Germany is the largest apparel market in the EU and one of the strictest on labelling process. It transposed EU Regulation 1007/2011 into its own Textile Labelling Act (TKG), and turned packaging registration into a hard gate through the Packaging Act (VerpackG). For a Chinese trims supplier, hang tags, woven labels, care labels and poly bags in Germany are not finished once the words are printed correctly: the statutory fibre names must be right, the responsible operator must be identified, and the packaging registration must exist.

This guide unpacks three layers: how fibre composition is written in German, what retailers expect on care and sizing, and the compliance actions on packaging and chemicals. It ends with a pre-shipment checklist you can hand straight to the merchandiser and the inspector.

1. Keep the Three Layers Apart: EU Regulation, TKG and Buyer Standards

The EU regulation sets the frame, the TKG sets the German names and enforcement detail, and buyer standards — an own RSL, OEKO-TEX, GS — set the contractual threshold. They sit at different legal levels, and blending them in one specification is where trouble starts. Put statutory items in a mandatory column and buyer items in a contractual column: at inspection you then neither explain law with a buyer standard nor use the law to refuse an extra requirement.

A common misjudgement: the buyer says EU standard is enough, yet the shipment is still rejected by the German retailer because fibre names were printed in English. The regulation requires the official language of the member state, and German is not optional here.

2. Fibre Composition: German Names and How to Write Percentages

Composition is stated by weight percentage: a single fibre reads 100 % Baumwolle, and blends are listed in descending order. Fibre names must come from the German statutory list in the annex to the TKG — not English, not a transliteration of the Chinese. Components under 5 % can often be grouped as sonstige Fasern (other fibres), but elastane and decorative fibres follow separate rules, so do not merge everything for convenience.

Chinese English German statutory name
Cotton Cotton Baumwolle
Polyester Polyester Polyester
Elastane Elastane Elasthan
Viscose Viscose Viskose
Polyamide Polyamide Polyamid
Wool Wool Wolle
Linen Linen Leinen
Acrylic Acrylic Acryl

The trim's own material does not belong in the garment composition. That a woven label is polyester and a care label is nylon is trim specification, not garment content; the composition printed on the care label always follows the garment. Mixing the two is the most common basic error at document review, and the most expensive to rework.

3. Care Labelling and Sizing: Not Mandatory by Law, Always Checked by Retail

Germany has no mandatory care labelling statute; the symbol system follows ISO 3758, adopted in Europe as EN ISO 3758. But large retailers, platforms and brand buying contracts routinely require all five basic symbols, and once shown they must be accurate — a wrong care instruction can amount to misleading advertising under German competition law. Sizes follow DE 32–54 or the EU system, childrenswear is marked by body height in centimetres, and Chinese adult sizes must not be carried over directly.

💡 German buyers read care labelling as a quality signal: missing symbols are not taken as the law being silent, but as the supplier being unprofessional. This decides more orders than the statute itself.

4. Packaging: Making VerpackG and LUCID Registration Work

Anyone placing packaged goods on the German market is the first distributor of that packaging and must register in LUCID at ZSVR, contract a system participant and report by material and weight. Poly bags, cartons, tape and mailers all count; a hang tag is normally a product component, but if tags ship in their own bag, that bag is packaging.

When a customer asks a Chinese supplier for packaging data, do not answer verbally. List grams per unit split by paper, plastic and metal, state whether the figure was weighed or calculated, and hold the error within plus or minus 5 %. Those numbers decide what the customer pays in packaging fees, and a wrong figure is chased back through every report.

5. Chemicals and Certification: GS, OEKO-TEX and the GPSR Responsible Person

GS is a voluntary safety mark that German buyers often require for infant, next-to-skin and functional categories, and OEKO-TEX STANDARD 100 is close to an entry ticket. On chemicals, the German Chemicals Prohibition Ordinance restricts certain azo dyes and heavy metals, while REACH SVHC and the General Product Safety Regulation apply at the same time.

The GPSR requires the manufacturer's and the EU responsible person's name, address and contact details on the product or its packaging. For trims, the back of the hang tag is the natural carrier: a small block of white space solves it. By the time a customer asks for it as an afterthought, the press is usually already running.

6. Eight Checks Before Shipment

  • Percentages add up to 100, run in descending order, and carry no gap left by rounding.
  • Every fibre name is the German statutory term; no English, no bilingual mixture.
  • Care symbols match what the garment actually tolerates: wash temperature, bleaching, tumble drying, ironing.
  • Sizes follow DE or EU, childrenswear carries body height in centimetres, and adult sizes are not copied from Chinese charts.
  • Manufacturer and EU responsible person are complete with name, address and contact, at a size that reads on the actual item.
  • Packaging material and per-unit weight data are ready and can be entered into the customer's LUCID reporting template.
  • Test reports cover fibre composition, formaldehyde, banned azo dyes and heavy metals, with nickel release added for metal parts.
  • Change records are clear: if yarn, paper, coating or an upstream supplier changed, retest rather than lean on the previous lot's report.

Related reading

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