Antimicrobial textiles: GB importer labelling
Before supplying antimicrobial-treated goods in GB, identify the treatment, check each active substance for the relevant product type and use, and assess label triggers. Keep a treatment file and arrange free consumer replies within 45 days. Coordinate factory evidence through Cambridge China Bridge.
Start with the treatment and intended function
Ask the factory which textile, coating or component is treated, what treatment product is used and what the finished article is intended to do. A treated article with a primary biocidal function is considered a biocidal product. Resolve that classification before using this treated-article labelling workflow.
The microfibre cloths and mops guide covers physical specifications and sample trials. Add a separate treatment schedule to the purchase specification, including proposed packaging and online claims. Record whether the treatment protects the material or supports a claim about the user's surroundings.
Check eligibility by substance and use
For every active substance, check approval for the relevant product type and use, or inclusion on the GB Simplified Active Substance List, and satisfy the applicable conditions or restrictions. Where approval is pending, HSE directs buyers to the GB List of Active Substances and its treated-article eligibility column. A negative entry means the article cannot be placed on the GB market.
Save the checked entry, check date, intended use and relevant approval conditions together. If relying on transitional eligibility, record the applicable end point and recheck before supply. Ask for chemical identities rather than a treatment trade name alone. Keep efficacy reports alongside this record; assess whether their samples and test conditions support the proposed claim using the test-report verification guide.
Decide what the label must say
Additional labelling is triggered by a claim about biocidal properties or by specific active-substance approval conditions. It must state that the article incorporates biocidal products, give the biocidal property where substantiated, name all active substances and identify any nanomaterials with the prescribed bracketed nano wording. Include relevant treatment-related instructions and precautions.
Removing an antibacterial claim does not remove the treatment or settle every labelling duty. Even without that claim, provide instructions and precautions where necessary to protect humans, animals or the environment, and check approval conditions. Review packaging and sales copy together. Avoid approving a broad protection claim using a report that only tests the treated fabric under laboratory conditions.
Approve artwork and keep the evidence together
The person first placing the treated article on the GB market is responsible for its labelling. Required labelling must be clearly visible, easily legible, appropriately durable and in English. Where the article's size or function makes it necessary, HSE allows the information on packaging, instructions for use or the warranty.
Keep the supplier's treatment declaration, substance-status check, approval conditions, claim evidence, approved artwork and batch references in the importer compliance file. Ask the factory to obtain your approval before changing the treatment or treated material. During inspection, compare actual labels and packing against approved artwork rather than checking only that a label is present.
Prepare for consumer information requests
Anyone in the treated article's supply chain must provide information about its biocidal treatment when a consumer requests it, free of charge within 45 days. HSE states this duty separately from the claim-triggered labelling rules. Do not make your reply process depend on whether the pack carries an antibacterial claim.
Give customer service a response template linked to the treatment file. Log receipt of the request, identify the product and batch, retrieve the treatment details and record the reply. Agree with the factory how missing information will be obtained before you approve the order. Cambridge China Bridge's own staff in China can coordinate supplier documents and artwork checks against the buyer's agreed specification.
Frequently asked questions
Does removing an antibacterial claim avoid labelling?
Not necessarily. Approval conditions can require additional wording, and necessary safety instructions still apply. Removing the claim does not remove the treatment.
Is an antimicrobial test report enough for GB imports?
Keep separate checks for active-substance eligibility, intended use and label triggers. Use the report to assess the claim it actually supports, with matching material and test conditions.
Who is responsible for treated-article labels?
The person first placing the treated article on the GB market is responsible. Agree who approves the artwork and checks the finished goods before supply.
How quickly must we answer a consumer treatment request?
Anyone in the supply chain must provide treatment information free of charge within 45 days. Keep a request log and accessible treatment records.