FtLblD - Directive 94/11/EC

What FtLblD is and why it matters

The Footwear Labelling Directive (FtLblD) — formally Directive 94/11/EC on the labelling of the materials used in the main components of footwear for sale to the consumer — is the EU rule that tells the buyer what a shoe is actually made of. It harmonises how footwear sold to consumers in the Union must declare the materials of its three main parts, so that the same information is presented consistently from one Member State to the next. If you make, import or sell footwear in the EU, this Directive almost certainly governs the label on your product.

FtLblD matters because it removes guesswork at the point of sale and prevents the patchwork of conflicting national labelling rules that existed before it. For a brand owner, it is a low-complexity but high-visibility obligation: the requirement is narrow, but it appears on every pair you sell, and a missing or wrong material label is an easy thing for a market surveillance authority or a competitor to spot. Getting it right is cheap; getting it wrong is conspicuous.

📄 Official text: Directive 94/11/EC on the labelling of footwear materials — on EUR-Lex →

Who FtLblD applies to

FtLblD covers footwear intended for sale to the consumer, and the duties run across the supply chain:

Manufacturers established in the EU — carry primary responsibility for supplying the correct label and for the accuracy of the information it conveys.
EU-established sellers (importers and distributors) — where the manufacturer is not established in the Union, the seller who first places the footwear on the EU market is responsible for the label and its accuracy. Retailers further down the chain must ensure the labelled footwear they sell actually carries the required information.
The consumer — is the protected party. The whole point of the Directive is to give the person buying the shoe a clear, comparable statement of what its main components are made of.

The Directive applies to footwear in general — articles designed to protect or cover the foot, with a fitted sole. Certain categories fall outside its scope, such as second-hand footwear, protective footwear covered by its own legislation (PPE), toy footwear, and footwear that is itself governed by dedicated rules. For everyday consumer footwear, however, the labelling duty applies in full.

Key dates and timeline

1994 — Directive 94/11/EC was adopted, replacing earlier divergent national approaches with a single harmonised labelling scheme for footwear materials across the internal market.
As a directive, FtLblD is not directly applicable; each Member State transposes it into national law. The labelling obligations have applied across the Union since that transposition, and the prescribed pictograms and material definitions have remained the common reference point ever since.
Because the rules are long-settled, the practical timeline for a brand is simply: any consumer footwear placed on the EU market today must already carry a compliant material label.

Core requirements

Labelling the three main components

The heart of FtLblD is that the label must convey the material of the three main components of the footwear:

the upper — the outer surface of the part attached to the sole;
the lining and sock — the inner lining of the upper and the insole, making up the inside of the article;
the outer sole — the underside of the footwear that is subject to abrasive wear in contact with the ground.

For each of these three parts, the label must indicate which material it is predominantly made of, so the consumer can read the make-up of a shoe at a glance.

The four material categories

For each component, the material is declared using one of four prescribed categories: leather, coated leather, textile, and other. Each category has its own pictogram and an agreed definition in the Directive. The material to be indicated for a given component is the one that makes up at least 80% of the surface of the upper, of the lining and sock, and of the volume of the outer sole. Where no single material accounts for at least 80%, information must be given on the two main materials that make up the component. This 80% threshold is the rule that decides what gets named on the label.

Pictograms or written indications

The information may be conveyed in two permitted ways: by the standardised pictograms set out in the Directive, or by written indications using the material terms. Pictograms exist both for the three components and for the four material categories, allowing a purely graphic label that needs no translation. Where written words are used instead, they must be in the language(s) of the Member State where the footwear is sold to the consumer. Member States may require that wording, but they cannot impose a labelling system other than the one the Directive lays down — the harmonised scheme is the only one allowed.

Where and how the label is attached

The label must appear on at least one article of footwear in each pair — it is enough to label one shoe of the pair, not both. It must be legible, securely attached and accessible, and the manufacturer or EU-established seller is responsible for the label being present and accurate. The label can be printed, stuck on, embossed or attached, provided it stays in place and remains readable. It must not be misleading, and it may be accompanied by additional information so long as that extra text does not contradict or obscure the required material declaration.

Obligations by role

Manufacturers (EU-established) — supply the correct pictogram or written label for the upper, lining and sock, and outer sole; apply the 80% rule correctly; ensure the label is durable, legible and accurate.
Importers / first EU sellers — take on the manufacturer’s labelling responsibility where the maker is outside the EU; verify that incoming footwear is correctly labelled before placing it on the market.
Distributors and retailers — sell only footwear that carries the required label, and do not remove, obscure or alter it.

Enforcement

FtLblD is enforced at national level by the market surveillance authorities of each Member State. In Denmark, the Danish Safety Technology Authority (Sikkerhedsstyrelsen) oversees product compliance of this kind. Authorities can check that footwear on sale carries the correct material label, require correction of non-compliant or misleading labels, and act against products that do not meet the harmonised scheme.

The consequences of non-compliance are set nationally and can include orders to stop sales until labelling is corrected, removal of stock, and penalties. Because the label is on every pair and easy to inspect, footwear labelling tends to be picked up quickly — both by authorities during retail checks and by competitors. The qualitative reality for a brand is that a labelling defect is visible across an entire product line at once.

Getting compliant

Identify the predominant material of the upper, the lining and sock, and the outer sole for each footwear model.
Apply the 80% rule; where no material reaches 80% of a component, declare the two main materials.
Assign each material to the correct category: leather, coated leather, textile or other.
Choose your format: the prescribed pictograms, or written indications in the language(s) of the markets where you sell.
Place the label on at least one shoe of each pair, ensuring it is legible, durable and accessible.
Confirm the label is accurate and not misleading, and that any additional text does not obscure the required information.
Keep the responsibility chain clear: if you import, make sure the labelling duty is met before the footwear reaches the EU market.

How Conphora helps

Conphora monitors FtLblD and maps your footwear against its requirements, flagging gaps in material declaration, pictogram use and the responsibility chain before they become enforcement problems. The platform helps you generate and keep the right labelling documentation, and alerts you when obligations change so your compliance stays current.

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Sources and further reading

This guide is for general information and is not legal advice.

Last updated: 12 June 2026