Who is responsible for textile labelling is a question that surprisingly often goes unanswered: the brand assumes the factory will sew in the label, the factory waits for labels from the brand, and the shop assumes that if the garment was delivered, everything is in order. EU Regulation No 1007/2011, however, divides the duties very precisely along the chain from manufacturer to retailer. This article explains who owes what, when a retailer becomes a "manufacturer" in the legal sense, and when commercial documents can replace a physical label.
The basic rule
Textile products may only be made available on the EU market if they are labelled or marked in line with the regulation. The label must be durable, easily legible, visible and accessible, and for products aimed at consumers in a given country it must be in that country's official language – Bulgarian for Bulgaria. The composition must also be visible to the buyer before purchase, including online. Who guarantees all this, though, depends on your role in the chain. The same company can play different roles for different products – manufacturer of its own collection and distributor of other brands in the same shop, for instance – so it is worth looking at each product separately.
Printed canvas label LBL 0072 6.5 x 5 cm – with white print, soft premium design, with logo
Woven label 9 cm x 3.5 cm folded - with customer logo
Metal tags E-2298 Gun Metal 2 x 0.4 cm – With sharp edges, for laser brandingWho owes what: roles along the chain
| Role | Core duty | In practice |
|---|---|---|
| Manufacturer (established in the EU) | Ensures the label is provided and its information is accurate | Determines composition, orders labels, is liable for their accuracy |
| Importer | Takes on the manufacturer's duties if the manufacturer is outside the EU | Checks labels and adds local-language labels before sale if needed |
| Distributor / retailer | Ensures it only sells correctly labelled products | Checks a label is present, does not sell unlabelled garments |
| Distributor acting as owner | Is treated as the manufacturer | Sells under its own brand, attaches or alters the label itself |
The last row is the key one. Under Article 15 of the regulation, a distributor that places a product on the market under its own name or trademark, attaches the label itself or changes its content is considered the manufacturer – with every obligation that comes with it.
Five practical scenarios
1. A brand sewing in its own atelier
A clear case: the brand is the manufacturer. It determines composition from the fabric supplier's information, orders the care and composition labels and is responsible for their accuracy.
2. A brand that outsources sewing to a factory
The factory sews, but the garments are sold under the brand's name, so the brand is the manufacturer under the regulation. The factory may sew in the labels, but responsibility for their content lies with the brand. That is why your factory order should state exactly which label goes where and how, and why you should approve composition labels in writing.
3. An importer bringing garments from outside the EU
If the manufacturer is in Turkey, China or another non-EU country, the importer takes on its labelling duties. If garments arrive with labels only in English or Turkish, the importer must provide the information in the local language before sale – for example with an additional sewn-in or securely attached label.
4. A shop selling other brands
The shop is a distributor. It does not have to test composition in a lab, but it must make sure every garment carries the label the regulation requires. If the shop cuts out the original label and attaches its own, it is now treated as the manufacturer.
5. Business-to-business sales
When textile products are supplied to economic operators within the supply chain – semi-finished items passed from one factory to another, for example – the regulation allows labels to be replaced or supplemented by accompanying commercial documents. That relief does not apply to the product that reaches the end consumer: it must carry a label.
Note: the regulation does not apply to customised products made up by self-employed tailors, nor to work contracted out on supplied materials where ownership is not transferred. If an atelier sews in series and sells finished garments, however, it is a manufacturer.
Not just composition: the manufacturer's name and address
Separately from the composition rules, the General Product Safety Regulation (EU) 2023/988 requires the manufacturer's name or trademark and a postal and electronic address to appear on the product, its packaging or an accompanying document – and, for imports, the importer's details too. In practice many brands put this on the back of the care label or on the hang tag.
What to do in your role
- If you are a brand: keep the fabric supplier's specification (composition in percentages), build a template for your composition label and approve each new version in writing.
- If you are an importer: check labels on every delivery and keep a local-language label ready for garments that lack one.
- If you are a retailer: check for a composition label at goods-in and ask the supplier to correct it if it is missing.
- If you are a factory: agree in writing who supplies the labels and what they say.
Frequently asked questions
Who enforces textile labelling in Bulgaria?
Market surveillance of textile products in Bulgaria is carried out by the Commission for Consumer Protection. Where there is a breach, the operator that placed or made the product available is responsible, according to its role in the chain.
If the fabric supplier gave the wrong composition, who is liable?
Towards consumers and the authorities, the garment manufacturer – that is, the brand – is liable. That is why it pays to ask for a written specification and, if in doubt, a lab test.
Can the composition appear only on the website for online sales?
No. It must be visible before purchase in the product description, and also on the label of the garment itself.
Care and composition labels from Bul-tex
Bul-tex manufactures and supplies clothing labels – woven, satin and printed – including care and composition labels with your own text. If you are a brand or importer and need labels in Bulgarian or other languages, get in touch. You will find the full text of the regulation on EUR-Lex, and more practical guides in our labels section.
