TR CU 017/2011: documents for clothing and textiles

TR CU 017/2011 “On safety of light industry products” covers clothing, underwear, textiles, footwear and leather goods. The key concept of the regulation is the layer of the product.

Layers of the product

What the laboratory checks

What must be on the labelling

• Name of the product and type of material
• Raw material composition in percent
• Size according to the size system in force
• Care symbols
• Manufacturer, country of origin, date of manufacture
• Unified mark of circulation on the market

How the marketplaces check the set is explained in the article on Wildberries and Ozon. How to choose a scheme for a series or a batch is explained in the analysis of schemes.

What falls under the regulation and what does not

TR CU 017/2011 covers light industry products: clothing and products made of textiles, leather and fur, hosiery, headwear, bed and table linen, and leather goods. But a number of related goods are covered by other rules, and this is the first thing to check.

The most frequent mistake of sellers is to issue a document under 017 for children’s clothing. The regulation is real, but for children TR CU 007 applies, and the marketplace will ask for it. You can read more in the article on children’s goods.

What is declared and what is certified

For light industry products for adults, the main form is declaration of conformity. Certification is used only in specific cases: for products that touch the skin in a special way and for some categories that the regulation names directly.

• Declaration. Outerwear, dresses, trousers, jumpers, bed linen, headwear and leather goods.
• Certification. Some types of underwear and the products for which the regulation directly provides this form.

The scheme is chosen according to what you supply: a series or a batch. For regular imports of one range, a serial document pays for itself in two or three deliveries. For a one-time purchase, a batch document is enough.

Importing textiles: what to prepare in advance

• The samples must be of the same fabric and the same cut as the batch; a showroom sample is not suitable
• A specification with the composition for each item of the range
• Information on dyes and finishing: colour fastness is tested separately
• A layout of the label in Russian; agree it before printing, not after
• An agreement with the factory that it will notify you when it changes the fabric or the supplier of fittings
• An understanding of who the applicant is: you as the importer, or the factory through an authorized person

Colour fastness to sweat and rubbing is the indicator that is failed most often when goods are ordered from low-cost manufacturers. A dye can hold well in washing and still fail the sweat test, and then the batch is left without documents.

Care symbols

This is a part of the labelling that people treat as a formality, although its absence is the same violation as the absence of the composition. The symbols show the modes for washing, bleaching, drying, ironing and professional cleaning.

What goes wrong here:

• The symbols are copied from a similar product and do not match the real material
• The stated mode damages the product; this is a complaint from the buyer and not only a regulatory one
• The symbols are placed only on the package and not on a sewn-in label, and they are lost after unpacking
• The label fades or wears off long before the end of the service life of the product

Typical mistakes

How to select samples so that the test report refers to your batch is explained in a separate article.

How to assemble a range under one document

It is expensive and not necessary to issue a separate document for each model. The regulation allows similar products to be combined, but people understand the limits of combining in different ways, and this is where gaps in the coverage of the range appear.

• What can be combined. Products of one type, one layer, of the same material and the same manufacturer, for example T-shirts of one model in different colours and sizes.
• What cannot be combined. Different types of products: dresses and trousers, knitwear and outerwear, products of different layers.
• What needs checking. A change of material with the same cut is in fact a different product with different indicators.

A practical method: make a range table with the type of product, the layer, the composition and the manufacturer, and group the rows. Each group will be a separate document, and you will immediately see which items are left uncovered. It is useful to keep such a table after the documents are issued as well: when you add a new model, you will see in a minute whether it falls under an existing document or whether you need a new one.