---
title: "FtLblD — Footwear Labelling Directive"
description: "The Footwear Labelling Directive requires footwear sold to EU consumers to carry a label showing the material of the upper, lining and sock and outer sole, with the manufacturer, its EU agent or the first importer responsible and retailers selling only labelled footwear. It has applied since 23 March 1996; since 16 July 2021 market surveillance follows Regulation (EU) 2019/1020."
type: "guide"
url: "https://www.conphora.com/regulations/ftlbld/"
markdown: "https://www.conphora.com/regulations/ftlbld.md"
locale: "en"
language: "en"
published: "1994-05-09"
updated: "2026-09-12"
author: "Conphora compliance team"
publisher: "Conphora"
reference: "Directive 94/11/EC"
celex: "31994L0011"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31994L0011"
tags: ["FtLblD", "Labelling & Packaging"]
license: "Free to quote with attribution and a link to the page"
---

# FtLblD — Footwear Labelling Directive

The Footwear Labelling Directive requires footwear sold to EU consumers to carry a label showing the material of the upper, lining and sock and outer sole, with the manufacturer, its EU agent or the first importer responsible and retailers selling only labelled footwear. It has applied since 23 March 1996; since 16 July 2021 market surveillance follows Regulation (EU) 2019/1020.

## Key facts

- **Official title:** Directive 94/11/EC of the European Parliament and of the Council of 23 March 1994 on the approximation of the laws, regulations and administrative provisions of the Member States relating to labelling of the materials used in the main components of footwear for sale to the consumer
- **Reference:** Directive 94/11/EC
- **CELEX:** 31994L0011
- **Act type:** Directive
- **In force:** 1994-05-09
- **Applies from:** 1996-03-23
- **Enforced by:** National market surveillance authorities enforce the national laws transposing the directive, which Regulation (EU) 2019/1020 lists in Annex I (point 8) as Union harmonisation legislation; in Denmark the control authority under § 9 of the product and market surveillance act (lovbekendtgørelse nr. 22 af 8. januar 2026, which lists the directive in § 2, stk. 1, nr. 21) is Erhvervsstyrelsen, whose department Markedsovervågning is the former Sikkerhedsstyrelsen, part of Erhvervsstyrelsen since January 2026, applying executive order nr. 1046 af 28. maj 2021 on footwear and textile labelling. The toolkit is inspections of shops and web shops, orders to correct the labelling under § 14 of the act, and fines under § 18 of the executive order and § 37(1) of the act, which can rise to imprisonment of up to two years in aggravating circumstances for the offences that § 37(2) lists, with companies liable under § 19 of the order and § 37(5) of the act; the directive itself leaves the action against non-conforming footwear to national legislation and, being listed in Annex II of Regulation (EU) 2019/1020, relies on Article 41 of that regulation for the requirement that penalties be effective, proportionate and dissuasive.
- **Category:** Labelling & Packaging

## Who it applies to

**Covered by the act:** The labelling of the materials used in the main components of footwear for sale to the consumer, footwear meaning all articles with applied soles designed to protect or cover the foot, including parts marketed separately as referred to in Annex I; The three parts of the footwear defined in Annex I: the upper, the lining and sock, and the outer sole; The four material groups of Annex I: leather, coated leather, textile, and all other materials, each with a pictogram and written indications in the official languages; The examples in Annex II: shoes for indoor or outdoor wear, ankle-, half-, knee- and thigh boots, sandals, espadrilles, tennis, running and other sports shoes, special sports footwear with spikes or studs and skating, ski, wrestling, boxing and cycling boots, dancing slippers, moulded rubber or plastic footwear, overshoes, disposable footwear with applied soles and orthopaedic footwear, and as a general rule products of Chapter 64 of the Combined Nomenclature; The operators who answer for the label: the manufacturer or its authorised agent established in the Community, otherwise the person responsible for first placing the footwear on the Community market, and the retailer

**Derived and downstream products:** Four groups are excluded: second-hand, worn footwear; protective footwear covered by Directive 89/686/EEC (repealed by Regulation (EU) 2016/425 with effect from 21 April 2018, references to be read as references to that regulation); footwear covered by Directive 76/769/EEC (repealed by the REACH Regulation (EC) No 1907/2006 with effect from 1 June 2009, references to the repealed directive to be read as references to that regulation); and toy footwear (Art. 1(1); Regulation (EU) 2016/425, Art. 46; Regulation (EC) No 1907/2006, Art. 139; executive order nr. 1046/2021, § 2); The material to label is the one making up at least 80 % of the surface area of the upper and of the lining and sock, and at least 80 % of the volume of the outer sole; where no material reaches 80 %, the two main materials are given (Art. 4(1)); Accessories and reinforcements such as ankle patches, edging, ornamentation, buckles, tabs and eyelet stays are left out when classifying the upper (Art. 1(2)(iii)); Textile means the products covered by Directive 71/307/EEC on textile names and its amendments; the Danish order defines a textile product by reference to Regulation (EU) No 1007/2011, which now governs textile fibre names (Annex I, point 2(b); executive order nr. 1046/2021, § 3, nr. 5); Member States may not prohibit or impede the placing on the market of footwear that complies with the directive by applying unharmonised national labelling provisions, and additional textual information may accompany the required label (Art. 3 and Art. 5); Directive 94/11/EC is EEA-relevant: it is listed as point 3e of Chapter XIX of Annex II to the EEA Agreement, so the same labelling rules apply to footwear placed on the market in Norway, Iceland and Liechtenstein under those States' implementing law (EEA Joint Committee decision, CELEX 21997D0710(15), Art. 1)

**Roles under the act:**

- **Manufacturer (including brand owners)** — The manufacturer, or its authorised agent established in the Community, chooses between pictograms and written indications and is responsible for supplying the label and for the accuracy of the information it contains; the directive does not define the term further. In Denmark an importer or retailer that places footwear on the market under its own name or trade mark is treated as the manufacturer.
- **Authorised agent (authorised representative) established in the Union** — The manufacturer's authorised agent established in the Community may make the choice between pictograms and written indications and carries, with the manufacturer, the responsibility for supplying the label and for its accuracy; under the Danish order a manufacturer may appoint an authorised representative by written mandate, the mandate may cover the manufacturer's labelling duties under §§ 4 to 6 of the order, and the representative must carry out the tasks the mandate sets out.
- **Importer (the person first placing the footwear on the Union market)** — Where neither the manufacturer nor its authorised agent is established in the Community, the obligation to supply the label and to ensure the accuracy of its information falls on the person responsible for first placing the footwear on the Community market.
- **Retailer (distributor selling to consumers, in shops or online)** — The retailer remains responsible for ensuring that the footwear it sells bears the appropriate labelling prescribed by the directive; the Danish order adds that the label and the meaning of any pictograms must be visible and accessible to the consumer before the purchase, online as in physical shops.

## Key dates

- 1994-03-23: Directive 94/11/EC adopted by the European Parliament and the Council
- 1994-04-19: Published in the Official Journal, OJ L 100, p. 37
- 1994-05-09: Entry into force according to the EUR-Lex document information; the directive has no entry-into-force article of its own
- 1995-09-23: Deadline for Member States to adopt and publish the transposing laws, regulations and administrative provisions and to inform the Commission
- 1996-03-23: Member States apply the labelling measures (date as corrected by the corrigendum of 24 February 1996)
- 1997-09-23: End of the derogation for stock invoiced or delivered to the retailer before 23 March 1996
- 2004-05-01: 2003 Act of Accession adds the Czech, Estonian, Latvian, Lithuanian, Hungarian, Maltese, Polish, Slovenian and Slovak written indications to Annex I
- 2007-01-01: Council Directive 2006/96/EC applies: Bulgarian and Romanian written indications added to Annex I
- 2013-07-01: Council Directive 2013/15/EU applies: Croatian written indications added to Annex I
- 2021-07-01: Denmark: executive order nr. 1046 af 28. maj 2021 on footwear and textile labelling in force, replacing order nr. 759 af 15. september 1995
- 2021-07-16: Regulation (EU) 2019/1020 applies; the directive is listed in its Annex I (point 8) and Annex II (point 7)

## What you must do

### Manufacturer (including brand owners)

- Identify the three parts to be labelled using the Annex I definitions: the upper is the outer face of the structural element attached to the outer sole; the lining and sock are the lining of the upper and the insole, constituting the inside of the footwear; the outer sole is the bottom part subjected to abrasive wear and attached to the upper.
- Classify the material of each part as leather, coated leather, textile or other materials using the Annex I definitions: leather is hide or skin with its original fibrous structure more or less intact, tanned to be rot-proof, with any surface coating or glued-on finish not thicker than 0,15 mm; coated leather has a coating thicker than 0,15 mm but not exceeding one third of the total thickness; hide disintegrated into fibres, pieces or powder and re-formed into sheets is not leather.
- Apply the 80 % rule: label the material that makes up at least 80 % of the surface area of the upper and of the lining and sock, and at least 80 % of the volume of the outer sole; where no material reaches 80 %, give the two main materials. Leave accessories and reinforcements such as ankle patches, edging, ornamentation, buckles, tabs and eyelet stays out of the classification of the upper.
- Choose either the Annex I pictograms or written indications in at least the language or languages which the Member State of consumption may determine in accordance with the Treaty; the Danish indications in Annex I are Overdel, Foring og bindsål and Ydersål for the parts and Læder, Overtrukket læder, Tekstil-materialer and Andre materialer for the material groups, and the Danish order accepts pictograms or text in Danish.
- Affix the information to at least one article of footwear in each pair by printing, sticking, embossing or an attached label, so that it is visible, securely attached and accessible, with pictograms large enough to make the information easy to understand, and never in a way that could mislead the consumer.
- Supply the label and answer for the accuracy of the information it contains; this responsibility sits with you or with your authorised agent established in the Community and passes to the first importer only if neither of you is established there.
- Add further textual information only alongside the required information, and use the term full grain leather only for leather bearing the original grain surface as exposed by removal of the epidermis, with none of the surface removed by buffing, snuffing or splitting.
- In Denmark, label the footwear in accordance with §§ 4 to 6 of executive order nr. 1046 af 28. maj 2021 before placing it on the market; an importer or retailer that markets footwear under its own name or trade mark is treated as the manufacturer and takes over these duties.
- In Denmark, label the footwear in accordance with §§ 4 to 6 of executive order nr. 1046 af 28. maj 2021 before placing it on the market.

### Authorised agent (authorised representative) established in the Union

- Where the manufacturer has appointed you as its authorised agent established in the Community, you may make the choice between the Annex I pictograms and written indications in at least the language or languages which the Member State of consumption may determine in accordance with the Treaty.
- You share the manufacturer's responsibility for supplying the label and for the accuracy of the information it contains; only where neither of you is established in the Community does that duty pass to the person first placing the footwear on the Community market.
- In Denmark, act under a written mandate from the manufacturer, which may cover the labelling duties of §§ 4 to 6 of the executive order, and carry out the tasks the mandate sets out.
- Failing to carry out the tasks set out in the mandate is a finable offence in Denmark; the separate offence of not giving the authorised representative a written mandate is committed by the manufacturer, not by you.

### Importer (the person first placing the footwear on the Union market)

- Where neither the manufacturer nor its authorised agent is established in the Community, supply the label and answer for the accuracy of its information as the person responsible for first placing the footwear on the Community market.
- Check before placing the footwear on the market that each pair carries the three-part material label in the form (pictograms or words) and language required in the Member State of consumption, on at least one shoe, visible, securely attached and accessible, with pictograms large enough to understand.
- In Denmark, ensure that the footwear is labelled in accordance with §§ 4 to 6 of the executive order before you place it on the market, and do not place it on the market if you know or ought to know that it is not, until it has been correctly labelled.
- If you learn or ought to know that footwear you have already placed on the market is not correctly labelled, immediately take the measures needed to have it labelled in accordance with §§ 4 to 6 of the order.
- If you place footwear on the market under your own name or trade mark, you are treated as the manufacturer and take over the manufacturer's labelling duties.

### Retailer (distributor selling to consumers, in shops or online)

- Sell only footwear that bears the labelling prescribed by the directive; the retailer remains responsible for this even though the manufacturer, its authorised agent or the first importer supplies the label.
- In Denmark, ensure that footwear is labelled in accordance with §§ 4 to 6 of the executive order before you make it available on the market, and if you know or ought to know that it is not, do not make it available until it has been correctly labelled.
- Make the label visible and accessible to the consumer before the purchase, in the shop and in the web shop.
- Inform the consumer in writing of the meaning of any pictograms before the purchase, for example with a poster on the wall, information leaflets in the shop or on the sales page where the footwear is added to the basket; the Danish penalty provision is worded for a failure to inform the consumer in writing, so keep the explanation in written form.
- If you sell footwear under your own name or trade mark, you are treated as the manufacturer and take over its labelling duties.
- Expect inspections of shops and web shops: Erhvervsstyrelsen's department Markedsovervågning checks footwear labelling in both channels and can order you to correct it, and it is a finable offence to make unlabelled footwear available on the market, to fail to check the labelling before you do so, or to fail to make the label visible or to explain the pictograms before the purchase.

## Requirements

Each duty above as an identified requirement (21); ids are permanent and shared with the compliance engine.

### evidence

- `ftlbld-mfr-add-further-textual` (Manufacturer (including brand owners), product, before-market) — Add further textual information only alongside the required information, and use the term full grain leather only for leather bearing the original grain surface as exposed by removal of the epidermis, with none of the surface removed by buffing, snuffing or splitting. [Art. 5 and Annex I, point 2(a)(i)]

### data

- `ftlbld-mfr-identify-parts-labelled` (Manufacturer (including brand owners), product, before-market) — Identify the three parts to be labelled using the Annex I definitions: the upper is the outer face of the structural element attached to the outer sole; the lining and sock are the lining of the upper and the insole, constituting the inside of the footwear; the outer sole is the bottom part subjected to abrasive wear and attached to the upper. [Art. 1(2)(i) and Annex I, point 1]
- `ftlbld-mfr-apply-rule-label` (Manufacturer (including brand owners), product, before-market) — Apply the 80 % rule: label the material that makes up at least 80 % of the surface area of the upper and of the lining and sock, and at least 80 % of the volume of the outer sole; where no material reaches 80 %, give the two main materials. Leave accessories and reinforcements such as ankle patches, edging, ornamentation, buckles, tabs and eyelet stays out of the classification of the upper. [Art. 1(2)(iii), Art. 1(2)(iv) and Art. 4(1)]
- `ftlbld-dist-make-label-visible` (Retailer (distributor selling to consumers, in shops or online), product, at-listing) — Make the label visible and accessible to the consumer before the purchase, in the shop and in the web shop. [§ 13, stk. 1; https://www.sik.dk/erhverv/produkter/tekstilprodukter-og-fodtoej/kontrol-maerkning-tekstilprodukter-og-fodtoej]

### mark

- `ftlbld-mfr-affix-information-least` (Manufacturer (including brand owners), product, before-market) — Affix the information to at least one article of footwear in each pair by printing, sticking, embossing or an attached label, so that it is visible, securely attached and accessible, with pictograms large enough to make the information easy to understand, and never in a way that could mislead the consumer. [Art. 4(3) and Art. 4(4)]
- `ftlbld-mfr-supply-label-answer` (Manufacturer (including brand owners), product, before-market) — Supply the label and answer for the accuracy of the information it contains; this responsibility sits with you or with your authorised agent established in the Community and passes to the first importer only if neither of you is established there. [Art. 4(5)]
- `ftlbld-mfr-label-before-placing-denmark` (Manufacturer (including brand owners), product, before-market) — In Denmark, label the footwear in accordance with §§ 4 to 6 of executive order nr. 1046 af 28. maj 2021 before placing it on the market. [§ 7]
- `ftlbld-imp-supply-label-answer` (Importer (the person first placing the footwear on the Union market), product, before-market) — Where neither the manufacturer nor its authorised agent is established in the Community, supply the label and answer for the accuracy of its information as the person responsible for first placing the footwear on the Community market. [Art. 4(5)]

### decision

- `ftlbld-mfr-classify-material-part` (Manufacturer (including brand owners), product, before-market) — Classify the material of each part as leather, coated leather, textile or other materials using the Annex I definitions: leather is hide or skin with its original fibrous structure more or less intact, tanned to be rot-proof, with any surface coating or glued-on finish not thicker than 0,15 mm; coated leather has a coating thicker than 0,15 mm but not exceeding one third of the total thickness; hide disintegrated into fibres, pieces or powder and re-formed into sheets is not leather. [Annex I, point 2]
- `ftlbld-mfr-choose-annex-pictograms` (Manufacturer (including brand owners), product-market, before-market) — Choose either the Annex I pictograms or written indications in at least the language or languages which the Member State of consumption may determine in accordance with the Treaty; the Danish indications in Annex I are Overdel, Foring og bindsål and Ydersål for the parts and Læder, Overtrukket læder, Tekstil-materialer and Andre materialer for the material groups, and the Danish order accepts pictograms or text in Danish. [Art. 4(2) and Annex I; https://www.retsinformation.dk/eli/lta/2021/1046 · § 4, stk. 2]
- `ftlbld-oth-make-choice-between` (Authorised agent (authorised representative) established in the Union, product-market, before-market) — Where the manufacturer has appointed you as its authorised agent established in the Community, you may make the choice between the Annex I pictograms and written indications in at least the language or languages which the Member State of consumption may determine in accordance with the Treaty. [Art. 4(2)]

### procedure

- `ftlbld-imp-immediately-take-measures` (Importer (the person first placing the footwear on the Union market), product, on-event) — If you learn or ought to know that footwear you have already placed on the market is not correctly labelled, immediately take the measures needed to have it labelled in accordance with §§ 4 to 6 of the order. [§ 11, stk. 2]

### verification

- `ftlbld-imp-check-placing-footwear` (Importer (the person first placing the footwear on the Union market), product-market, before-market) — Check before placing the footwear on the market that each pair carries the three-part material label in the form (pictograms or words) and language required in the Member State of consumption, on at least one shoe, visible, securely attached and accessible, with pictograms large enough to understand. [Art. 4(2), Art. 4(3) and Art. 4(4)]
- `ftlbld-imp-ensure-footwear-labelled` (Importer (the person first placing the footwear on the Union market), product, before-market) — In Denmark, ensure that the footwear is labelled in accordance with §§ 4 to 6 of the executive order before you place it on the market, and do not place it on the market if you know or ought to know that it is not, until it has been correctly labelled. [§ 10 and § 11, stk. 1]
- `ftlbld-dist-sell-footwear-bears` (Retailer (distributor selling to consumers, in shops or online), product, before-market) — Sell only footwear that bears the labelling prescribed by the directive; the retailer remains responsible for this even though the manufacturer, its authorised agent or the first importer supplies the label. [Art. 4(5)]
- `ftlbld-dist-ensure-footwear-labelled` (Retailer (distributor selling to consumers, in shops or online), product, before-market) — In Denmark, ensure that footwear is labelled in accordance with §§ 4 to 6 of the executive order before you make it available on the market, and if you know or ought to know that it is not, do not make it available until it has been correctly labelled. [§ 12 and § 14]

### standing

- `ftlbld-dist-inform-consumer-writing` (Retailer (distributor selling to consumers, in shops or online), company, ongoing) — Inform the consumer in writing of the meaning of any pictograms before the purchase, for example with a poster on the wall, information leaflets in the shop or on the sales page where the footwear is added to the basket; the Danish penalty provision is worded for a failure to inform the consumer in writing, so keep the explanation in written form. [§ 13, stk. 2, og § 18, nr. 9; https://www.sik.dk/erhverv/produkter/tekstilprodukter-og-fodtoej/kontrol-maerkning-tekstilprodukter-og-fodtoej]

## Penalties

The directive itself contains no penalty article: it requires Member States to ensure that all footwear placed on the market meets its labelling requirements and, where footwear not in conformity with those requirements is placed on the market, to take appropriate action as specified in national legislation. Since 16 July 2021 the directive is listed in Annex II of Regulation (EU) 2019/1020 as Union harmonisation legislation without provisions on penalties, so Member States must lay down effective, proportionate and dissuasive penalties for infringements of it under Article 41 of that regulation. In Denmark, executive order nr. 1046 af 28. maj 2021 lets the control authority issue orders under § 14 of the product and market surveillance act where footwear is not labelled in accordance with §§ 4 to 6, and § 18 of the order punishes with a fine a manufacturer that fails to label the footwear, an authorised representative without a written mandate or that fails its tasks, an importer or retailer that places or makes available unlabelled footwear or fails to act on it, and a retailer that does not make the label visible or does not explain the pictograms before the purchase; with companies liable under § 19 of the order. The act adds, in § 37(1), a fine for the economic operator that breaches the general duty of § 5 to place only compliant products on the market and for the operator that fails to comply with a decision of the control authority, including an order under § 14(1); because footwear labelling is one of the product areas listed in § 2(1)(21) of the act, the penalty for those offences can rise to imprisonment of up to two years in aggravating circumstances (danger to safety or health, an accident causing serious injury or death, a repeat infringement, or a systematic infringement for economic gain, § 37(2)) and companies can be held liable under § 37(5).

## Checklist

1. Confirm the article is footwear with an applied sole for sale to the consumer and that none of the four Article 1(1) exclusions applies: second-hand worn footwear, protective footwear under the PPE rules, footwear covered by the REACH restrictions, toy footwear.
2. Decide your role for each model: manufacturer or authorised agent in the Union, first importer, or retailer, remembering that own-brand importers and retailers count as the manufacturer in Denmark (executive order § 15).
3. Measure the composition of the upper and of the lining and sock by surface area and of the outer sole by volume, leaving accessories and reinforcements on the upper out of the count (Article 1(2) and Article 4(1)).
4. Assign each part to leather, coated leather, textile or other materials using the Annex I definitions, checking any coating against the 0,15 mm and one-third-of-thickness limits.
5. Apply the 80 % rule and, where no material reaches it, name the two main materials (Article 4(1)).
6. Choose pictograms or written indications in the language of each country of sale; for Denmark, the pictograms or Danish words (Article 4(2), executive order § 4).
7. Put the label on at least one shoe of each pair, printed, stuck, embossed or attached, visible, securely attached and accessible, with pictograms large enough to read (Article 4(3) and (4)).
8. For stores and web shops, show the label and explain the pictograms in writing before the purchase, since the Danish penalty provision is worded for a failure to inform the consumer in writing, and record who supplies each label so the responsibility for its accuracy is clear (Article 4(5), executive order § 13 and § 18, nr. 9).

## Questions

### When did the Footwear Labelling Directive start to apply?

Directive 94/11/EC was adopted on 23 March 1994, published in OJ L 100 on 19 April 1994 and entered into force on 9 May 1994. Member States had to adopt their transposing measures by 23 September 1995 and apply them from 23 March 1996, with stock invoiced or delivered to retailers before that date exempt until 23 September 1997. The substance of the rules has not changed since; the three amendments only added language versions of the written indications when new Member States joined in 2004, 2007 and 2013.

### Which footwear must carry the material label?

All articles with applied soles designed to protect or cover the foot that are for sale to the consumer, including parts marketed separately. Annex II lists examples: flat or high-heeled shoes for indoor or outdoor wear, ankle-, half-, knee- and thigh boots, sandals, espadrilles, tennis, running and other sports shoes, special sports footwear with spikes or studs, skating, ski, wrestling, boxing and cycling boots, dancing slippers, moulded rubber or plastic footwear, overshoes, disposable footwear with applied soles and orthopaedic footwear, and as a general rule products of Chapter 64 of the Combined Nomenclature. Excluded are second-hand worn footwear, protective footwear under the PPE rules, footwear covered by Directive 76/769/EEC (now the REACH restrictions) and toy footwear.

### What exactly must the label show?

The material of each of three parts, the upper, the lining and sock, and the outer sole, given as leather, coated leather, textile or other materials by pictogram or by words. The material named is the one making up at least 80 % of the surface area of the upper and of the lining and sock, and at least 80 % of the volume of the outer sole; if no material reaches 80 %, the two main materials are given. Accessories and reinforcements such as buckles, edging, ornamentation, tabs and eyelet stays do not count when classifying the upper.

### Can I use the pictograms instead of Danish words?

Yes. The manufacturer or its authorised agent in the Union chooses between the Annex I pictograms and written indications in at least the language or languages determined by the Member State where the footwear is sold, and Member States must see that consumers are adequately informed of the meaning of the pictograms. The Danish order accepts either the pictograms or text in Danish, and requires the retailer to inform the consumer in writing of the pictograms' meaning before the purchase; the Danish penalty provision is worded for a failure to inform the consumer in writing, so keep the explanation in written form.

### Do both shoes of a pair need a label?

No. Labelling means affixing the required information to at least one article of footwear in each pair, by printing, sticking, embossing or an attached label. The label must be visible, securely attached and accessible, the pictograms must be large enough to understand easily, and the label must not mislead the consumer.

### Who is responsible for the label: the brand, the importer or the shop?

The manufacturer or its authorised agent established in the Union is responsible for supplying the label and for the accuracy of its information. If neither is established in the Union, the duty falls on the person responsible for first placing the footwear on the Union market, in practice the importer. The retailer remains responsible for ensuring that the footwear it sells bears the prescribed labelling. In Denmark the order spells this out for manufacturers (§ 7), authorised representatives (§§ 8 and 9), importers (§§ 10 and 11) and retailers (§§ 12 to 14), and treats own-brand importers and retailers as manufacturers (§ 15).

### What happens if footwear in Denmark is sold without a correct label?

Erhvervsstyrelsen's department Markedsovervågning, the former Sikkerhedsstyrelsen and part of Erhvervsstyrelsen since January 2026, inspects footwear labelling in shops and online. It can order the economic operator to correct the labelling under § 14 of the product and market surveillance act, and § 18 of the executive order provides fines for failing to label footwear, for placing or making available unlabelled footwear, for not making the label visible or not explaining the pictograms before the purchase, for a manufacturer that does not give its authorised representative a written mandate and for an authorised representative that neglects the tasks the mandate sets out; companies can be fined under § 19.

## What changed

- 2026-09-12 (guidance): **Guide rebuilt on the SPEC-62 model from the consolidated text** — The page now carries the structured model and the body was rewritten from the consolidated text of 1 July 2013. Corrections to the previous text: the Danish control authority is Erhvervsstyrelsen (department Markedsovervågning, the former Sikkerhedsstyrelsen) under the product and market surveillance act and executive order nr. 1046 af 28. maj 2021, not Sikkerhedsstyrelsen as a separate authority; the key dates (entry into force 9 May 1994, application 23 March 1996, stock derogation until 23 September 1997) and the three enlargement amendments are now stated exactly; the 80 % rule is stated per part as the directive words it; and the retailer's own duties under the Danish order are added.
- 2021-07-16 (applies): **Regulation (EU) 2019/1020 applies to footwear labelling** — The Market Surveillance Regulation applies from this date and lists Directive 94/11/EC in Annex I (point 8) as Union harmonisation legislation and in Annex II (point 7) as legislation without provisions on penalties, so that Member States must lay down effective, proportionate and dissuasive penalties for infringements under Article 41; market surveillance authorities use the regulation's powers when they check footwear labels.
- 2021-07-01 (applies): **Denmark: new executive order on footwear and textile labelling** — Executive order nr. 1046 af 28. maj 2021 on labelling of footwear and labelling and marking of textile products entered into force, issued under § 8 and § 37(6) and (7) of act no. 799 of 9 June 2020 on products and market surveillance as amended by act no. 782 of 4 May 2021, the provisions that are now § 8 and § 37(3) and (4) of lovbekendtgørelse nr. 22 af 8. januar 2026. It repeals order nr. 759 af 15. september 1995, restates the directive's labelling rules with Danish as the language for written indications, allocates duties to manufacturers, authorised representatives, importers and retailers, and makes breaches finable.
- 2013-07-01 (amendment): **Council Directive 2013/15/EU adds the Croatian indications** — By reason of the accession of Croatia, Part B of the Annex to the directive of 13 May 2013 (OJ L 158, 10 June 2013) adds the Croatian written indications for the upper, the lining and sock and the outer sole and for the four material groups to Annex I; Member States apply the measures from the date of Croatia's accession.
- 2007-01-01 (amendment): **Council Directive 2006/96/EC adds the Bulgarian and Romanian indications** — By reason of the accession of Bulgaria and Romania, Part D, point 1 of the Annex to the directive of 20 November 2006 (OJ L 363, 20 December 2006) adds the Bulgarian and Romanian written indications to points 1(a) to (c) and 2(a) to (c) of Annex I; the directive entered into force with the Treaty of Accession.
- 2004-05-01 (amendment): **2003 Act of Accession adds nine language versions** — The Act concerning the conditions of accession of the Czech Republic, Estonia, Cyprus, Latvia, Lithuania, Hungary, Malta, Poland, Slovenia and Slovakia (OJ L 236, 23 September 2003) added the Czech, Estonian, Latvian, Lithuanian, Hungarian, Maltese, Polish, Slovenian and Slovak written indications to Annex I, shown as marker A1 in the consolidated text.
- 1997-09-23 (applies): **End of the stock derogation** — Stock invoiced or delivered to the retailer before 23 March 1996 was exempt from the national measures until this date; from here on all footwear for sale to the consumer had to carry the material label.
- 1996-03-23 (applies): **Member States apply the labelling measures** — The transposing measures that Member States had to adopt and publish by 23 September 1995 apply from this date, as corrected by the corrigendum published in OJ L 47 of 24 February 1996 (marker C1 in the consolidated text). Three years after application the Commission was to report to the Council on difficulties encountered by operators.
- 1994-05-09 (in-force): **Directive 94/11/EC enters into force** — Adopted by the European Parliament and the Council on 23 March 1994 and published in OJ L 100 of 19 April 1994, the directive entered into force on 9 May 1994 according to the EUR-Lex document information; it contains no entry-into-force article of its own and is addressed to the Member States, which had to transpose it by 23 September 1995.

## FtLblD in plain terms

The Footwear Labelling Directive (FtLblD), formally Directive 94/11/EC, is the EU rule that tells the buyer what a shoe is made of. It applies to the labelling of the materials used in the main components of footwear for sale to the consumer, footwear meaning all articles with applied soles designed to protect or cover the foot, including parts marketed separately (Art. 1(1)). The label conveys the material of three parts, the upper, the lining and sock, and the outer sole, as one of four groups, leather, coated leather, textile or other materials, either by the pictograms of Annex I or by written indications in the language of the country of sale (Art. 1(2) and Art. 4(2)).

As a directive it works through national law: Member States had to adopt their measures by 23 September 1995 and apply them from 23 March 1996, with stock invoiced or delivered to retailers before that date exempt until 23 September 1997 (Art. 6). Member States must ensure that all footwear placed on the market meets the labelling requirements and take appropriate action under national law against footwear that does not (Art. 2), and they may not prohibit or impede compliant footwear by applying unharmonised national labelling rules (Art. 3). The text has been touched only three times since 1994, each time to add language versions of the written indications when new Member States joined (2004, 2007 and 2013); the Commission's footwear industry page presents the directive as protecting consumer interests by reducing the risk of fraud for both consumers and industry.

> **Official text**
> Read the directive on EUR-Lex: [Directive 94/11/EC (CELEX 31994L0011)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31994L0011), or the [consolidated text of 1 July 2013](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01994L0011-20130701) that includes the language terms added at the 2004, 2007 and 2013 enlargements.

## Scope

Footwear is any article with an applied sole designed to protect or cover the foot, including parts marketed separately (Art. 1(1)). Annex II gives a non-exhaustive list of what that covers: flat or high-heeled shoes for ordinary indoor or outdoor wear; ankle-boots, half-boots, knee-boots and thigh boots; sandals, espadrilles, tennis shoes, running and other sports shoes, bathing sandals and other casual footwear; special sports footwear with or designed for spikes, studs, stops, clips or bars, together with skating boots, ski boots, cross-country ski footwear, wrestling boots, boxing boots and cycling shoes, and composite articles of footwear with skates attached; dancing slippers; footwear formed from a single piece such as moulded rubber or plastics, but not disposable articles of flimsy material without applied soles; overshoes; disposable footwear with applied soles; and orthopaedic footwear. As a general rule, products of Chapter 64 of the Combined Nomenclature fall within the directive (Annex II).

Four groups are excluded (Art. 1(1)): second-hand, worn footwear; protective footwear covered by Directive 89/686/EEC, which Regulation (EU) 2016/425 repealed with effect from 21 April 2018 so that the reference is read as protective footwear under that regulation (Regulation (EU) 2016/425, Art. 46); footwear covered by Directive 76/769/EEC on restrictions of dangerous substances, repealed by the REACH Regulation (EC) No 1907/2006 with effect from 1 June 2009, references to the repealed directive to be read as references to that regulation (Regulation (EC) No 1907/2006, Art. 139; executive order nr. 1046/2021, § 2); and toy footwear. The directive is about footwear for sale to the consumer, so footwear that is never offered to consumers is outside it, while work or professional footwear sold to consumers that is not PPE must be labelled like any other shoe.

The duties fall on three actors. The manufacturer or its authorised agent established in the Community is responsible for supplying the label and for the accuracy of the information it contains; if neither is established in the Community, the obligation falls on the person responsible for first placing the footwear on the Community market; and the retailer remains responsible for ensuring that the footwear it sells bears the appropriate labelling (Art. 4(5)). The Danish order adds that an importer or retailer that places footwear on the market under its own name or trade mark is treated as the manufacturer (executive order nr. 1046/2021, § 15).

## What you must do

### The three parts and the four materials

Annex I defines the parts. The upper is the outer face of the structural element attached to the outer sole. The lining and sock are the lining of the upper and the insole, constituting the inside of the footwear. The outer sole is the bottom part, subjected to abrasive wear and attached to the upper (Annex I, point 1). For the upper, accessories and reinforcements such as ankle patches, edging, ornamentation, buckles, tabs, eyelet stays or similar attachments are left out of the classification; for the outer sole, the classification is based on the volume of the materials (Art. 1(2)(iii) and (iv)).

Annex I also defines the materials. Leather is hide or skin with its original fibrous structure more or less intact, tanned to be rot-proof, with or without hair or wool, including split or segmented hide; hide that is disintegrated into fibrous particles, small pieces or powder and re-formed into sheets is not leather, and any surface coating or glued-on finish may not be thicker than 0,15 mm. Coated leather is leather whose surface coating does not exceed one third of the total thickness of the product but is thicker than 0,15 mm. Textile means the products covered by Directive 71/307/EEC on textile names and its amendments, a reference that today points to the textile fibre names regime of Regulation (EU) No 1007/2011, which the Danish order uses to define a textile product (executive order nr. 1046/2021, § 3, nr. 5). Everything else is other materials (Annex I, point 2). The material pictograms appear on the label beside the pictograms for the three parts (Annex I, point 2).

### The 80 % rule

The label gives the material that constitutes at least 80 % of the surface area of the upper and of the lining and sock, and at least 80 % of the volume of the outer sole. If no one material accounts for at least 80 %, information is given on the two main materials used in the composition (Art. 4(1)). The Commission's footwear industry page summarises the same rule: only materials covering at least 80 % of the surface area or 80 % of the volume of the outer sole need to be labelled, and where that threshold is not met, information should be given on the two main materials used.

### Pictograms or words, and the language

The information is conveyed on the footwear itself. The manufacturer or its authorised agent established in the Community may choose either pictograms or written indications in at least the language or languages which the Member State of consumption may determine in accordance with the Treaty, as defined and illustrated in Annex I, and Member States must ensure that consumers are adequately informed of the meaning of the pictograms without creating trade barriers (Art. 4(2)). Annex I lists the written indications in every official language; for Denmark they are Overdel, Foring og bindsål and Ydersål for the parts and Læder, Overtrukket læder, Tekstil-materialer and Andre materialer for the material groups. The Danish order accepts either the pictograms or text in Danish and adds that the label may only name materials listed in its Annex I (executive order nr. 1046/2021, § 4, stk. 2, and § 5, stk. 3).

### Where and how the label goes

Labelling means affixing the required information to at least one article of footwear in each pair, by printing, sticking, embossing or an attached label (Art. 4(3)). The label must be visible, securely attached and accessible, the pictograms must be large enough to make the information easy to understand, and it must not be possible for the labelling to mislead the consumer (Art. 4(4)). Additional textual information may accompany the required information where the need arises, and Member States may not prohibit or impede compliant footwear on that account (Art. 5); where the optional term full grain leather is used, it applies only to leather bearing the original grain surface as exposed by removal of the epidermis, with none of the surface removed by buffing, snuffing or splitting (Annex I, point 2(a)(i)).

### Obligations by role

Manufacturers and their authorised agents in the Union choose the format, supply the label and answer for its accuracy (Art. 4(2) and Art. 4(5)). Importers step into that responsibility when neither the manufacturer nor its agent is established in the Union (Art. 4(5)). Retailers remain responsible for selling only labelled footwear (Art. 4(5)). The Danish order spells the chain out: the manufacturer labels the footwear before placing it on the market (§ 7); an authorised representative acts under a written mandate that may cover the labelling duties (§§ 8 and 9); the importer ensures the footwear is labelled before placing it on the market, holds it back if it knows or ought to know it is not, and acts immediately on footwear already placed (§§ 10 and 11); the retailer ensures the footwear is labelled before making it available, keeps the label visible and accessible to the consumer before the purchase, informs the consumer of the meaning of the pictograms before the purchase and holds back footwear it knows or ought to know is unlabelled (§§ 12 to 14); and own-brand importers and retailers are treated as manufacturers (§ 15). Erhvervsstyrelsen's guidance notes that the rules apply to online sales as well as physical shops, and that the meaning of the pictograms can be explained with a poster on the wall, leaflets in the shop or on the sales page where the footwear is added to the basket.

## Enforcement and penalties

Member States must ensure that all footwear placed on the market meets the labelling requirements and, where non-conforming footwear is placed on the market, take appropriate action as specified in their national legislation (Art. 2). The directive contains no penalty article of its own. Since 16 July 2021, Regulation (EU) 2019/1020 lists it in Annex I (point 8) as Union harmonisation legislation subject to the regulation's market surveillance framework and in Annex II (point 7) as legislation without provisions on penalties, which means Member States must lay down effective, proportionate and dissuasive penalties for infringements of it under Article 41 of that regulation (Regulation (EU) 2019/1020, Art. 41, Art. 44, Annex I and Annex II).

In Denmark, the product and market surveillance act (lovbekendtgørelse nr. 22 af 8. januar 2026) lists the footwear labelling directive among the acts it covers (§ 2, stk. 1, nr. 21), names Erhvervsstyrelsen as the control authority (§ 9(1)) and punishes with a fine an economic operator that places a non-compliant product on the market (§ 37(1)(1), read with § 5) or that disregards a decision of the authority (§ 37(1)(6)); because footwear labelling is a product area listed in § 2(1)(21), the penalty for those offences can rise to imprisonment of up to two years in aggravating circumstances such as danger to safety or health, an accident causing serious injury or death, a repeat infringement or a systematic infringement for economic gain (§ 37(2)), and companies can be held liable (§ 37(5)). Executive order nr. 1046 af 28. maj 2021, issued under §§ 8 and 37 of the act, lets the authority issue orders under § 14 of the act where footwear is not labelled in accordance with §§ 4 to 6 (§ 17) and provides fines for the manufacturer that fails to label, the authorised representative without a written mandate or that fails its tasks, the importer or retailer that places or makes available unlabelled footwear or fails to act on it, and the retailer that does not make the label visible or does not explain the pictograms before the purchase (§ 18), with companies liable under § 19. The authority is Erhvervsstyrelsen's department Markedsovervågning: from January 2026 Sikkerhedsstyrelsen is a department of Erhvervsstyrelsen under that name, performing the same tasks as before. It checks footwear and textile labelling through inspections of both web shops and physical shops.

## How Conphora helps

Conphora monitors FtLblD and the Danish order and maps your footwear against the labelling requirements, flagging gaps in the material classification, the 80 % rule, the pictogram or language choice and the responsibility chain before they become enforcement problems. The platform helps you keep the labelling documentation per model and alerts you when the rules or the Danish authority's practice change.

[See how Conphora works](/how-it-works) · [See plans and pricing](/pricing)

## Sources

- [Directive 94/11/EC on labelling of the materials used in the main components of footwear, consolidated text of 1 July 2013 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01994L0011-20130701)
- [Directive 94/11/EC as published in OJ L 100, 19 April 1994 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31994L0011)
- [Document information, dates and relationships for CELEX 31994L0011 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:31994L0011)
- [Council Directive 2006/96/EC, accession of Bulgaria and Romania (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006L0096)
- [Council Directive 2013/15/EU, accession of Croatia (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013L0015)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Regulation (EU) 2016/425 on personal protective equipment (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0425)
- [Footwear industry, labelling rules (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/sectors/textiles-ecosystem/footwear-industry_en)
- [Kontrol med mærkning af tekstilprodukter og fodtøj (Erhvervsstyrelsen, Markedsovervågning)](https://www.sik.dk/erhverv/produkter/tekstilprodukter-og-fodtoej/kontrol-maerkning-tekstilprodukter-og-fodtoej)
- [Bekendtgørelse nr. 1046 af 28. maj 2021 om mærkning af fodtøj og etikettering og mærkning af tekstilprodukter (Retsinformation)](https://www.retsinformation.dk/eli/lta/2021/1046)
- [Bekendtgørelse af lov om produkter og markedsovervågning, LBK nr. 22 af 8. januar 2026 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/22)
- [Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen (Erhvervsstyrelsen)](https://erhvervsstyrelsen.dk/sikkerhedsstyrelsen-en-del-af-erhvervsstyrelsen)

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

## Sources

- [Directive 94/11/EC on labelling of the materials used in the main components of footwear, consolidated text of 1 July 2013 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01994L0011-20130701)
- [Directive 94/11/EC as published in OJ L 100, 19 April 1994 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31994L0011)
- [Document information, dates and relationships for CELEX 31994L0011 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:31994L0011)
- [Council Directive 2006/96/EC adapting directives in the field of free movement of goods, accession of Bulgaria and Romania (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006L0096)
- [Council Directive 2013/15/EU adapting directives in the field of free movement of goods, accession of Croatia (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32013L0015)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Regulation (EU) 2016/425 on personal protective equipment, repealing Directive 89/686/EEC (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0425)
- [Footwear industry, labelling rules (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/sectors/textiles-ecosystem/footwear-industry_en)
- [Kontrol med mærkning af tekstilprodukter og fodtøj (Erhvervsstyrelsen, Markedsovervågning)](https://www.sik.dk/erhverv/produkter/tekstilprodukter-og-fodtoej/kontrol-maerkning-tekstilprodukter-og-fodtoej)
- [Bekendtgørelse nr. 1046 af 28. maj 2021 om mærkning af fodtøj og etikettering og mærkning af tekstilprodukter (Retsinformation)](https://www.retsinformation.dk/eli/lta/2021/1046)
- [Bekendtgørelse af lov om produkter og markedsovervågning, LBK nr. 22 af 8. januar 2026 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/22)
- [Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen (Erhvervsstyrelsen)](https://erhvervsstyrelsen.dk/sikkerhedsstyrelsen-en-del-af-erhvervsstyrelsen)

_Reviewed 2026-09-24 by Conphora compliance team_