Footwear labelling for retailers

The footwear industry includes a range of materials and products, from men's, women's, and children's shoes to specialist items such as snowboard boots and protective footwear.

Understanding the materials used in footwear through clear and accurate labelling helps consumers make informed purchasing decisions based on value, ethical standards, and environmental impact.

Comprehensive labelling of footwear and its components ensures transparency beyond design and pricing.

The Footwear (Indication of Composition) Labelling Regulations 1995 set out how footwear sold in the UK must be labelled. The Regulations apply to all types of footwear, from sandals to knee-length boots.

However, some products are exempt, including:

• second-hand or worn footwear
• protective footwear (e.g., safety boots)
• footwear containing asbestos
• footwear intended for use in play (e.g., designed as toys or fancy dress for children under 14)

Manufacturers are responsible for providing accurate product labels describing the composition of the footwear and its main components. Retailers must ensure that the footwear sold in shops or online is correctly labelled and complies with UK regulations.

Footwear labelling requirements

Footwear labels must provide the consumer with information about three main parts of the footwear.

The label must indicate what material makes up 80% of:

• the surface area of the upper (the external surface attached to the outer sole, excluding any accessories or reinforcements)
• the internal surface area of the lining and insole (which covers the inside surface of the footwear)
• the outer sole (the bottom part that contacts the ground)

Manufacturers must ensure that the materials are labelled according to one of the four compositions specified in the Regulations:

• leather
• coated leather
• textile
• other materials (e.g., rubber, plastic and foam)

How to describe footwear materials

The term ‘full grained leather’ is defined in the Footwear (Indication of Composition) Labelling Regulations 1995 and can be used as additional information where it applies.

Wool does not have to be named separately on footwear labels. Even as a main material, it falls under ‘textile’, which also includes plant-based and synthetic fibres such as cotton, hemp and polyester, unless a brand chooses to specify it.

The Regulations allow for other expressions, for example ‘acrylic’, to be used, but they must not mislead consumers. ‘Other materials’ would include rubber, plastic, and foam.

The information can be provided using pictograms (symbols) or written descriptions identifying the main materials used for the upper, lining, insole, and outer sole. Schedule 2 of the Regulations specifies the required pictogram format.

When footwear is made from more than one material, identify the two primary materials used. If pictograms are used, retailers must ensure customers can understand what each symbol represents.

Attaching and displaying footwear labels

The label must be attached to at least one item of footwear per pair. It can be affixed by printing, sticking, embossing or using an attached label, tag, fastener or string.

The labelling must be visible, securely attached and accessible, with the pictogram dimensions sufficiently large to be easily understood.

Labels may also be present on the packaging, but the Regulations require them to be affixed directly to the footwear itself.

Footwear labelling in store

If a retailer uses pictograms in store, they must display a clear notice in a prominent place explaining what the symbols mean. The notice must be large enough for customers to easily see and understand the information.

Footwear labelling for online retail

For online and distance selling, certain information - particularly the main characteristics of the goods - must be provided clearly to consumers before they make a purchase. The online product description must accurately reflect all footwear labelling information.

If pictogram labels are used, consumers must be clearly informed of the symbols' meanings. This also applies to online product advertising.

Accurate footwear labelling and avoiding misleading Information

Retailers must ensure that all the footwear they offer and sell to consumers is accurately described.

Consumers must have accurate information about the products offered so they can decide whether they want to buy them. Footwear labelling enables consumers to make informed choices based on their personal preferences and environmental considerations.

In addition, the Digital Markets, Competition and Consumers Act 2024 (DMCCA) prohibits traders and retailers from misleading consumers. This includes falsely describing products, omitting key information, or presenting information in a way that could confuse or mislead the consumer - for example, by displaying an incorrect footwear label on a product.