Categorizing textile products for setting ecodesign requirements

There are already a large number of different categorisations approaches for textile products that serve a variety of applications. These systems differ not only in their intended use, but also in their target group. The applications range from the definition of a uniform standard for the industry in general to the specification of a baseline for certification processes. 

In order to either identify a suitable system or develop a new one, various existing national (German) and international textile product categorisation systems were analysed. Based on five evaluation criteria, it became clear that some of these systems have similarities, but that each categorisation system represents a unique method of categorising textile products. Furthermore, it was assessed which aspects (e.g. raw material or end product) should be included in the definition of a product classification system.

In summary, the harmonised system (HS) of the World Customs Organisation was identified as a suitable basis for a categorisation system. The decisive advantage is the internationally standardised and globally valid product nomenclature, which is applied to all goods that are traded across borders. In addition, individual elements of other systems are proposed that can be easily integrated to further enhance the system geared towards sustainability.

The production volume of textile fibres has roughly tripled since 1975. The biggest increase can be seen in the synthetic fibre polyester (Textile Exchange 2023). The Ellen MacArthur Foundation found that more than half of the “fast fashion products” are disposed of in less than a year. Globally, the use phase of clothing - i.e. the average number of times a garment is worn before it is no longer used - has fallen by 36 % compared to 15 years ago (Ellen McArthur Foundation 2017). The environmental impact of the production and disposal of textiles associated with increased consumption has a significant impact on people and the environment worldwide. Political efforts are therefore being made to significantly minimise these effects. At European level, the EU strategy for sustainable and circular textiles has been adopted. This strategy consists of several key actions, one of which is the Ecodesign for Sustainable Products Regulation. This framework is used to define ecodesign requirements for textile products(European Commission 2022a, 2020b).

“Ecodesign is a systematic and comprehensive design approach for products in order to minimise environmental impacts over the entire life cycle through improved product design.”(German Environment Agency 2020) Categorisation is necessary to define requirements that take into account ecodesign aspects for textile products, as the variety of textile product groups is almost infinite. This article compares several existing categorisation systems and evaluates their suitability for a system for setting ecodesign requirements for the resulting product groups as opposed to each individual textile product.

1.1 Background 

The term textiles covers a wide range of different products that are categorised into different groups according to various criteria. The term refers to textile fibres, semi-finished und finished textile products as well as finished goods made from them (DIN 60000). For example, technical textiles (such as geotextiles, automotive textiles or bandages), clothing and home textiles can be categorised according to their intended use. Numerous sub-categories can be formed within these groups. In the case of clothing, a distinction can be made between workwear and everyday clothing. Clothing for various purposes is summarised under everyday clothing: sportswear (climbing, skiing, cycling, hiking, etc.), business fashion, everyday fashion, babies and children's clothing or clothing for weather protection. Last but not least, various products such as trousers, jackets, socks, jumpers etc. can be summarised in these exemplary categories. These products in turn can be made from different materials (cotton, wool, polyester, polyamide, regenerated fibres, etc.). In order to develop a suitable categorisation system that is specifically suited to the definition of ecodesign requirements, the system must reflect the different properties of the various textiles described above.

Depending on the material, the specific product, such as a T-shirt, differs in terms of its properties (wearability, functionality and durability), its potential environmental impact and also in terms of possible optimisation approaches with regard to the reduction of environmental impact, resource consumption and possibilities for implementing circular economy approaches. 

1.2 Structure of the study

The study is structured as follows: Firstly, the background and objectives of this study are outlined. The methodological approach is then presented and a comparative analysis is carried out on the basis of defined criteria. The results are interpreted and a suitable categorisation system and its limitations are presented.

Similar to energy-related appliances, which were the first products to be regulated at European level in terms of ecodesign, a categorisation of products is also necessary for textiles in order to be able to develop category-specific ecodesign requirements for textiles (European Commission 2022a). The overarching aim of this study is therefore to define the criteria for a categorisation system and to identify a suitable and universal categorisation system for this product group. First and foremost, the system must be able to categorise the wide variety of textile products. Secondly, it must enable all relevant eco-design requirements to be considered.

Since there are already several approaches to categorise textile products for different purposes, these existing systems need to be analysed to assess their suitability for this specific application. This shows that the product aspects such as durability, recyclability, reparability, etc. of the ecodesign approach must be considered to assess whether a system is suitable or not. Not only the fibres used and the specific product aspects are considered in order to generate product categories with similar requirements for the products, but also the potential use or recycling options for the respective product category are included.

Furthermore, the following aspects were used as a basis for the development of a categorisation of textiles, with the aim of defining ecodesign requirements for these resulting groupings or categories: 

• The selection and development of a categorisations system should both take into account existing systems and aim for a practical solution, as the proposal for the Ecodesign Regulation stipulates that the implementation of ecodesign requirements should not impose disproportionate administrative burdens on manufacturers and other economic operators in the production processes (European Commission 2022a).
• The broadest possible inclusion of differentiated clothing products that are part of the planned Ecodesign for Sustainable Products Regulation (i.e. textile products for which no criteria are initially planned, such as accessories, are excluded from the systematisation) is sought in order to cover the planned regulated products.
• The categorisation principle should reflect the most common product presentations on the market (especially on the basis of material compositions) in order to be able to define standards per category on the basis of average values in future and to minimise the risk of getting lost in details.
• Consideration should be given to integrating this system into the retail sector in the future by basing the newly defined system on existing and binding standards and practices.

In summary, the objective of this study is to analyse the existing categorisation systems as well as the advantages and disadvantages of these different categorisation systems in order to identify the most suitable categorisation system that can be used as the basis for the Ecodesign for Sustainable Products Regulation. The analysis is conducted using three different methodological approaches: In a first step, a desktop-research was performed to gather relevant existing categorisation systems. For this desktop research of existing categorisation systems, a systematic research was carried out using relevant databases. As the categorisation systems are mainly used by companies, certifiers or governmental institutions, not all systems could be identified in this way. Therefore, in a second step, the findings were presented to and discussed with various experts from industry, associations, and research institutes with expertise in this field to validate the systems as well as identify further existing categorisation systems.

The extracted national (German) and international (not German specific) categorisation systems are then analysed with the help of a comparative analysis by using previously defined evaluation criteria. 

Based on the desktop research and expert interviews the following eleven categorisation systems could be identified. Two of the are national categorisation systems (in Germany); nine of them are international categorisation systems. In the following an overview about the origin of the categorisation system, a short description of the grouping and application, the recipient and addressee as well as the source is given. 

a) National categorisation systems

1.  Trade Association of Textile, Shoes and Leathergoods (Handelsverband Textil Schuhe Lederwaren 2013)

• Product group key
• Uniform standard for the clothing industry, comparability of data between individual companies and levels is to be ensured.
• Recipient/ Addressee: Apparel industry

2. Dialog Textil-Bekleidung (DTB) (Dialog Textil-Bekleidung e. V. o. J.)

• Product group key
• Uniform standard for the clothing industry, comparability of data between individual companies and levels is to be ensured.
• Recipient/ Addressee: Apparel industry

b) International categorisation systems

1. SAP product groups (SAP SE n. d.)

• Textile compositions according to EU Regulation (EU) No. 1007/2011 (designation of textile fibres and labelling/marking)
• Recipient/ Addressee: Companies of all sectors

2. Nice-classification (World Intellectual Property Organization 2023

• 12th edition, version 2023
• International classification of goods and services for the registration of trademarks; Class 25
• Recipient/ Addressee: Companies of all sectors

3. GS1 identification numbers (GS1 identification numbers)

• Extended fashion data model GS1 (Germany)
• Recipient/ Addressee: GS1 identification numbers

4. Harmonised System (HS) of the World Customs Organisation (World Customs Organization 2022)  

• Textiles and textile articles 50−63, 59−63 Apparels
• Recipient/ Addressee: Harmonised System (HS) of the World Customs Organisation

5. Textile Ex-change (Textile Exchange 2021)

• Material, process and product classifications for certification pro-cesses/ Provide systematic reporting framework for raw materials etc./ Provide guidance on selection and pairing the aspects
• Recipient/ Addressee: Certified bodies (for use in certification process); Secondary users: suppliers, manufacturers, brands/retailers, other stakeholders having an interest in GOTS and Textile Exchange standard

6. Eco Mark Program der Japan Environment Association (Environmental Association Eco Mark 2022)

• Certification criteria for the Ecolabel, product category no. 103 Clothing
• Recipient/ Addressee: Apparel industry

7. Ecomodulation France (Ministère de la transition écologique et de la cohésion des territoires 2022)

• Eco-organisation for individual systems in the sector as part of the extended producer responsibility for textiles, shoes and household linen
• Recipient/ Addressee: Producers

8. EU Ecolabel (European Union 2014)

• Environmental criteria for the award of the EU Ecolabel for textile products
• Recipient/ Addressee: Companies of all sectors

9. JRC product categories (Delre et al. 2024)

• Makes use of the PRODCOM codes; categories were defined according to "covering/warming upper body", "garments to put on top", "garments to cover lower body", "one-piece to cover upper and lower body" and "garments to cover legs and/or feet"
• Recipient/ Addressee: Apparel industry (in order to set ecodesign requirements for these categories)

These categorisation systems were analysed on the basis of five evaluation criteria that are listed below. These aspects are derived on the aspects from Table 1 below. 

I. Categorisation architecture

What is the typification and structure of the categorisation system of textile (clothing) products as well as the scope and limits? (e.g., gender differentiation and product sub-groupings). 

II. Orientation and basis

What purpose does the existing categorisation system serve and which system is used as a basis, if applicable? (e.g., inclusion of coding numbers or barcodes of goods).

III. Depth of categorisation

How specifically are the (clothing) products defined at item level (e.g., specific surface structure, material composition, mixing ratios)?

IV. Coverage of product functions

Does the typification consider the function of a particular product?

V. Unambiguous allocation of products

Can products be listed more than once and therefore not clearly be categorised?

For the analysis it is important to determine the required specification. Therefore, the intended application must also be considered. For this purpose and for the definition of the five analysis criteria, technical textile aspects based on product criteria are included. The following table 1 shows how the exemplary used product aspects of durability, reparability and recyclability are related to the product structure, which includes, for example, the choice of fibre and surface, but also additional characteristics relevant to the respective product aspects. In addition to the product structure, the use phase and, in some cases, the technological implementation of processes were also examined in order to determine parameters. A categorization system must be able to include these parameters or classify the products in such a way that the respective differences can be considered when defining practical requirements.

Considering these potential requirement characteristics which, from a textile technology perspective, must inevitably be considered in the product requirements definition as they have an influence on the respective aspects, five analysis criteria could be derived according to which the existing categorisation systems are examined. This approach makes it possible to analyse whether existing systems already form a possible basis for the definition of product requirements. 

Chapter 3 lists the categorisation systems and distinguishes between national (German) and international validity. Article categories within the scope of quality labels were also initially included in the analysis. Approximately 20 labels are currently recognised by the German government's “Green Button” label for sustainable textiles(Deutsche Gesellschaft für Internationale Zusammenarbeit GmbH 2023). These 20 labels were evaluated. It was found that the labels do not define sufficiently specific categories. Rather, 3-8 (sub-)categories are listed within the scope of the labels (e.g., bluesign, fairtrade, Oeko-tex). These sub-categories are not standardised and only cover a small proportion of the textile and clothing articles available on the market. Against this background, these labels were not included in the analysis. 

4.1 National (German) categorisation systems 

The existing national categorisation systems differ in their respective structures. The analysis revealed that both the main product groups as well as the product groups and sub-groups are defined differently. Table 2 below shows a comparison of the similarities and differences. The relevant evaluation criteria in chapter 3 were used to structure the analysis. 

From the analysis of the differentiated product group codes, conclusions can be drawn for the creation of a system of product groups for ecodesign requirements. This concerns, among other things, the subdivision into men's, women's, and children's categories as well as the categorisation of products into knitwear and warp-knitted fabrics. The specific products listed within the product groups (BTE) and sub-groups (DTB) can be used for the categorisation within the new system to be defined. It should be emphasised that both product group codes do not constantly distinguish between differentiated materials within the product groupings. This aspect should be included where appropriate against the background of ecodesign requirements and a corresponding need for the definition of area-specific testing parameters. The inclusion of functional clothing products is not to be categorised as schematic; such products are only explicitly included in some cases. Due to the finishes and surface structures, functional products place individual requirements on criteria such as durability and recyclability (German Environment Agency 2022). With regard to ecodesign parameters, corresponding products should therefore be specifically included within a system. 

4.2 International categorisation systems 

Five internationally used systems are analysed according to the five evaluation criteria. To provide a suitable overview, only specific characteristics of the respective criteria are summarised and listed as examples. To this end, the focus is particularly on similarities between different product groupings and unique selling points that have characteristics with regard to ecodesign requirements, which can form the basis for the development of the product system. Following the presentation of the cumulative analysis results based on the existing international product groupings, it is also explained which systems were not included in the further analysis after an initial assessment and on the basis of which core aspects. 

I. Categorisation architecture

According to GS1 Germany GmbH it is common to differentiate goods offered by model or article. Within the articles, this is subdivided according to colours and sizes, as well as other characteristics. It should be noted that it is common practice, especially in smaller retail companies, to categorise the product range according to the standard product group codes of the relevant associations. To make it easier for these companies to categorise the articles, the master data of the BTE and DTB product group codes are therefore used within the product grouping for textile and clothing products, among others. In addition to gender, age groups are divided into four categories - adults, teens, infants and babies(GS1 Germany GmbH 2019). Within the Textile Exchange product classifications, a distinction is made between men, women, infants, babies, and unisex products with regard to clothing. As a special characteristic of this categorisation, a further distinction is made between the respective denim products(Textile Exchange 2021). The French ecomodulation system has formed a product categorisation to define specific product parameters, which does not differentiate fundamentally between genders. Clothing-specific main product groups correspond here: Street trousers and shorts, trousers/skirts/ dress made of denim, dress and skirt made of woven fabric, dress and skirt made of knitted fabric, shirt and blouse, T-shirt/polo shirt/shirt/blouse made of knitted fabric, pullover, nightwear, lingerie, swimming costume. These main groups are underlaid with product examples, but are not further differentiated(Ministère de la transition écologique et de la cohésion des territoires 2022). The system of nomenclature for textile clothing products within the Harmonised system of the World Customs Organisation is based on Chapter XI. In sections 61 and 62 (first two digits of the nomenclature), the respective positions of the product categories are listed (further two digits). This includes the distinction between men and boys, women and girls, and babies. The different product types are summarised under this heading so that, for example, suits, jackets and trousers fall under one heading(World Intellectual Property Organization 2023). The JRC product categories represent ten different product categories that have no further specific subdivisions. A supplementary description of the respective category indicates that these categories were defined according to "covering/warming upper body", "garments to put on top", "garments to cover lower body", "one-piece to cover upper and lower body" and "garments to cover legs and/or feet". No distinction is made between age and gender or other specifications within the categories (Delre et al. 2024).

II. Orientation and basis

GS1 is responsible for the overlap-free article numbering system worldwide. The GS1 identification numbers as "Global Trade Item Number" thus form the basis of the barcodes as a unique identification of trade units for over 20 industries(GS1 Germany GmbH 2019). Textile Exchange checks the completeness of its product classification using the harmonised system for the designation and coding of goods (customs classification). Coverage is focussed on the textile-specific classes 50-63(Textile Exchange 2021). The JRC product categories were developed exclusively for the development of textile ecodesign requirements as part of the preparatory study on textiles for product policy instruments carried out by the JRC. A supplementary list of the PRODCOM codes of the products that fall within the scope of the preparatory study is linked in this context. In addition, the identified product categories are aligned with the ongoing work of the PEFCR A&F. The extent to which the linking of the PRODCOM codes will be maintained and included in the course of the development of requirements and a prospective practical implementation is not yet described at this time (Delre et al. 2024).

III. Depth of categorisation

Within the code list, GS1 separates between 19 main colours and colour gradations. In addition, industry-specific standard designations for clothing sizes are included. These standards vary from country to country, so that a country code is added within the system for specification purposes. Additional measurements (e.g., skirt length, waist size, sleeve length or collar width) can also be specified. Furthermore, the clothing items are categorised according to the respective cuts (e.g., wide, normal/comfort, tight/slim, super slim). Based on EU Regulation 1007/2011 on textile labelling, 49 fibre designations are added. For products with different material layers (e.g. upper and lower materials), an additional indication is determined. The occasion for which the corresponding products are designed is also included; for example, a distinction is made between maternity wear and festive wear. This information is predominantly based on individual labelling and is not based on a predefined basic structure. The area structure is differentiated into around 68 layouts(GS1 Germany GmbH 2019). Textile Exchange additionally specifies the products within the listed product groups on the basis of product details. This summarises corresponding details that can be classified as comparable. Examples include the categories "Suits, suit trousers" and "Jumpers, pullovers, cardigans". In addition, material compositions can be specified for product presentation. These are not based on existing product categories, but can be named individually(Textile Exchange 2021). Within the Harmonised system of the World Customs Organisation, a fundamental distinction is made between the surface construction of the product. Section 61 accordingly includes "Articles of apparel and clothing accessories, knitted or crocheted". Section 62 "Articles of apparel and clothing accessories, not knitted or crocheted". The subheadings are selected on the basis of material use. A distinction is made between cotton, synthetic fibres and other textile materials (World Intellectual Property Organization 2023). Within the JRC product categories no distinction is made between the product presentations (e.g. knitted, not-knitted). The use of materials is not included. The categorisation is exclusively based on the division into “T-shirts”, “shirts and blouses”, “sweaters and mid-layers”, “jackets and coats”, “pants and shorts”, “dresses, skirts and jumpsuits”, “leggings, stockings, tights and socks”, “underwear”, “swimwear”, “apparel textile accessories”. The surface structure and the use of materials are included in the PRODCOM codes, but not directly in the specific product categories of the system developed by the JRC (Delre et al. 2024).

IV. Coverage of product functions

Functional products are listed specifically within the Textile Exchange product classification under the product detail "activewear, sportswear" and are therefore presented individually. These products are not described in detail beyond this(Textile Exchange 2021). GS1 includes the water resistance of a material in the product system as part of the product attributes to be selected (GS1 Germany GmbH 2019). The Harmonised system of the World Customs Organisation and the other grouping systems do not differentiate between functional products. Accordingly, within the HS, for example, both functional jackets and fashion jackets fall under one heading (World Intellectual Property Organization 2023). The JRC product categories consider "sportswear" as a separate category. In addition, no product functions such as outdoor products are included separately and therefore also fall under the existing general product categories, similar to the harmonised system. It is also described that workwear is also included in the existing categories as long as they are defined as apparel textiles. A specific categorisation of these textiles is therefore not planned (Delre et al. 2024).

V. Occurrence of multiple allocation

Within the Textile Exchange product grouping, the "many-to-many" principle was applied to product categories and product details. Different combinations of classifications are therefore potentially possible and permissible. Instructions for pairing product categories and product details are provided, but any product details can be selected together with any product categories (Textile Exchange 2021). A systematic and clear allocation to specific product categories is not given. It must be checked in the further course whether this system should be included for the transfer of ecodesign criteria. The French ecomodulation specifies on the one hand knitwear and knitted fabrics in individual product groups. Woven goods, on the other hand, are not explicitly described (Ministère de la transition écologique et de la cohésion des territoires 11/23/2022). Based on the existing explanations and the assessment of the parameters set, which are to be ensured in the long term through textile testing, it cannot be concluded why no standardised specific subdivision is specified in this context. As a result, it is not possible, for example, to specifically allocate which criteria a dress or skirt made of woven fabric must fulfil, as (Cotton fabric in twill weave) product parameters are only set for skirts and dresses made of knitted or denim fabric within ecomodulation. Also, in view of the fact that dresses and skirts are predominantly made from knitwear in practice, there are also woven products that are not manufactured and sold as a denim weave. 

Explanation of the exclusion of categorisation systems:

As part of the analysis, it can be summarised that the Nice Classification for the registration of trade marks is not a suitable system for the systematic categorisation of clothing products. Although the differentiated textile products are listed in the list of goods by class, they are not comprehensively specified. This applies in particular to the subdivision into women's, men's and children's articles and the inclusion of the fabric construction (woven, knitted/knitted) (World Intellectual Property Organization 2023). The SAP product groups are based on the implementation of the EU Regulation on Textile Composition (EU) No. 1007/2011. For example, fibres for several textile components of an article (mixed fibre products) can be processed within the system. Specific fibre codes can be assigned to fibre components. It should be noted at this point that the author does not have full access to this fee-based system. It was not possible to evaluate whether an existing basic categorisation for textile products is already available to the user. For this reason, the SAP product groups were excluded from the analysis (SAP SE n. d.). The Eco Mark programme of the Japan Environment Association sets certification criteria for the national eco-label. Product categories that are differentiated for this purpose are divided into seven summarised classes, including Uniforms/Workwear/Hygiene Articles/Sportswear/Outerwear, Underwear and Nightwear and Japanese Clothing, Socks/Tights/ Socks, Hats/Gloves, Other Clothing. Beyond this, no further specification is made with regard to product classification, for example in relation to material use or product function (Environmental Association Eco Mark 2022). This product grouping is therefore not suitable for the systematic definition of clothing products. The product categorisation under the EU Ecolabel also does not represent a comprehensive product scheme compared to the analysed groupings. The focus of the environmental criteria to be applied is primarily on ecological aspects and different emissions of the individual fibre types. For this reason, criteria are mainly defined for individual fibre materials as components, without considering the overall construction of the textile product. Minimum criteria for fitness for use are specified for semi-finished woven and knitted products and for the finished product. For this purpose, the textile products and material types are classified into categories based on the surface construction, mostly without specific product categories, for example for tolerances on dimensions during washing and drying. For criteria such as colour fastness to differentiated aspects, uniform values are prescribed for all applicable product types in order to comply with the minimum standards of the EU Ecolabel. For the pilling resistance criterion, for example, a distinction is made between "knitted and non-woven materials" and "woven fabrics" (European Union 2014). The underlying system of the EU Ecolabel is not a complete product classification system and does not include the specific aspects of differentiated textile products in the definition of ecological criteria. 

The summarised result can be found in table 3

4.3 Interpretation of the analysis results and findings

The following categorisation system for ecodesign specifications refers exclusively to clothing products until further notice. Chapter 5.3 explicitly specifies the products excluded from the system of the categorisation system in this context.

The specification factors derived from the analysis results are explained and an evaluation is made of which of these aspects should be included in the systematic definition of an (ecologically orientated) product classification system. To summarise, specific reference is first made to the EU Ecolabel, which can be used on a voluntary basis to certify raw materials or individual products. Against the background of the mandatory ecodesign criteria based on the Ecodesign Regulation, parameters are to be defined for finished end products in return. The reason for this is that most of the underlying criteria, such as reparability and recyclability, must be applied to the end product. A textile unfinished surface construction can only provide limited information about the corresponding product potential, which is why it is necessary to define a classification system for textile end products as a basis for these parameters. Colour, size, and cut-based gradations such as those within the GS1 product grouping are an exception within the analysed categories. It must be continuously analysed whether this differentiation should also be included in the context of ecodesign requirements. The distinction between the intended use of the clothing and the age group are factors that must be considered in the course of the previous considerations. In the context of the practical example of French ecomodulation, it can be concluded at this point that it should be possible to assign every potential product available on the market to a defined class, including the distinction between knitted and woven fabrics, as part of a systematic product categorisation. If this is not the case, it can be assumed that mandatory ecodesign parameters cannot be reliably implemented in the future due to insufficiently systematic product structuring. 

In addition, primary system requirements were derived from the analysis, which are defined as follows.

• Within a system, there is no need to differentiate between men's and women's articles. It cannot be fundamentally assumed that products have different technical textile aspects due to gender assignment. Furthermore, it is not possible to make a generalised assessment of the use of materials on this basis. Studies have shown that clothing products exhibit average differences between men's and women's articles within the use phase, with a  comparatively longer utilisation phase of men's articles and the associated poorer collection quality after disposal (Jarmer and Brieger 2020, 2021). However, no use is made of the direct integration of the gender-based division within the elementary categorisation system.
• In contrast, children's and baby clothing products are allocated to a separate category. The corresponding articles have different material and presentation aspects compared to men's and women's articles. This relates in particular to the surface presentation and the use of materials. Similar to the differentiated usage phase of men's products explained above, different usage patterns can also be fundamentally assumed for infant and baby clothing. In particular, the factor of increased average washing cycles within a product life cycle compared to adult clothing must be included in the further development in the form of product output qualities to be defined elsewhere. In addition, stricter requirements are needed with regard to the use of chemicals.
• A distinction should be made between the surface finishes knitted/crocheted and woven. Against the background of the ecodesign requirements to be established, in particular for the product aspect of durability, it can be assumed that these parameters will be determined on the basis of physical textile tests. For the majority of these textile tests, a distinction must be made regarding the surface presentation. Fleece is provisionally excluded due to its relatively low use in clothing production. Fleece, on the other hand, is a knitted fabric and is mainly used in functional clothing. This surface finish can therefore be gradually and specifically included in the outdoor category, for example.
• Outdoor and sportswear are grouped together as they have related product design factors in terms of material use and surface production. Both types of clothing allow conclusions to be drawn about common types of use, particularly with regard to textile finishes due to the common applications. On the contrary, swimwear garments have a different use of materials and surface structure compared to other clothing products, hence they are excluded from the outdoor and sportswear product group. Based on this, there is a need to successively list these products within a separate product category.

Products that can be defined as functional products should therefore be grouped in separate or specific groups, as these kinds of products have to fulfil more particular requirements in relation to certain product aspects in the context of ecodesign. Leather, fur, and feather products (including such product inserts) are generally excluded from the categories summarized below due to the different requirements for these materials compared to textile synthetic or natural fibres. Corresponding criteria should be developed independently of other product categories and typified in separate categories.

Based on the analysis of the internationally applied systems, the harmonised system of the World Customs Organisation is considered to be the most suitable and comprehensive system. The Combined Nomenclature (CN) is the EU's eight-digit coding system consisting of the Harmonised System (HS) codes and other EU subdivisions. It is an internationally standardised and valid product nomenclature in accordance with Convention No. L 198 of July 1987 and provides a comparatively comprehensive coverage of all product types potentially available on the market within the differentiated product groupings. All goods that can be traded across borders are listed in the customs tariff schedule according to a legal and logical structure. Each product is assigned a specific number, the so-called code number. In standardised customs clearance, these numbers are used to classify goods in the customs tariff. The system is used by more than 200 countries and economies as a basis for customs tariffs and for the collection of international trade statistics. Accordingly, over 98 % of goods in international trade are classified according to the HS. Each individual code number contains duty rates and the scale for the resulting duty amount. When the HS code is referred to in the following, the first four digits of the numerical sequence are meant, which designate the HS chapter and the HS heading (World Customs Organization n.d.).

The analysis results of the national product group codes are used to further develop the categorization system, in particular due to the comparatively comprehensive product descriptions. In preparation for this, the product groups and product codes were linked to the HS customs nomenclature as specific products. This serves to identify sample products that go beyond the existing information in the HS system. This makes it possible to break down the prospective definition of parameters to products that belong in the respective customs classification but are not currently explicitly listed in the system. Downstream, individual articles have been defined differently against the background of the new scheme. These include, for example, windcheaters and ski outerwear, which have been removed from the category "Coats (including short coats), capes, anoraks, windcheaters, ski jackets, blousons and similar articles" (6201, 6202)”. As part of the new categorisation system presented below, these products are grouped under the heading "functional clothing".

The JRC's system proposal was developed as part of the preparatory study on textiles for product policy instruments. It is intended to serve as a basis for the development of textile product requirements and therefore serves in part as a benchmark for this analysis. It was necessary to check whether all the necessary criteria identified were included and whether optimisation potential could be identified. In particular, the indirect linking of the PRODCOM codes was analysed. Although the PRODCOM codes have a complete reference to the CN codes, i.e. they can be translated, in cases where the PRODCOM codes are more detailed than the CN codes, the use of HS codes instead of the PRODCOM headings in an optimised system is preferred at this point, as the HS codes (especially the product-related first four digits), unlike the PRODCOM codes, are included in the processes of economic operators in the context of export and import activities to determine the tariff classification for uniform customs clearance. The advantage of the HS codes is the consideration of the existing working methods of economic operators without creating a disproportionate administrative burden. The customs tariff numbers must be transmitted as part of the customs declaration before crossing the border. In the following chapters 5.1 and 5.2, the advantages of a direct link between a corresponding product system and the HS numbers are also specifically addressed in this context. 

Higher-level categories for clothing are proposed based on the area of application of clothing. This overarching categorisation step makes it possible to map common features of a wide range of products such as trousers, T-shirts and jumpers based on the requirements and usage profile and thus to check whether the ecodesign requirements developed for specific product examples are transferable and which products can be grouped together in a category for ecodesign requirements. The most important aspects identified from the other systems analysed will also be incorporated at this point.

Superordinate application categories of clothing based on their area of application are proposed as follows:

• Fashion (non-functional) clothing
• Functional clothing
• Underwear
• Fashion/Functional clothing and underwear for babies/children’s

The application category of fashion clothing includes clothing/apparel products that are worn as everyday clothing and for special occasions, but have not undergone any additional finishing or functionalisation. A differentiation between men's and women's clothing is not recommended. 

The application categories of functional clothing include clothing products that are finished and therefore have an additional function. Due to their specific function, durability requirements cannot be equated with defined apparel articles. The chemical finish also influences the recyclability, for example, which is why general requirements in a common product group with fashion/apparel products cannot include these specific product features. For these reasons, product requirements must be defined specifically for this type of product. In particular, tracksuits and outdoor clothing and/or clothing in the sports sector are assigned to this category. Swimwear garments are excluded. 

The underwear application category includes clothing products that are worn close to the body. For the most part, these products have different structures, fineness’s, functional areas and therefore cannot be included in the other categories. In addition, specific requirements should also be set with regard to increased washing cycles. Products that are made of fine knit are therefore excluded: tights, stockings and other hosiery as well as lingerie. Products with a correspondingly different surface structure behave differently in terms of durability, recycling and repair requirements and must be considered separately in order to be able to set appropriate requirements. It is proposed not to include this type of product in the reference framework of textile products for the time being, or to create a further specific class for it in the future.

Babies and children's clothing should also be subject to different durability requirements, as they are exposed to greater stress, particularly during washing. In addition, requirements for chemicals are specifically defined, e.g. stricter thresholds for chemical residues. In the HS nomenclature, baby articles are defined as "body height not exceeding 86 cm" (World Customs Organization 2022). For the addition of children, children's sizes could be drawn as a boundary to adult clothing. In addition, the categories of fashion clothing and underwear are combined for babies and children, as the quantitative ratio of differentiated underwear products for babies and toddlers differs from that of adult underwear. 

Outline of the product types within the categorisation system using product examples

In the course of the analysis, it is important to distinguish to which categories the clothing products belong.

Source: Sabrina Mauter / Hochschule Niederrhein

At the next level (subcategories), a distinction is made between knitted/crocheted and not knitted/crocheted (woven) on the basis of different manufacturing processes, as is also done in the HS system (These designations have been taken from the descriptions of the harmonised customs system and are intended to ensure recognisability): The chapter numbers (the first two digits) 61 of the HS nomenclature cover exclusively knitted and crocheted products and 62 products that are not knitted or crocheted but predominantly woven. The other two digits indicate the product category within the respective chapter of the customs system and thus distinguish, for example, between shirts for men or boys, knitted or crocheted (6105) and blouses, shirts and shirt-blouses for women and girls, knitted or crocheted (6106). 

The reason for this further differentiation is the fact that different parameters, for example for durability, have to be worked out for knitted/crocheted or woven goods due to their specific properties. For example, the dimensional stability of knitted or crocheted goods is different from that of woven goods. For woven fabrics, a change in dimensional stability is mainly the shrinkage of the fabric. For knitted or crocheted fabrics, however, non-reversible stretching can also occur. 

The JRC's product system differentiates between which part of the body the product covers. The background to this analysis is, in particular, that it makes it possible to create generally valid requirements, as the products have a similar product structure. Requirements for on top garments, for example, which are pulled over a t-shirt or sweater, i.e. for the most part various jackets, can therefore be evaluated in a standardized manner and are consciously differentiated from requirements for t-shirts (upper body) and pants (lower body), for example. Then, other parameters must be applied. The following subcategories are applicable to each of the superordinate application categories:

• Upper body knitted/crocheted
• Upper body not knitted/crocheted
• Lower body knitted/crocheted
• Lower body not knitted/crocheted
• On top garments knitted/crocheted
• On top garments not knitted/crocheted

5.1 Product categories system

The proposed system can be easily integrated into the HS system. It should be noted that the existing HS nomenclature (specification of chapter numbers and product category positions) is less differentiated. The HS code numbers cover a variety of products that do not all belong to the same product type in the proposed categorisation system. As it shown below, the HS code numbers appear several times in the categorisation system (example: HS code number 6104 covers suits, costumes, jackets, blazers, dresses, etc. for women and girls. This number is therefore assigned both in the subdivision "fashion clothing" and in the subdivision "fashion clothing and underwear for babies/children" as subcategories “upper body” and “lower body”).

The proposed complete categorisation system (No. 1-28) is presented below. For this purpose, the defined application categories (e. g. No. 1), subcategories (e. g. Fashion clothing), product types (e. g. On top garments knitted/crocheted) and the four digits of the HS nomenclature (e. g. 6101, 6102, 6103, 6104, 6114) are linked.

1. Fashion clothing – On top garments knitted/crocheted – HS-codes: 6101, 6102, 6103, 6104, 6114
2. Fashion clothing – On top garments not knitted/crocheted – HS-codes: 6201, 6202, 6203, 6204
3. Fashion clothing – Upper body knitted/crocheted – HS-codes: 6104, 6105, 6106, 6109, 6110, 6114
4. Fashion clothing – Upper body not knitted/crocheted – HS-codes: 6204, 6205, 6206
5. Fashion clothing – Lower body knitted/crocheted – HS-codes: 6103, 6104, 6114
6. Fashion clothing – Lower body not knitted/crocheted – HS-codes: 6203, 6204
7. Underwear – Upper body knitted/crocheted – HS-codes: 6107, 6108, 6114
8. Underwear – Upper body not knitted/crocheted – HS-codes: 6207, 6208
9. Underwear – Lower body knitted/crocheted – HS-codes: 6107, 6108, 6114
10. Underwear – Lower body not knitted/crocheted – HS-codes: 6207, 6208
11. Functional clothing – On top garments knitted/crocheted – HS-codes: 6101, 6102, 6103, 6104, 6112, 6114
12. Functional clothing – On top garments not knitted/crocheted – HS-codes: 6201, 6202, 6203, 6204, 6211
13. Functional clothing – Upper body knitted/crocheted – HS-codes: 6104, 6105, 6106, 6109, 6110, 6112, 6114
14. Functional clothing – Upper body not knitted/crocheted – HS-codes: 6204, 6205, 6206, 6211
15. Functional clothing – Lower body knitted/crocheted – HS-codes: 6103, 6104, 6112, 6114
16. Functional clothing – Lower body not knitted/crocheted – HS-codes: 6203, 6204, 6211
17. Fashion clothing and underwear for babies/children – On top garments knitted/crocheted – HS-codes: 6101, 6102, 6103, 6104, 6107, 6108, 6111, 6114
18. Fashion clothing and underwear for babies/children – On top garments not knitted/crocheted – HS-codes: 6201, 6202, 6203, 6204, 6207, 6208, 6209
19. Fashion clothing and underwear for babies/children – Upper body knitted/crocheted – HS-codes: 6104, 6105, 6106, 6107, 6108, 6109, 6110, 6111, 6114
20. Fashion clothing and underwear for babies/children – Upper body not knitted/crocheted – HS-codes: 6204, 6205, 6206, 6207, 6208, 6209
21. Fashion clothing and underwear for babies/children – Lower body knitted/crocheted – HS-codes: 6103, 6104, 6107, 6108, 6111, 6114
22. Fashion clothing and underwear for babies/children – Lower body not knitted/crocheted – HS-codes: 6203, 6204, 6207, 6208, 6209
23. Functional clothing for babies/children – On top garments knitted/crocheted – HS-codes: 6101, 6102, 6103, 6104, 6111, 6112, 6114
24. Functional clothing for babies/children – On top garments not knitted/crocheted – HS-codes: 6201, 6202, 6203, 6204, 6209, 6211
25. Functional clothing for babies/children – Upper body knitted/crocheted – HS-codes: 6104, 6105, 6106, 6109, 6110, 6111, 6112, 6114
26. Functional clothing for babies/children – Upper body not knitted/crocheted – HS-codes: 6204, 6205, 6206, 6209, 6211
27. Functional clothing for babies/children – Lower body knitted/crocheted – HS-codes: 6103, 6104, 6111, 6112, 6114
28. Functional clothing for babies/children – Lower body not knitted/crocheted – HS-codes: 6203, 6204, 6209, 6211

In order to best integrate the differentiated use of materials within the classification system, all 28 categorisation systems can additionally be segmented into the following material groups (table 4). The term chemical fibre refers to both artificial (regenerated fibres from natural raw materials – "man-made") and synthetic fibres (produced from crude oil). At first sight, this additional segmentation increases the complexity of the system. However, it may be that ecodesign requirements refer to material groups e.g. in the context of recyclability or for durability requirements.

5.2 Procedural approach 

The proposed system is intended to enable the specific allocation of ecodesign requirements to products or product groups. Figure 2 shows the procedure for applying the system presented in three successive steps to obtain the ecodesign requirements for a product in the design process. Most of the required knowledge and information is already available today, as the HS nomenclature is integrated in the proposed system. Currently, computer software is used to determine to which HS code number a product belongs. This requires information on the material used (cotton, wool, man-made fibre) and the surface technology used (knitted/crocheted; non-knitted/crocheted). To determine the ecodesign requirements for a specific product, it is now also necessary to assign it to the (new) subordinate application category, the (new) subcategories and the (new) more specific material group. Both systems, the HS nomenclature and the (future) ecodesign product requirements, can therefore be applied in parallel without the need to change the customs tariff scheme.  

Procedure for integration of future ecodesign criteria based on the categorisation system

For the practical integration of ecodesign requirements into industrial processes, a defined procedure is required.

Source: Sabrina Mauter / Hochschule Niederrhein

The proposal for the Ecodesign Regulation states in Article 5 that the implementation of ecodesign requirements should not impose disproportionate administrative burdens on manufacturers and other economic operators within the production processes. One advantage of this categorisation system is that it does not require a new product definition, as the functional categories are linked to the existing HS categories. A further differentiation is only necessary for specific products, for example, for a functional product and an underwear product. It is also necessary to define children's clothing. For this purpose, a specification based on body size can be used. 

In addition, a complementary analysis is required to include products with more than one layer of material (outer and under fabric, lining). When implementing this defined order, it is initially recommended that only upper materials are used for compliance with the minimum requirements, as this material layer is exposed to the relatively greatest external influences in terms of load and wear patterns. Both systems, the HS nomenclature and the Ecodesign product criteria, can be applied in parallel without the need to change the customs tariff scheme. 

5.3 Products excluded from the system 

For this report, products that can be categorised as everyday clothing are selected, as the quantity of textiles placed on the market and the quantity of textile products on the waste market are predominantly categorised as clothing. Sorting analyses of waste textiles carried out by the Centre Textile Logistics from Niederrhein University of Applied Sciences and Fraunhofer IML in 2020 and 2021 show that inferior product qualities are mainly found in everyday clothing and that a tendency towards higher product quality can be assumed for household and home textiles, for example (Jarmer and Brieger 2021). The reason for this lies on the one hand in the differentiated product surface and on the other hand in the differentiated functionality of these textile products (Maes et al. 2021). 

Table 5 below lists the product groups excluded from the categorisation system with their reasons for exclusion and HS nomenclature. As far as possible, product examples have been supplemented by the listing within the product group codes.

The analysis of existing textile product categorizations shows that a new categorisation system is needed that considers the specific characteristics of the products in order to define practicable and ecologically appropriate requirements. 

As part of the analysis carried out, the aspects of product and surface structure (knitted/crocheted, not-knitted/crocheted), the use of materials (composition, chemical/natural fibres, mono- or multi-material) and the inclusion of potential finishes on functional products and the associated separate surface presentations were derived in particular. In addition, it is necessary that the classification has a clear definition so that no double categorisation can take place. This is a necessary criterion, especially against the background of potential mandatory requirements. Based on the analysis, aspects such as classification by age or gender, colour and cut are not considered relevant for the definition of requirements and therefore do not have to be included in a corresponding product classification system. 

None of the existing and analysed textile product categorisation systems include these requirements. This led to the conclusion that a system needs to be set up that is specifically geared towards defining requirements and provides an optimal basis. In particular, this should be ensured by the fact that the requirements to be developed are based on average values for the corresponding categories, as it is not practical to establish separate and specific requirements for each potential product and material mix.

Particular attention was paid in the analysis to the newly developed JRC system, which has been developed for the textile ecodesign requirements. However, by including the textile technology requirements, the expert team was able to determine that this system also requires a more specific orientation. With this in mind and considering some of the appropriate characteristics of this system, an appropriately modified and more detailed version was created. The system developed therefore still has links to the JRC version, such as the division into upper body, lower body and outer garments worn over other products. The link to existing product codes is also similar, but it is recommended to use the first four digits from the HS code instead of the PRODCOM codes. The categorisation system developed in the course of this work (in connection with the combination of the HS codes), have advantages over the PRDODCOM codes for this specific application, which have been described in detail in chapters 4.3, 5.2. This particularly applies in addition to the aspects already listed in the JRC preparatory study as follows. Most PRODCOM codes have a full reference to the CN, which means that there is full comparability between the PRODCOM data (and the HS data, as the HS code is part of the CN). However, data may be missing in PRODCOM if, for example, the unit of measurement for PRODCOM codes is not standardised, the corresponding trade data on the quantity cannot be provided or the unit of measurement does not match the unit of measurement given in the CN, even if a PRODCOM code has a full CN reference and/or if there is no clear link between PRODCOM and CN (Delre et al. 2024). Especially for practicable integration and handling in trading companies, it is recommended to link the basic categorisation directly to the first four digits of the HS codes. This will significantly reduce the workload for economic operators, as the integration of the HS codes has already been implemented on a product-specific basis. This forms the basis for developing a query system for business participants in just a few steps, which only requires a small amount of additional effort as it is based on existing structures. 

Furthermore, as developed in the system, it is recommended to include the product design as well as the use of materials and the associated different surface designs and finishes in functional products. In the opinion of the project team, it is not possible to create general requirements for specific product groups without this differentiation, as otherwise the product range would be too large. The further developed system enables the demand for a low administrative effort in the implementation of product requirements in the design and development process and lays the textile-technical basis for summarized (minimum) requirements. 

Botta, Valeria; Cabral, Ivo (2021): Durable, repairable and mainstream. How ecodesign can make our textiles circular. With assistance of Veronika Abraham, Andreas Backs, Valentina Romagnoli. Edited by ECOS - Environmental Coalition on Standards. Brussels, Belgium. Available online, checked on 10/25/2023.

Delre, A.; Perez Arribas, Z.; Senatore, V.; Garcia John, E.; Kouloumpis, V.; Napolano, L. et al. (2024): Preparatory study on textiles for product policy instruments. Ecodesign, EU Green Public Procurement, EU Ecolabel. 1st milestone. Edited by Joint Research Centre (JRC). Sevilla., checked on 4/26/2024.

Deutsche Gesellschaft für Internationale Zusammenarbeit GmbH (2023): Anerkannte Siegel beim Grünen Knopf. Edited by Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH. Bundesministeriums für wirtschaftliche Zusammenarbeit und Entwicklung (BMZ), checked on 12/29/2023.

Dialog Textil-Bekleidung e. V. (o. J.): DTB-Warengruppenschlüssel, checked on 7/14/2023.

Ellen McArthur Foundation (2017): A New Textiles Economy. Redesigning fashion's future., checked on 6/18/2024.

Environmental Association Eco Mark (2022): Umweltzeichen Produktkategorie Nr.103. Akkreditierungskriterien für Bekleidung Version 3.6, checked on 12/3/2023.

European Commission (2022a): Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC., checked on 12/20/2022.

European Commission (2022b): COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS. EU Strategy for Sustainable and Circular Textiles (COM (2022) 141 final)., checked on 6/24/2024.

European Union (2014): Beschluss der Kommission vom 5. Juni 2014 - zur Festlegung der Umweltkriterien für die Vergabe des EU-Umweltzeichens für Textilerzeugnisse - (Bekanntgegeben unter Aktenzeichen C(2014) 3677) - (2014/350/EU). 2014/350/EU. European Union, checked on 12/19/2023.

German Environment Agency (2020): Ökodesign., updated on 7/8/2024, checked on 7/8/2024.

German Environment Agency (2022): Die Rolle der Langlebigkeit und der Nutzungsdauer für einen nachhaltigen Umgang mit Bekleidung. Eine Studie zum aktuellen Forschungsstand. 112/2022. With assistance of Jan Gimkiewicz, Sina Depireux, Laura Spengler, Brigitte Zietlow, checked on 11/19/2023.

GS1 Germany GmbH (2019): Erweiterte Stammdaten für Fashion, Schuhe und Sport. Ausgabe 1.0, checked on 7/14/2023.

Handelsverband Textil Schuhe Lederwaren (2013): BTE-Warengruppenschlüssel - Warengruppen, checked on 7/14/2023.

Jarmer, Jan-Philipp; Brieger, Ida Marie (2020): Wissenschaftliche Begutachtung und Bewertung der Alttextilsammlug inkl. Sortieranalyse. Edited by Fraunhofer Institute for Material Flow and Logistics IML, Hochschule Niederrhein, checked on 1/5/2024.

Jarmer, Jan-Philipp; Brieger, Ida Marie (2021): Wissenschaftliche Bgutachtung und Bewertung der Alttextilsamlung inkl. Sortieranalyse im Vergleichszeitraum. Edited by Fraunhofer Institute for Material Flow and Logistics IML, Hochschule Niederrhein, checked on 1/5/2024.

Maes, Edwin; Devaere, Stijn; Colignon, Philippe; Wynants, Jasmien; Soenen, Bram (2021): Ecodesign criteria for consumer textiles. Edited by Public Waste Agency of Flanders, checked on 1/4/2024.

Mauter, Sabrina (2023): Recyclingbasierte Produktaspekte im Kontext der Ökodesign-Anforderungen für Textilprodukte. Hochschule Niederrhein, Mönchengladbach, checked on 10/25/2023.

Ministère de la transition écologique et de la cohésion des territoires (2022): Erlass vom 23. November 2022 mit Lastenheften für die Öko-Organisationen und individuellen Systeme des Sektors mit erweiteretn Herstellerverantwortung für Textilien, Schuhe und Haushaltswäsche. Edited by Direction de l'information légale et administrative (Journal officiel de la République française - N° 273), checked on 12/9/2023.

Ministère de la transition écologique et de la cohésion des territoires (11/23/2022): Arrêté du 23 novembre 2022 portant cahiers des charges des éco-organismes et des systèmes individuels de la filière à responsabilité élargie du producteur des textiles, chaussures et linge de maison (TLC). 

Ökopol GmbH (2023): Die Umsetzung der EU-Textilstrategie. Begriffsbestimmungen und Definitionen als Grundlage für die Ableitung möglicher Ökodesign-Anforderungen. With assistance of Dirk Jepsen, Anna Falkenstein, Frederike Bartzsch, Edith Claßen, Maike Rabe, Markus Muschkiet, Berfin Begtoran. Im Auftrag des Umweltbundesamtes (Projekt Nr. 173705), checked on 11/6/2023.

SAP SE (n. d.): Artikel: Textilzusammensetzungen., checked on 7/14/2023.

Textile Exchange (2021): Materials, Processes, & Products Classification (ASR-213-V1.1-2021.05.01), checked on 7/14/2023.

Textile Exchange (2023): Materials Market Report.

DIN 60000, 1969-01-00: Textilien; Grundbegriffe.

World Customs Organization (n. d.): Informationen zum Zolltarif und zur Ermittlung der Codenummer., checked on 12/29/2023.

World Customs Organization (n. d.): What is the Harmonized System (HS)?, checked on 1/3/2024.

World Customs Organization (2022): HS Nomenclature 2022 edition., checked on 7/14/2023.

World Intellectual Property Organization (2023): Markenklassifikation. Nizza-Klassifikation - Internationale Klassifikation von Waren und Dienstleistungen für die Eintragung von Marken (Liste der Waren nach Klassen).