1. Study on Fashion Recalls in the European Union (2018-present)

1.1 Surveillance of fashion articles in the European Union

In the European Union, the Member States control and monitor the consumer products available within the market in order to prevent the marketing of dangerous products that may pose risks to the health and safety of consumers. The Rapid Exchange of Information System for non-food consumer products, better known as RAPEX at EU level, aims at the rapid exchange of information between national and EU market surveillance authorities on the presence of a product that may create a risk (https://ec.europa.eu/safety-gate-alerts/screen/webReport).

Among all the sectors, fashion items (including clothing, footwear, accessories and jewelry) represent one of the categories with the highest number of alerts. This report makes an analysis of the alerts within this sector from 2018 to March 2022.

In this period, more than 1000 alerts were notified, with an annual average of 210. From these, 58% were related to clothing and 32% to jewelry, while footwear and accessories only represented the remaining 10% of the alerts (Figure 1). The numbers per year in the sector do not vary particularly, although 2018 and 2021 share a higher number of alerts.

 

Figure 1. Distribution of alerts by product category (2018-present) and percentage by year

 

By analyzing the distribution of recalls by country, the ones which found the most problems were Cyprus and Germany (15% each), Bulgaria (11%), France (9%) and Sweden (7%) (Figure 2). Some of these countries have focused only on the control of a particular category, as is the case in Cyprus with clothing items (mainly of kids’ clothes), while others have made regular alerts in all studied categories (clothing, accessories, footwear and jewelry).

 

Figure 2. Countries with the most product alerts within the fashion sector

 

1.2 Surveillance of clothing articles from 2018 to 2022

Firstly, more than 600 alerts were reported in the clothing category, which is by far the one with the highest percentage of non-compliance within the fashion sector. Of this total, 86% were due to safety related risks and the remaining 14% due to the presence of chemical compounds hazardous to health or the environment.

Within the product alerts due to safety, most of them were related to baby or children’s articles, and were mainly caused by injuries, strangulation or choking risks. These alerts were mostly related to product features such as the presence of unsuitable cords and drawstrings (73%) and small pieces or components (26%). The remaining reported problems were due to other characteristics such as the flammability of the fabric or the presence of sharp and stabbing elements.

 

Figure 3. Distribution of clothing alerts by security risk

 

With regards to the health and environment risks, due to the presence of harmful chemicals, the most noteworthy are the alerts caused by the presence of chromium (VI) 65% of the product alerts related to chemical risk. The remaining ones were due to the presence of phthalates, azodyes and arylamines, and nickel.

 

Figure 4. Distribution of clothing alerts by chemical substance

 

1.3 Surveillance of accessories from 2018 to 2022

For accessories (belts, bags, etc.), 95% of the alerts were caused by the presence of harmful chemicals. The main substances present in the products were phthalates (specially dibutyl phthalate (DBP)) and chromium (VI); other substances that also appeared with some frequency were nickel, lead and cadmium (Figure 5).

 

Figure 5. Distribution of accessories’ alerts by chemicals

 

1.4 Surveillance of footwear from 2018 to 2022

In footwear, the alerts were also mainly related to the presence of regulated chemical substances (around 76%), with the remaining ones being due to components such as small parts. The most detected substance for this category was chromium (VI) (related to leather parts), whose presence caused 67% of the recalls, followed by phthalates, SCCPs, lead, azodyes and arylamines, and PAHs.

Figure 6. Distribution of footwear alerts by chemicals

 

1.5 Surveillance of jewelry products from 2018 to 2022

Finally, jewelry was the second most problematic category of fashion items in the period under review, with 337 alerts reported. In all the cases, these are alerts were caused by the presence of excessive levels of regulated chemical substances (Figure 7), with heavy metals standing out as the most detected ones: cadmium (54%), lead (17%) and nickel (29%).

 

Figure 7. Distribution of jewelry alerts by chemicals

 

1.6 Conclusions

Several general conclusions can be drawn from the above information, which may be of value to companies that intend to place fashion products on the European market.:

  • Firstly, within the clothing category, there is a clear tendency of non-compliances related to safety risks in baby or children’s articles, especially due to the presence of small elements attached to the garment or inadequate strings or cords, which may pose a great danger as they may cause choking or other injuries. This type of problems could be prevented at the design stage, through the implementation of restrictions in line with the current security regulations in the market.
  • The risks associated to the presence of regulated chemical substances, by their harmful effects to the health or the environment, are still present in every category of the fashion sector analyzed in this study (clothing, accessories, footwear and jewelry). Among the regulated substances leading to alerts, it is necessary to highlight that ones related to Cr(VI) (associated with leather parts), plasticizers (such as phthalates), azo dyes and arylamines, and heavy metals. Jewelry is the category with the highest risk in this area, due to the possible presence of harmful or sensitizing heavy metals. Therefore, it is important to pay more attention to the security of this type of items, which in many cases are not at the heart of a fashion company’s business but can represent a significant risk.
  • Brands and manufacturers should increase the control of the manufacturing chain and be constantly informed about the current regulations with respect to product health and safety, to minimize the possibilities of commercializing products which may carry a risk to the end consumer, and which therefore may be susceptible to recalls. In addition to the economic losses for the company and the impact that a recall has on sustainability, due to the loss of resources, product recalls can also have important reputation impacts on fashion brands/retailers.

Sigillum Knowledge Solutions is an international consultancy service provider focused on Health, Safety and Sustainability of consumer products. From design to end of life cycle we cover the full production process in order to ensure that any consumer good meets all legal requirements before it is placed on the market. The aim of Sigillum KS is create strategical partnerships with our clients, offering tailor made services to cover their specific needs in terms of regulatory monitoring and compliance, labelling or development of Product Health and Safety standards.