Activewear compliance by market: US, Canada, EU, UK and AU/NZ

The leggings are identical. The label, the test report and the customs paperwork are not. Most compliance trouble in activewear is not caused by a garment failing a test — it is caused by nobody deciding which tests apply until the goods are already made, at which point the fabric has been bought, the labels have been printed, and the only remaining options are expensive.

This is a plain-English map of what buyers normally require market by market, and what we put into the protocol at development stage so the fabric we quote is a fabric that can actually pass.

Market by market

United States

Two things drive most US activewear programs. The first is labelling: the FTC requires fibre content, the country of origin and the identity of the responsible company, and care instructions must be permanently attached under the Care Labeling Rule. None of that is difficult — but it has to be right on the trim card before the trims are cut, because a label error is a relabelling job on every piece.

The second is children’s product rules. If any part of the range is designed or intended for children 12 and under, CPSIA applies: third-party testing at a CPSC-accepted lab, a Children’s Product Certificate, and permanent tracking labels on the product and its packaging. Lead and phthalate limits reach the trims — drawcord tips, zipper pulls, snaps — not just the fabric. Youth activewear is where importers most often discover this late.

California Proposition 65

Prop 65 is not a ban list; it is a warning requirement, and the decision on whether to warn is the importer’s. What a factory can do is give you the evidence to make that decision properly: substance screening on the dyed lots and the trims in your order, plus the report itself. We do that screening; we do not tell you what your warning statement should say, because that is a legal call about your product and your channel.

Canada

Canada layers two things on top of a normal US-style program. The Textile Labelling and Advertising Regulations require fibre content in both English and French, along with a dealer identity (a CA number or full name and address), and care symbols follow the CGSB system. The Canada Consumer Product Safety Act sits underneath as the general safety obligation.

The practical consequence is small but easy to get wrong: bilingual content doubles the label copy, which changes the label size, which changes where it sits in the garment. It belongs in the trim card at development, not in an email after the labels are woven.

European Union

The EU is the most chemistry-driven of the major markets. REACH restricts a long list of substances in textiles, including the azo dyes that can release restricted aromatic amines, and the list is revised — which is why testing to the current scope matters more than a certificate issued three years ago. Regulation 1007/2011 controls fibre naming: the permitted names are prescribed and the percentages must add up, with only specific tolerances allowed.

For elastane-heavy activewear the composition line is where errors show up. A fabric sold to you as “88% polyester 12% spandex” has to be declared using the EU fibre name — elastane — and the declared percentages have to survive a lab check on the actual bulk fabric, not the swatch.

United Kingdom

Since divergence the UK runs its own REACH regime and its own textile labelling rules. In practice the test scope is largely the same as the EU’s today, but the report has to be issued against the UK protocol, and the two regimes can drift apart over time. If a program ships to both, we run the scope that satisfies the stricter of the two and issue the documentation each side needs rather than assuming an EU report is automatically enough.

Australia and New Zealand

Care labelling under the ACCC’s mandatory standard is the main requirement, with fibre content in the AS/NZS format. Compared with the EU and US programs this is a light regime — but it is a genuine mandatory standard, not a guideline, and the care symbols must be the correct set.

What good factory practice looks like

Protocol first, not after

Your market’s requirements go into the test protocol at development stage. That way the fabric we quote is a fabric that can pass it — rather than a cheaper fabric that fails a REACH screen after 3,000 metres have been dyed.

Independent labs only

Reports come from SGS, or a CMA/CNAS-accredited lab, issued in your name where you need them in your name. We do not issue our own certificates of compliance, because a self-issued certificate is worth nothing to a customs broker or a retailer’s compliance desk.

Documents travel with the shipment

Test reports, the inspection report and the pre-shipment photo report go out with the shipping documents. A broker waiting on a factory for paperwork is a demurrage bill with a delay attached.

A note on OEKO-TEX and recycled claims

Two things buyers ask for that are worth separating. OEKO-TEX® STANDARD 100 is a certification of the material against a skin-contact substance list; it is issued to whoever holds the certificate for that article, and it is not a substitute for market-specific compliance — a certified fabric still needs correct EU fibre naming and correct US care labelling. Recycled content claims (GRS and similar) are a chain-of-custody scheme: the claim is only as good as the transaction certificates behind each step, so if recycled polyester matters to your brand story, agree the scheme before the yarn is bought.

The disclaimer that matters

This is a summary of what our buyers usually need, not legal advice. Which rules apply to your product depends on what you sell, who wears it and where you sell it, and rules change — your compliance obligation is yours as the importer. What we can promise is the operational half: send us your protocol and we will test to it, put it in the order before sampling, and hand you the reports with the goods.

If you do not have a protocol yet, tell us the destination markets and whether any of the range is for children, and we will draft the test list we would run and let your compliance advisor mark it up.