich’).
3. The word WOOL should refer to sheep’s wool only, and there should be a clarification of trading standards to distinguish between different animal fibres (angora, alpaca, cashmere, and so on) which also possess their own unique properties, qualities and cachet.
4. When a garment’s fabric is composed of mixed fibres with a sheep’s wool content of less than 50%, the word YARN should be used in place of wool when describing its composition.
5. Constituent fibres of a fabric should always be listed in proportionate, descending order on a garment label, and only the first two constituent fibres should be used in the product title, marketing, or description (eg, if a garment is made up of 50% viscose, 30% cotton, 20% polyamide, 5% angora and 5% wool, only viscose and cotton should be used in the product title, marketing, or description.).
To sign the petition, simply leave your name and / or comment in the reply box below.