Who this guide is for
This guide is written for brand owners, importers and sourcing managers who buy underwear from China and sell it into the United States, the European Union, or both. It covers the label itself: what has to be printed on it, in which language, and under which regulation.
It is written from the buyer’s side of the table. When a label is wrong, the exposure lands on whoever placed the product on the market — in most programmes, that is the brand, not the supplier.
What it deliberately does not cover. It does not list the chemical restrictions that apply to textiles (REACH, CPSIA and their test methods are a separate subject), and it does not hand you a template to print without checking your own markets. It answers the question buyers actually arrive with: which rules apply, where they differ, and whether one label can satisfy all of them.
Which label rules apply to underwear — by market?
Three markets, six instruments. The table is the short version; each row is expanded in the sections below.
| Element on the label | United States | European Union | United Kingdom |
|---|---|---|---|
| Fibre composition | Required — 16 CFR Part 303 | Required — Regulation (EU) 1007/2011 | Required — SI 2012/1102 |
| Care instructions | Required — 16 CFR Part 423 | Not required by law | Not required by law |
| Country of origin | Required, on the front of the label | Not required | Not required |
| Company identity | Name, or an RN number | Not required by 1007/2011 | Not required by SI 2012/1102 |
| Language | English | Official language(s) of the country of sale | English |
| Safety and responsible operator | CPSIA for children’s styles | GPSR, applicable since 13 December 2024 | UK GPSR 2005 |
What must be on an underwear label in the United States?
US labelling is not one rule. Three instruments apply to the same label, and they come from two different agencies — which is why a supplier can satisfy one and fail another.
Fibre content, company identity and country of origin — 16 CFR Part 303
Under the Textile Fiber Products Identification Act, most textile garments sold in the US need a label carrying three things: the generic name and weight percentage of each constituent fibre, the company responsible for the product (its name, or a Registered Identification Number), and the country where the product was processed or manufactured.
Two details catch first-time buyers:
- Order and threshold. Fibres are listed in descending order by weight. Any fibre present at 5% or more must be named individually; below that it may be grouped as other fiber and placed last.
- Where the origin sits. Country of origin must appear on the front side of the label. On a garment with a neck — underwear tops included — it must be affixed inside the centre of the neck, midway between the shoulder seams, or adjacent to another label in that position.
Fibre names are not free text: the rules set the permitted generic names, and ISO 2076 is accepted alongside them. A fibre regenerated from bamboo is labelled rayon, not bamboo — a point the FTC has enforced.
Care instructions — 16 CFR Part 423
The FTC’s Care Labeling Rule requires a permanent care label that stays with the garment through its useful life, stating at least one cleaning method that will not harm the product. Where washing is stated, the label must also give the water temperature, the drying method and whether ironing is needed. Where a reasonable consumer action would damage the product, the label must warn against it: do not iron, only non-chlorine bleach.
The rule was amended in 2024. The definition of drycleaning was updated, and wetcleaning was recognised as a professional process alongside washing and drycleaning. Every instruction printed has to rest on a reasonable basis — testing, current technical literature, or documented industry practice.
Country of origin on imports — 19 CFR Part 134
Separate from the FTC rules, US Customs requires every imported article to be marked with its country of origin, legibly and permanently, so that the ultimate purchaser sees it. On underwear that is usually the same label that already carries fibre content. The obligation nevertheless comes from a different agency, and a missing mark is a customs problem rather than a labelling one.
Children’s styles add a second layer
If the programme includes kids’ underwear, labelling sits under a further set of rules for children’s products, and the age grading of the style decides what applies. We cover the mechanical and chemical side of that in our guide to kids’ underwear safety standards.
What must be on an underwear label in the European Union?
Fibre composition is the only mandatory element — Regulation (EU) 1007/2011
EU textile labelling is narrower than most buyers assume. Regulation 1007/2011 requires one thing: an accurate declaration of fibre composition, by weight, in descending order, using the standard fibre names listed in Annex I. It does not require care instructions. It does not require the country of origin. It does not require the manufacturer’s or the importer’s name.
The regulation applies to products containing at least 80% textile fibre by weight, which covers underwear. Fibre names are limited to the standard list: premium cotton or organic silk may not appear in the composition line, whatever the packaging claims elsewhere. The words 100%, pure and all may be used only where the product is made of a single fibre.
A certification mark such as OEKO-TEX Standard 100 may be printed on a label, but it is a claim about testing, not a labelling requirement — and it is the certificate holder’s mark to authorise. On a sourcing programme the holder is the partner factory, not the brand and not the trading company. Our comparison of underwear certifications sets out who holds what.
Language follows the country of sale
Composition must be given in the official language or languages of the member state where the product is made available to the consumer. A style sold in Germany, France and Spain carries German, French and Spanish — on separate labels or a single multi-language panel. Belgium has more than one official language, so a Belgian assortment can require Dutch, French and German on one label.
What the GPSR adds on top
Since 13 December 2024 the General Product Safety Regulation (EU) 2023/988 applies alongside 1007/2011, and it is the piece most suppliers have not caught up with. It requires an economic operator established in the EU to be responsible for the product, and that operator’s name, postal address and electronic address must appear on the product, its packaging or an accompanying document. The manufacturer’s identity goes on as well. For a brand outside the EU with no establishment inside it, that means appointing an authorised representative or working through an importer — a factory in China cannot be the responsible operator.
The GPSR also requires an internal risk analysis and technical documentation, kept for ten years. It does not change the fibre-composition rule; it sits on a second panel or a second label.
Does the UK still follow the EU labelling rules?
Substantially, yes — which surprises buyers who assume Brexit split the two regimes. The Textile Products (Labelling and Fibre Composition) Regulations 2012 remain in force and keep the fibre-composition requirement, enforced by UK market surveillance rather than an EU authority. The practical differences are language and address: the UK market needs English rather than the language of a member state, and a UK responsible person replaces the EU one.
Can one label serve the EU, the US and the UK at once?
The union, not the intersection
Yes, and it is normal practice for a supplier shipping one programme to several markets. The label has to carry the union of the requirements, not the overlap:
| Element | Why it is on the label |
|---|---|
| Fibre composition, descending order, using Annex I names | EU 1007/2011, UK SI 2012/1102, US 16 CFR 303 |
| Composition repeated in each EU market’s language | EU 1007/2011, Article 16 |
| Care instructions, in English and symbols | US 16 CFR 423; commercial practice elsewhere |
| Country of origin, on the front of the label | US 16 CFR 303 and 19 CFR 134 |
| Responsible company name, or an RN number | US 16 CFR 303 |
| EU responsible operator, name and address | GPSR (EU) 2023/988, Article 16 |
Where a single panel fails
The extra US elements do not make a label non-compliant in the EU: the EU regulates what must appear in the composition line, not what else may sit on the panel. The reverse is not automatic. An EU-only label carrying composition in three languages, but no country of origin and no company identity, will fail in the US — and it fails at the point of import, not at the point of sale.
Fibre-content tolerance: why 3% appears on both sides
Both regimes accept that a stated percentage will not match a laboratory result exactly, and both settle on 3% — but the two 3%s do different work, and the small-fibre rules are not the same.
| Point | United States — 16 CFR 303 | European Union — Article 20 |
|---|---|---|
| Manufacturing tolerance | 3% between stated and tested content | 3% between stated and tested content |
| Fibres under 5% | May be grouped as other fiber and listed last | No grouping rule; extraneous fibres up to 2% need not be declared |
| Carded and woollen goods | — | Extraneous fibres up to 5% need not be declared |
What the tolerance does not cover
Stating 95% cotton and 5% elastane covers you to a test result between 92% and 98% cotton, in both markets. It does not cover naming a fibre that is not present, or printing 5% elastane when the garment contains 1%. The tolerance absorbs manufacturing variation, not a wrong description.
Are care labels legally required in the EU?
No — and this is the most common misconception in the category. Regulation 1007/2011 does not require care instructions; fibre composition is the only element it makes mandatory. Care symbols are governed by the voluntary standard ISO 3758, administered through GINETEX, and adopted as industry practice rather than law.
In practice the distinction is academic for the supplier. Major EU retailers make care labelling a condition of the order, and a garment with no care instruction generates returns. But if a buyer asks whether a care label is a legal requirement in the EU, the accurate answer is that it is a commercial requirement, not a statutory one.
What are the penalties for non-compliant labelling?
| Market | Exposure |
|---|---|
| United States — FTC | A civil penalty per mislabelled garment, each garment a separate violation; the inflation-adjusted figure is above US$53,000 per violation as of 2025 |
| United States — Customs | Missing country-of-origin marking: the shipment can be withheld, marked at the importer’s cost, or denied entry |
| European Union | 1007/2011 leaves penalties to each member state; market surveillance can order withdrawal from the market, and national fines vary widely |
| United Kingdom | SI 2012/1102 creates offences with their own penalties, enforced by UK market surveillance |
United States
The penalty structure is what makes a labelling error expensive rather than embarrassing: the FTC treats each mislabelled garment as a separate violation, so an error across a 20,000-piece programme is not one mistake but twenty thousand. Customs exposure runs on a different track — there, the goods themselves can be stopped.
European Union
Regulation 1007/2011 sets the requirement and leaves the sanction to member states, so the fine depends on where the product was made available. The remedy that matters most commercially is withdrawal from the market, which pulls the style off the shelf in every affected state at once.
United Kingdom
The 2012 regulations create specific offences with their own penalties, enforced by UK market surveillance rather than an EU body.
How we handle labelling on an order
Unitex Underwear is a sourcing and supply-chain management company. We place, follow and inspect underwear orders in partner factories across the Xiamen–Quanzhou–Jinjiang knitwear cluster in Fujian, China. On labelling that means three things — and one thing that it does not mean.
What we need from you
- The markets the programme will be sold in, listed per style. A style sold in Germany, France and Poland needs three languages; the same style sold only in Ireland needs English.
- The legal entity that will appear on the label as the responsible company or brand owner, with its registered address.
- For EU programmes, the name and address of your EU responsible operator under the GPSR.
What we do
- We build the label specification against the markets you name, and put the composition line, the care instruction set and the origin marking in writing before sampling.
- We coordinate the fibre-composition and care-performance testing the label rests on, and keep the reports with the order file.
- We give you label artwork for approval before bulk, so a missing language panel or origin mark is caught at the sample stage rather than at the port.
What we do not do
We are not the responsible operator on your label, and we do not absorb your compliance obligation. The label names your company because your company places the product on the market. What we can do is make sure the label artwork we prepare matches the rules of the markets you tell us about — which is why we ask for the market list before the first sample, not before the first shipment.
Label formats, materials and application methods sit next to this subject; our packaging and labelling guide covers which label construction survives repeated washing and which does not.
Compliance & verification
Every requirement in this guide traces to a published instrument, and each one is linked in the sources below so you can check it rather than take our word for it. The four that carry the most weight in practice:
- Regulation (EU) No 1007/2011 — fibre composition, the Annex I fibre names, Article 16 on language, Article 20 on tolerances.
- Regulation (EU) 2023/988 (GPSR) — responsible economic operator and traceability, applicable from 13 December 2024.
- 16 CFR Part 303 and Part 423 — US fibre content, country of origin, and care instructions.
- 19 CFR Part 134 — US customs marking of country of origin.
Fibre composition and care claims are testable. If you want evidence behind a label, ask the supplier for the composition test report and the basis for the care instructions printed — not for a certificate of the label itself, because no such certificate exists. Buyers who want the equivalent check for a supplier rather than a garment will find it in our B2B sourcing FAQ.
· Xiamen Unitex Trade Co., Ltd. — OEM & ODM underwear sourcing partner