New EU regulations not good for SA apparel exports

For most of us the decision to buy an item of clothing is based on style, fit and price and then maybe, just maybe, some thought about ethical fashion will be an ingredient of our purchasing decision. How often have we thought about the chemicals that are present in our clothing?

The EU has enacted regulations that require clothing manufacturers and importers to "identify and quantify" the chemicals used in their products. All apparel companies had until 1 December 2008 to complete the EU pre-registration process.

Are South African manufacturers exporting to the EU prepared to comply with the EU regulations? Apparel exports to the EU from South Africa in 2003 were nearly US$70 million in 2006, total textile exports were in the region R3.1 billion while global apparel exports amounted to US$95.6m in 2007. Apparel exporters who fall under AGOA including South Africa will have to comply with these regulations. In 2003 total apparel exports to the EU under AGOA was 34%.

According to the regulations all clothing manufacturers will have to comply with the EU's Chemical Control System REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). The onus falls on both manufacturers and importers to check if the chemicals used in the production of a particular item of clothing has been registered with REACH and if it has not they have to register the chemicals.

The regulations go further. Under Article 33 of REACH if a "substance of potential concern makes up 0.1% or more by weight of an article, the importer, manufacturer and retailer need to provide the recipient [the consumer] with sufficient information including the name of the substance." In other words consumers have the right to be informed through labelling information about "potentially hazardous chemicals" used to make the apparel they purchase.

This complex set of regulations will be rolled-out over the next few years; however the deadline for chemicals deemed to be "carcinogenic, mutagenic or toxic to reproduction, as well as substances produced or imported by an applicant in volumes exceeding 1,000 tonnes a year" is 1 December 2010, with registration preparation falling on 1 December 2008.

How does this affect the South African fashion sector? Any designer designing and have clothing manufactured in South Africa that is destined for export to the EU will need to comply with these regulations. In other words, the onus will fall on both the individual designer and the manufacturer to comply with the EU regulations before export can take place. The extra research and administrative cost to meet EU regulations could result in manufacturing cost for local designs exported to the EU increasing. This places a burden on local independent designers and could result in a sharp (maybe temporary) decline in South African designed content being exported to the European Union.

Has the Department of Trade Industry informed the apparel and fashion sector about these regulations and what are they doing to assist the industry to comply with such regulations? Do fashion events companies that say their mission is "to take African fashion to the world" know about these rules and what are they doing about informing and assisting South African designers who are the creators of African fashion to meet these stringent regulations?