{
  "type": "problem",
  "slug": "footwear-label",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/footwear-label/",
  "markdown": "https://www.conphora.com/solutions/problem/footwear-label.md",
  "title": "We sell shoes without the material label",
  "description": "Footwear material labelling under Directive 94/11/EC: the three parts, the 80 % rule, pictograms or words, and who supplies the label.",
  "answer": "Directive 94/11/EC requires footwear sold to consumers to carry a label on at least one shoe of each pair that states the material of the upper, the lining and sock, and the outer sole, by pictogram or written indication. The manufacturer or its EU authorised agent supplies the label, or the first placer on the EU market if neither is established in the EU. Retailers must check it is there.",
  "theme": {
    "id": "labelling-packaging",
    "label": "Labelling and packaging"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    },
    {
      "id": "distributor",
      "label": "Distributor"
    }
  ],
  "regulations": [
    "FtLblD"
  ],
  "path": [
    "regulation-library",
    "product-validation"
  ],
  "trigger": "A retailer or a market surveillance authority points out that shoes on sale carry no label for the upper, the lining and the outer sole",
  "keep": null,
  "why": [
    {
      "text": "Directive 94/11/EC sets one EU-wide scheme for telling consumers what their shoes are made of. It applies to the labelling of the materials used in the main components of footwear for sale to the consumer, and defines footwear as all articles with applied soles designed to protect or cover the foot, including parts marketed separately (Article 1(1)). Annex II gives examples, from sandals and espadrilles to ski boots, dancing slippers, disposable footwear and orthopaedic footwear. Excluded are second-hand worn footwear, toy footwear, protective footwear covered by Directive 89/686/EEC and footwear covered by Directive 76/769/EEC (Article 1(1)). Both directives have since been repealed: Regulation (EU) 2016/425 replaced the first from 21 April 2018, and references to it are read as references to that regulation (Article 46 of Regulation (EU) 2016/425); Regulation (EC) No 1907/2006 repealed the second with effect from 1 June 2009, and what that exclusion covers today is not clear from the text.",
      "sources": [
        1,
        5,
        6
      ]
    },
    {
      "text": "The label speaks about three parts. The upper is the outer face of the structural element attached to the outer sole; the lining and sock form the inside of the shoe; the outer sole is the bottom part subjected to abrasive wear (Article 1(2) and Annex I point 1). For the upper and for the lining and sock, the label names the material that makes up at least 80 % of the surface area; for the outer sole, at least 80 % of the volume. If no material reaches 80 %, the two main materials are given (Article 4(1)). Accessories and reinforcements such as ankle patches, edging, buckles and eyelet stays are not counted for the upper (Article 1(2)(iii)).",
      "sources": [
        1
      ]
    },
    {
      "text": "Materials fall into four categories defined in Annex I point 2: leather, coated leather, textile and other materials. The definitions matter. Hide or skin that is disintegrated into fibres, small pieces or powder and then made into sheets is not leather, and a surface coating on leather may not be thicker than 0.15 mm; coated leather has a coating thicker than 0.15 mm but not more than one third of the total thickness.",
      "sources": [
        1
      ]
    },
    {
      "text": "The form of the label is set too. The information is conveyed on the footwear itself, by pictograms or written indications in at least the language or languages the Member State of consumption may determine (Article 4(2)). It is affixed to at least one shoe of each pair, by printing, sticking, embossing or an attached label, and must be visible, securely attached and accessible, with pictograms large enough to be understood. It must not mislead the consumer (Article 4(3) and (4)). Additional text may accompany it (Article 5). Member States may not prohibit or impede footwear that meets these requirements by applying unharmonised national labelling rules (Article 3), and the Court has read Articles 3 and 5 as precluding a national country-of-origin labelling requirement for leather footwear components (Case C-95/14).",
      "sources": [
        1,
        4
      ]
    },
    {
      "text": "Responsibility sits with the business closest to the source. The manufacturer or its authorised agent established in the EU supplies the label and answers for its accuracy; if neither is established in the EU, the obligation falls on the person who first places the footwear on the EU market. The retailer remains responsible for ensuring that the shoes it sells bear the label (Article 4(5)). Because this is a directive, the Member States enforce it under national law (Article 2), and it is listed in Annex I to Regulation (EU) 2019/1020, so that regulation's corrective measures apply (Article 16).",
      "sources": [
        1,
        2
      ]
    }
  ],
  "steps": [
    {
      "name": "Check that the product counts as footwear",
      "text": "Footwear means all articles with applied soles designed to protect or cover the foot, from sandals to thigh boots, including sports shoes, slippers and disposable footwear with applied soles. Second-hand worn footwear and toy footwear are excluded, as are protective footwear covered by Directive 89/686/EEC, now read as Regulation (EU) 2016/425, and footwear covered by Directive 76/769/EEC, repealed in 2009.",
      "item": "regulation-library"
    },
    {
      "name": "Identify the material of each of the three parts",
      "text": "The label covers the upper, the lining and sock, and the outer sole. For the upper and the lining, name the material that makes up at least 80 % of the surface area; for the outer sole, at least 80 % of the volume. If no material reaches 80 %, give the two main materials. Ignore accessories such as buckles, edging and eyelet stays."
    },
    {
      "name": "Use the four material categories",
      "text": "Classify each part as leather, coated leather, textile or other materials, using the definitions in Annex I. Leather made into sheets from fibres or powder is not leather. Coated leather has a surface coating thicker than 0.15 mm but not more than one third of the total thickness.",
      "item": "product-validation"
    },
    {
      "name": "Choose pictograms or words and fix the label",
      "text": "Use the Annex I pictograms or written indications in the language or languages the Member State of consumption may determine. Put the information on at least one shoe of each pair by printing, sticking, embossing or an attached label. It must be visible, securely attached, accessible and not misleading."
    },
    {
      "name": "Agree who supplies the label",
      "text": "Settle in the purchase contract who provides the label and vouches for its accuracy: the manufacturer, its authorised agent in the EU, or, if neither is established in the EU, the business that first places the shoes on the EU market. As a retailer, check incoming pairs before they go on sale."
    }
  ],
  "documents": [
    {
      "name": "The label or marking for the upper, the lining and sock, and the outer sole",
      "from": "The manufacturer, its EU authorised agent, or the first placer on the EU market",
      "ground": "Directive 94/11/EC Article 4(1)–(5)"
    },
    {
      "name": "Supplier material specifications supporting the 80 % classification",
      "from": "The supplier",
      "ground": "Directive 94/11/EC Articles 1(2) and 4(1), Annex I"
    }
  ],
  "risks": [
    {
      "title": "Shoes without the label may be acted against",
      "text": "Member States ensure that all footwear placed on the market meets the labelling requirements; where non-conforming footwear is placed on the market, the competent Member State takes appropriate action under its national legislation (Directive 94/11/EC Article 2(1) and (2)).",
      "source": 1
    },
    {
      "title": "The retailer stays responsible",
      "text": "The supplier of the label answers for its accuracy, but the retailer remains responsible for ensuring that the footwear it sells bears the prescribed labelling (Directive 94/11/EC Article 4(5)).",
      "source": 1
    },
    {
      "title": "Market surveillance measures apply",
      "text": "The footwear labelling directive is listed in Annex I to Regulation (EU) 2019/1020; where a product does not conform, authorities require corrective action and, if it is not taken, ensure the product is withdrawn or recalled or its sale prohibited (Regulation (EU) 2019/1020 Article 16(1), (2), (3) and (5)).",
      "source": 2
    }
  ],
  "faq": [
    {
      "q": "Does every shoe need a label, or one per pair?",
      "a": "One per pair is enough. Labelling means affixing the required information to at least one article of footwear in each pair (Directive 94/11/EC Article 4(3))."
    },
    {
      "q": "Can we use words instead of the pictograms?",
      "a": "Yes. The manufacturer or its authorised agent in the EU may choose pictograms or written indications, in at least the language or languages the Member State of consumption may determine (Directive 94/11/EC Article 4(2))."
    },
    {
      "q": "The upper is half leather and half textile. What do we write?",
      "a": "If no one material accounts for at least 80 %, the label gives the two main materials used (Directive 94/11/EC Article 4(1))."
    },
    {
      "q": "May we add ‘full grain leather’ or other text?",
      "a": "Additional text may accompany the required information. ‘Full grain leather’ may only be used for leather that keeps its original grain surface, with none of the surface removed by buffing, snuffing or splitting (Directive 94/11/EC Article 5 and Annex I point 2(a)(i)). Member States in turn may not impede footwear that meets the directive with unharmonised national labelling rules; the Court has held that Articles 3 and 5 preclude a national ban on leather footwear components without a country-of-origin label (Case C-95/14)."
    },
    {
      "q": "Does the directive say what the web shop must show?",
      "a": "No. The directive requires the information on the footwear itself (Article 4(2) and (3)). It sets no rule for online display. An online offer of footwear must show the information in Article 19 of the General Product Safety Regulation, such as the manufacturer's details, product identification and any warnings, but that list does not include the materials. Whether other consumer rules require the materials before a distance sale is a question for a lawyer."
    }
  ],
  "sources": [
    {
      "title": "Directive 94/11/EC on labelling of the materials used in the main components of footwear for sale to the consumer (consolidated text of 1 July 2013)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01994L0011-20130701",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R0988-20260529",
      "accessed": "2026-10-04"
    },
    {
      "title": "Judgment of the Court of 16 July 2015, UNIC and Uni.co.pel, Case C-95/14",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62014CJ0095",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2016/425 on personal protective equipment",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0425",
      "accessed": "2026-10-04"
    },
    {
      "title": "Directive 76/769/EEC on restrictions on the marketing and use of certain dangerous substances and preparations (document page: repealed by Regulation (EC) No 1907/2006, end of validity 31 May 2009)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:31976L0769",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "textile-label",
    "label-no-eu-address",
    "small-product-label",
    "distributor-duties",
    "product-images-warnings"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-04",
  "notice": "General information, not legal advice."
}