Scope note. This page is a checklist of what to confirm and who to ask. It is not legal advice, requirements change, and the correct answer depends on your specific product composition and destination. Verify with your own customs broker or compliance adviser before you place an order.
Who Is Legally Responsible for Bag Labelling?
The single most useful thing to understand: compliance obligations land on the importer of record, not on the overseas factory. A factory will print whatever label your purchase order specifies. If the specification is wrong or missing, the goods are still yours and the problem is still yours.
Never treat "the supplier handles compliance" as a plan. Treat the label content as a line item in your specification, exactly like fabric weight.
What Does Fibre Content Labelling Require?
European Union
Textile fibre composition labelling in the EU is governed by Regulation (EU) No 1007/2011. In outline:
- Fibre composition must be stated by percentage — for example "100% cotton" or "60% cotton, 40% polyester".
- The label should be durably attached, visible and legible.
- Where a product contains non-textile parts of animal origin (leather trim, for instance), that must be indicated.
- Notably, a carrier bag made of polypropylene and calcium carbonate — the typical non-woven shopper — is in principle outside the mandatory textile labelling scope, because it is not a textile product in the regulation's sense.
That last point matters commercially: a cotton tote and a non-woven tote can carry different labelling obligations even when they sit side by side in the same order.
United States
Governed by the Textile Fiber Products Identification Act, enforced by the FTC. Points that recur for bag buyers:
- A "textile fibre product" is generally one containing at least 80% textile fibre by weight once ornamentation is removed.
- Country of origin must appear in English.
- Handbags are specifically exempted under the Act — but that exemption should not be assumed to extend to tote bags, shoppers or drawstring bags. If you are relying on an exemption, confirm it applies to your exact product with your broker.
- Customs may test fibre content, and mislabelled shipments can be detained.
Can You Legally Call a Bag "Reusable"?
Calling a bag reusable can carry a legal definition rather than a marketing meaning. Some US jurisdictions define a reusable bag by minimum performance — a stated carrying capacity sustained over a stated number of uses, and sometimes a minimum material thickness or washability requirement. These are state and municipal rules, and they differ.
If your bag is being sold into a jurisdiction with a single-use plastic restriction, confirm the local definition of "reusable" before fixing fabric weight — the definition may set your minimum specification for you.
What Do Recycled and Eco Claims Require?
Claims like "recycled", "organic" or "biodegradable" attract more scrutiny than material descriptions, and generally need substantiation:
- Recycled content — typically evidenced through a chain-of-custody certification. Ask whether certification covers this specific production run, not just that the mill holds a certificate.
- Organic cotton — likewise certificate-based, with transaction-level documentation.
- Biodegradable / compostable — the most heavily policed category in both markets. Do not make this claim without test evidence you have actually seen.
If a claim will appear on your packaging or website, get the supporting document before production, not when a regulator asks.
What Should You Put in Your Purchase Order?
| Item | Why it belongs in the PO |
|---|---|
| Exact label wording and fibre percentages | Factory prints what you specify; ambiguity becomes a relabelling job |
| Label type and attachment | EU expects durable attachment; a hangtag may not qualify |
| Country-of-origin marking | Required in English for the US |
| Language(s) | Some EU member states require the local language |
| Any claim to be printed | "Recycled", "organic" and similar need supporting documents |
| Documents to accompany shipment | Certificates, test reports, declarations |
Which Compliance Questions Can Only Your Broker Answer?
- Tariff classification. The heading depends on material composition and construction — a coated or lined bag may classify differently from a plain one. This drives your duty rate.
- Applicable duty rate and any trade measures for your material and origin.
- Whether an exemption applies to your specific product.
- Local definitions of "reusable" where you sell.
Your factory can tell you what the bag is made of and print what you specify. It cannot tell you how your customs authority will classify it. Those are different jobs — ask each party the question they can actually answer.