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Exporting clothing, footwear and textiles from the EU

Clothing and textiles leave the EU through the standard export procedure, with an EORI number and an export declaration in AES. To claim a lower tariff, garments must meet the trade agreement's list rule, which for textiles often requires specific processing such as spinning, with its own tolerances. Exporting cat and dog fur, or products containing it, is prohibited.

Updated · Each section links to the official source it comes from

Classification
HS Chapters 50 to 63 for textiles and clothing
Origin rules
Often 'specific processing' rules, with textile tolerances
Proof of origin
REX statements on origin or EUR.1, by agreement
Export ban
Cat and dog fur, and products containing it
Declaration
Electronic export declaration in AES, with an EORI number

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Which HS heading is the garment or textile classified under? Read more
  2. 2Does it meet the agreement's list rule, and what proof of origin goes with it? Read more
  3. 3Does it contain cat or dog fur, or is the destination subject to sanctions? Read more
  4. 4Which certificates and test reports does the destination accept? Read more
  5. 5Who lodges the export declaration, and are the documents ready? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Tariff classification of textiles

The HS heading decides the tariff, the measures that apply and the origin rule.

    • Access2Markets' guide to classifying textiles explains how to classify garments to find the applicable customs duties and non-tariff measures; a small feature can change the heading.
    • For example, knitted or crocheted blouses and shirt blouses fall under heading 6106 and others under 6206; garments with pockets below the waist or a tightening at the bottom are classified elsewhere.
    • The list rules of origin are based on the HS nomenclature, so the product's heading must be identified before the rule can be read.
    • Customs can give legal certainty on the code through a Binding Tariff Information decision.

    How we help: Compliant Always keeps the classification behind each product, and any binding decision, with the product file, dated. Ask about this

    Origin and proof of origin

    Preferential origin under EU trade agreements, how it is proved, and certificates of non-preferential origin.

    • To get a lower or zero tariff under a trade agreement, goods must be wholly obtained in the EU or sufficiently worked or processed there under the product-specific 'list rules' of the agreement's origin protocol, read by HS heading.
    • The Commission's Rules of Origin Self-Assessment tool (ROSA), in Access2Markets' My Trade Assistant, helps check a product against the rules and explains which proof of origin to prepare.
    • Product-specific rules can require a specific production process, such as spinning of fibres for yarns; such rules are mostly used in the textile, clothing and chemical sectors.
    • A tolerance lets producers use some non-originating materials the rule would otherwise prohibit; specific tolerances apply to textiles and clothing classified in HS Chapters 50 to 63.
    • Insufficient operations, such as ironing or pressing of textiles, packaging or simple assembling, never confer origin on their own.
    • Cumulation can let materials originating in a partner country count as originating, where the countries apply identical origin rules.
    • Proof can be a movement certificate EUR.1 or EUR-MED issued by customs, or a self-declaration by the exporter on a commercial document: a statement on origin, or an invoice or origin declaration.
    • EU exporters must be registered in REX, with their national competent authorities, to make out statements on origin under agreements including those with Canada, Japan, Vietnam, Singapore, the UK, New Zealand and Chile, and the EU-MERCOSUR Interim Agreement.
    • Without a REX number, an exporter may make out statements on origin for consignments of originating products worth up to EUR 6 000 (EUR 10 000 for trade with the OCTs).
    • Suppliers' declarations let an exporter rely on the originating status of materials bought in the EU. Exporters keep copies of proofs of origin and related records for at least three years.
    • A Binding Origin Information (BOI) decision from customs fixes the origin of goods for up to three years, but does not replace the proof of origin.
    • A certificate of non-preferential origin may be required by the destination; Access2Markets says these are usually issued by the local chamber of commerce, and in some countries by ministries or customs.

    How we help: Compliant Always keeps the REX number, suppliers' declarations and each statement on origin or certificate with the shipment it covers, and shows which proofs are missing or out of date. Ask about this

    Export restrictions, licences and sanctions

    Goods and destinations that need an export licence or cannot be exported at all.

    • The placing on the market, and the import to or export from the EU, of cat and dog fur and products containing such fur are prohibited (Article 3 of Regulation (EC) No 1523/2007).
    • Access2Markets says the export of some goods, or exports to certain destinations, may be prohibited or restricted and need a licence; check TARIC for export licences and the EU Sanctions Map for restrictions.
    • Restricted or prohibited types include some live animals, meat and plants, certain food products, dangerous chemicals, drugs and medicines, dual-use goods, waste, cultural goods and counterfeit goods.
    • Member states may exceptionally have national restrictions, which are checked with their competent authorities.
    • The export procedure includes presenting export licences, and an oral declaration is not allowed for goods subject to prohibitions or restrictions.
    • EU sanctions on Russia (Regulation (EU) No 833/2014) prohibit exports of listed goods and oblige operators to contractually prohibit the re-export of certain sanctioned goods.

    How we help: Compliant Always keeps any licence with the shipments it covers and shows when it is near its end, before the next shipment is declared. Ask about this

    Documents for the destination

    What the importing country may ask the EU exporter to supply, as Access2Markets sets it out.

      • The destination's health, safety and technical requirements usually fall to the buyer as importer, who will need the exporter's help to show compliance. Access2Markets advises assuming only what the exporter can fulfil.
      • The destination may ask for certificates showing the product meets its health and safety rules, which may differ from the EU's.
      • Check in My Trade Assistant's Procedures and Formalities section which certificates the destination accepts, and whether testing can be done by an accredited laboratory in the EU or must be done in the destination.
      • Destination authorities may also ask for a commercial invoice, packing list, import licence, proof of preferential origin, or a certificate of non-preferential origin.

      How we help: Compliant Always reads your test reports and certificates against what the destination asks for, and answers importers' questions from the record. Ask about this

      EORI and the export declaration

      Who may export, the registration number every declaration carries, and the two stages of the export procedure: export and exit.

      • The export procedure (Article 269 UCC) is obligatory for EU goods leaving the EU customs territory, with very few exceptions, so that export measures such as restrictions are applied.
      • An EORI number is mandatory for customs operations in the EU, export included. It is assigned by the customs authority of the member state where the operator is established, and does not expire.
      • Access2Markets says an exporter normally needs to be established in the EU, including a VAT registration; a non-EU resident needs a person established in the EU, such as a logistics provider or customs agent, to act as exporter.
      • The export declaration is lodged electronically in the Automated Export System (AES), at the customs office for the place where the exporter is established or where the goods are packed or loaded (Article 221(2) UCC-IA).
      • It gives the origin of the goods, the destination country, commodity codes, customs procedure codes and the value. Customs may release the goods, ask for documents, or check them physically.
      • The goods and the Master Reference Number (MRN) are then presented at the customs office of exit, which supervises their departure. Goods stay under customs supervision until they leave.
      • Keep invoices, transport documents and packing lists for at least three years. Exports are exempt from EU VAT if records and the customs proof of export are kept.

      How we help: Compliant Always keeps the EORI, invoice, packing list, MRN and proof of exit with each shipment, dated, and shows what is missing before the goods are declared. Ask about this

      Who answers for what

      WhoWhat they answer forHow we help
      ExporterClassification, the export declaration, the EORI number, and proof of origin where preference is claimed.The shipment's documents kept together and dated.
      ManufacturerThe production steps and materials behind the origin calculation, and fibre and fur content.Bills of materials and suppliers' declarations kept by style and lot.
      Suppliers of yarn and fabricSuppliers' declarations on the origin of the materials they supply.Suppliers' declarations dated and shown when they lapse.
      Customs representative or forwarderLodging the declaration and presenting the goods for export and exit.The documents behind the declaration, ready before it is lodged.

      Member states

      The export rules are EU law, but member states run them. The EORI number, the export declaration, origin registrations such as REX and approved exporter status, and dual-use licences go through the national authorities of the member state concerned.

      Export certificates for food, animal products and plants are issued by member states' competent authorities; the Commission supplies harmonised certificates through TRACES and guidance in its Export library. Certificates of non-preferential origin are usually issued by local chambers of commerce.

      Where are the goods going?

      Most of what clothing, footwear and textiles have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

      Questions businesses ask

      Do EU-made clothes qualify for lower tariffs abroad?
      Only if they meet the list rule for their heading in the trade agreement, and the proof of origin it requires is supplied. Textile and clothing rules often require a specific production process, such as spinning of fibres for yarns.
      Is sewing a garment in the EU enough for EU origin?
      It depends on the agreement's list rule for the garment's heading, which may require specific processing of the materials. Insufficient operations, such as ironing or pressing, packaging or simple assembling, never confer origin on their own.
      What tolerance applies to textiles in rules of origin?
      The tolerance rule lets a producer use some non-originating materials the list rule would otherwise prohibit. Specific tolerances apply to textiles and clothing in HS Chapters 50 to 63; check the agreement that applies.
      What is cumulation of origin for textiles?
      A rule letting materials originating in one partner country count as originating when further processed in another, if both apply identical origin rules. There are bilateral, diagonal, regional and full cumulation.
      Can I export products containing cat or dog fur from the EU?
      No. Regulation (EC) No 1523/2007 prohibits the placing on the market, import and export of cat and dog fur and products containing it.
      How do I classify a garment for export?
      By its HS heading, based on its features. Access2Markets' classification guide for textiles explains the headings, and customs can issue a Binding Tariff Information decision for legal certainty.
      What proof of origin do textiles need for the UK or Japan?
      A statement on origin by an exporter registered in REX. Without a REX number, one may be made out for consignments worth up to EUR 6 000.
      Do I need suppliers' declarations to prove textile origin?
      Often. Access2Markets says proofs for the originating status of materials bought within the EU are given by suppliers' declarations, which the exporter collects.
      Do I need an EORI number to export clothing?
      Yes. An EORI number is needed for every export declaration. It is assigned by the customs authority of the member state where you are established.
      How does Compliant Always help with exporting from the EU?
      Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

      Sources

      Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

      Tell us what you make, and we will show you the rules for it.

      Name the product and the markets you sell in. We will come back to you with what applies in the EU and what your paperwork needs to show.

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