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), or the consolidated text of 1 July 2013 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.
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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)
- Directive 94/11/EC as published in OJ L 100, 19 April 1994 (EUR-Lex)
- Document information, dates and relationships for CELEX 31994L0011 (EUR-Lex)
- Council Directive 2006/96/EC, accession of Bulgaria and Romania (EUR-Lex)
- Council Directive 2013/15/EU, accession of Croatia (EUR-Lex)
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)
- Regulation (EU) 2016/425 on personal protective equipment (EUR-Lex)
- Footwear industry, labelling rules (European Commission, DG GROW)
- Kontrol med mærkning af tekstilprodukter og fodtøj (Erhvervsstyrelsen, Markedsovervågning)
- Bekendtgørelse nr. 1046 af 28. maj 2021 om mærkning af fodtøj og etikettering og mærkning af tekstilprodukter (Retsinformation)
- Bekendtgørelse af lov om produkter og markedsovervågning, LBK nr. 22 af 8. januar 2026 (Retsinformation)
- Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen (Erhvervsstyrelsen)
This guide is for general information and is not legal advice.