EU footwear labelling: which symbol for your upper
The label on your shoe box is not a design decision. It is a legal classification, and the number that decides it sits in your tannery's technical sheet — not in your factory's sample room.
A guide by TL San Martín, a tannery of origin in Elda (Alicante, Spain) since 1995, LWG Gold certified under the Leather Manufacturer standard — the only standard where a Gold medal exists.
Every pair sold in the EU carries a label naming the material of three parts: upper, lining plus insock, and outer sole. A material only gets named if it covers 80% of that part — otherwise you name the two main ones. And whether your upper counts as "leather" or "coated leather" is decided by a single number your tannery holds: the thickness of the finish.
Directive 94/11/EC has governed this since 1994, and it still catches first collections out — usually at the worst moment, when the boxes are already printed.
What exactly has to appear on the label?
Three components, in this order, each with either a pictogram or a written indication in the language of the country of sale:
| Component | What it covers | How the 80% is measured |
|---|---|---|
| Upper | The outside surface of the shoe attached to the sole | By surface area, ignoring accessories and reinforcements |
| Lining and insock | The lining of the upper and the insole inside the shoe | By surface area |
| Outer sole | The underside subject to abrasive wear | By volume, not surface |
The rule is the same in all three: if one material covers 80% or more, you name that material alone. If nothing reaches 80%, you name the two main materials. The label must appear on at least one item of each pair, and it may be printed, stuck on, embossed or attached — as long as it is visible, securely fixed and accessible.
One detail that saves arguments with a factory: when classifying the upper, accessories and reinforcements are not counted. Ankle patches, edging, ornamentation, buckles, tabs and eyelet stays are excluded from the calculation. A sneaker with leather panels and a textile collar trim is often still "leather" once you strip out the parts that do not count.
Why is "leather" a legal word and not a marketing one?
Because Annex I defines it. For labelling purposes, leather is a hide or skin whose original fibrous structure is intact, tanned so it does not rot, with the hair or wool on or off. That definition carries two consequences founders discover late:
- If the fibres are ground, pulverised or reduced to sheets or particles and then reconstituted, it is not leather. No bonded or "reconstituted leather" sheet may carry the leather pictogram.
- If the surface coating is more than 0.15 mm thick, the correct term is "coated leather", not leather — provided the coating still does not exceed one third of the total thickness. Above that, it stops being leather altogether for labelling purposes.
That 0.15 mm is the number nobody in the supply chain volunteers. A heavily pigmented finish, a cast or transfer film, a patent effect — any of these can push a hide over the line. The material is not worse for it; the label simply has to say so. This is why the finish specification and the label are the same conversation, and why the answer lives in the tannery, not in the shoe factory. If you are still choosing the article itself, start with leather for shoes and the difference between full grain, corrected grain and split, because the finish route follows from that choice.
What do you have to ask your tannery before the label is printed?
Four questions. Any tannery that runs its own drums answers them in one email; a trader forwards them on and comes back in a week.
- What is the total finish thickness in mm? You need a figure, not "a light pigment". Under 0.15 mm you label leather; over it, coated leather.
- Is the article finished leather, or a split with a coating? A coated split is legally a different animal from a coated full grain, and the customer-facing story is different too.
- What is the material declaration for the lining? Leather, textile or "other materials" — the lining pictogram is a separate decision from the upper and is frequently copied wrongly from the sample sheet.
- Is the article free of reconstituted fibre? If the answer is a percentage, you are being quoted bonded material and the leather pictogram is off the table.
Keep the answers with the batch reference. When you reorder next season and the finish is adjusted, the label may have to change with it — see the reasons a lot reads differently from the sample.
Is the label the same thing as the customs code?
No, and mixing them up costs money in both directions. Labelling tells the consumer what the shoe is made of under 94/11/EC. Tariff classification tells customs which heading the shoe falls under, and the upper material drives the heading — 6403 for leather uppers, 6404 for textile uppers with rubber or plastic soles, and so on. The two use different definitions and different thresholds, which is why a pair can be labelled "coated leather" and still be classified under a leather heading. We cover the mechanics in footwear HS classification and in exporting leather goods.
Disclaimer. This is a sourcing guide, not legal or customs advice. Verify the current text of Directive 94/11/EC and its Annex I on EUR-Lex, and your national implementation with the relevant authority. The UK applies its own footwear labelling regulations — check GOV.UK before shipping there.
Frequently asked questions
Do I have to use pictograms, or can I write the material out?
Either. Annex I allows pictograms or written indications, but written indications must be in a language the destination member state accepts, which in practice means a multilingual label or country-specific runs.
My upper is 70% leather and 30% textile. What do I label?
Neither reaches 80%, so you name both — the two main materials. Before you accept that, recheck the calculation with accessories and reinforcements excluded; that alone often pushes the leather above 80%.
Who is legally responsible for the label?
The manufacturer, or their EU-established agent. Where neither is established in the EU, the obligation falls on whoever first places the footwear on the EU market — normally the importer. If you produce outside the EU, that is you.
Does a "genuine leather" stamp mean anything here?
Not in labelling terms. The directive recognises leather, coated leather, textile and other materials. "Genuine leather" is marketing language and covers everything from an honest crust to a coated split. Ask for the article name, the thickness and the finish spec instead — the same discipline we apply to reading an LWG certificate.
The open board. Specifying a first production run and need a material that survives the label check? Post what you are looking for — article, thickness, finish and market — in the Materials category of the TL San Martín Business Board, the free, open B2B board for leather and footwear. Sourcing questions like this one get answered faster between peers than in an inbox.