Sleeping Bag Regulations in the European Union: An Overview

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Sleeping Bag Regulations in the European Union

Planning to import or manufacture sleeping bags for sale in the European Union? In this guide, we explain what you must know about various standards, labelling, testing, and other compliance requirements.

More specifically, we take a closer look at the General Product Safety Regulation, the Biocidal Products Regulation, and the REACH Regulation, and how these relate to sleeping bags.


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General Product Safety Regulation

The General Product Safety Regulation requires that products imported, manufactured, and sold in the EU are safe to use. This also includes sleeping bags.

The regulation generally requires you to:

  • Comply with one or more product standards
  • Correctly label your product
  • Provide the technical documentation
  • Provide user instructions, when needed
  • Have your product lab-tested

EN standards

We could not find harmonised standards for sleeping bags. In general, complying with harmonised standards allow you to conform with the safety requirements set by the regulation. When no harmonised exist, you should use other relevant standards to ensure product safety.

Here we list some examples of standards that are relevant to sleeping bags. Note that other standards may exist.

Standards Description
EN ISO 23537-1 – Requirements for sleeping bags – Part 1: Thermal and dimensional requirements This standard sets requirements, test methods, and labelling provisions for adult-sized sleeping bags used for sports and leisure activities.
EN ISO 23537-2 – Requirements for sleeping bags – Part 2: Fabric and material properties This standard specifies the properties of fabric and materials, and the labelling requirements for adult-sized sleeping bags used for sports and leisure activities.
EN 16781 – Textile child care articles – Safety requirements and test methods for children’s sleep bags for use in a cot This standard sets safety requirements for children’s sleeping bags that are used without supervision and are designed to keep children warm without additional bedding.

The standard applies to products used by children under 24 months who cannot climb out of the cot that contains the sleeping bag.

EN 13538-2 – Determination of dimensional characteristics of sleeping bags – Part 2: Thickness and elastic recovery This standard specifies a method for determining the elastic recovery and thickness of sleeping bags that are filled with down or feathers.
EN 13538-3 – Determination of dimensional characteristics of sleeping bags – Part 3: Volume under load and easiness of packing This standard sets a method to measure the volume under load of sleeping bags and calculate how easy it is to pack sleeping bags that are filled with down or feather

Documentation

The regulation requires importers and manufacturers to provide technical documentation, instructions, and test reports.

Title Description
Technical documentation You must provide technical documentation for your product, which should contain the items specified in Article 9.
Instructions You are required to provide clearly written instructions and safety information. This may include information on the assembly, maintenance, safe use and disposal of the product.
Test reports You should have your products tested to ensure product compliance. If your product passes the test, you receive a test report that you should include in your technical documentation.

Labelling requirements

Importers and manufacturers are required to provide a label with their products. The label should go on the product, or the packaging or accompanying document.

Title Description
Product traceability information You need to provide identification information such as batch number, company name, and company address.
Warnings The regulation mandates manufacturers to provide warnings with their products, including age-suitability warnings.

Textile Labelling and Fibre Composition Regulation

The Textile Labelling and Fibre Composition Regulation establishes requirements for labelling textile products. This would also include sleeping bags, as we could not find an exemption for these products.

The regulation generally requires you to provide a product label that describes the product’s fibre content and composition (e.g. 100% cotton) using the textile fibre names listed in Annex I.

Examples

  • Silk
  • Cotton
  • Polyester
  • Elastane
  • Polyamide or nylon

Biocidal Products Regulation

The Biocidal Products Regulation establishes rules for biocidal products and articles treated with biocidal products. Some sleeping bags may be treated with insect repellents or other biocides. As such, such sleeping bags could be subject to this regulation’s requirements.

The regulation generally requires treated articles to:

a. Use biocides containing approved active substances (e.g. those in Annex I)

b. Carry labels containing information specified in Article 58

Note that, in this guide, we only cover requirements for treated articles.

Substance restrictions

Treated articles can only be sold if active substances contained within the biocidal product are listed in either Annex I of the regulation or ECHA’s Union list of biocidal active substances.

By filtering for product type “PT18 – Insecticides, acaricides and products to control other arthropods” on the list of biocidal active substances published on the ECHA website, we found many approved substances. Here are some examples:

  • deltamethrin
  • diflubenzuron
  • Dinotefuran
  • epsilon-Momfluorothrin

Information on biomedical treatment

According to Article 58, consumers can request information about the biocidal treatment of a product from importers and manufacturers, who are required to respond within 45 days.

Labelling requirements

Importers and manufacturers should ensure that their treated article (e.g. sleeping bag treated with insect repellent) carries a label containing the items specified in Article 58.

REACH Regulation

The REACH Regulation sets restrictions on substances used in consumer products. Sleeping bags may contain restricted substances present on the Annex XVII or SVHC Candidate Lists, such as azodyes in the textile parts or lead in the zippers.

Such restricted substances may pose health and environmental risks through exposure to the material. Importers and manufacturers should therefore test their products to ensure they do not contain any such substances above the permitted limits.

In the following subsections, we provide examples of restricted substances that may be found in sleeping bags.

Annex XVII

Annex XVII establishes restrictions for many substances, including some substances that can be used in sleeping bags. Here are some examples of these substances:

  • Azodyes and azocolourants (often used for colouring textiles)
  • Diphenylether, octabromo derivative (may be used as flame retardant in textiles)
  • Lead (may be found in the zipper, for example)
  • Phthalates (may be found in plastic components)

SVHC Candidate List

The SVHC Candidate List contains substances that may cause permanent harm to the environment and human health. You need to notify the ECHA via the SCIP database if your product contains an SVHC with a content exceeding 0.1% by weight.

Sleeping bags may contain listed substances. For example, the following substances may be found in textiles:

  • Triphenyl phosphate
  • Pentadecafluorooctanoic acid (PFOA)
  • Bumetrizole

Persistent Organic Pollutants (POPs) Regulation

The Persistent Organic Pollutants Regulation sets restrictions on substances, including substances used in consumer products.

According to the ECHA, persistent organic pollutants are substances that can remain in the environment for a long time. Some of these substances can be used as fire retardants, or water repellents. As such, these substances are sometimes used to manufacture sleeping bags.

In addition, some persistent organic pollutants are used as pesticides, which may end up in cotton, including cotton used in sleeping bags.

Here are some examples of restricted substances that may be found in sleeping bags:

  • PFAS
  • PFOS
  • PFOA
  • DDT

Lab Testing

You should get your product lab tested to prove compliance with the relevant regulations or directives. While some regulations require product testing, for others testing is still a practical necessity. If your product passes testing, you receive a test report indicating product compliance.

Regulation Lab testing
General Product Safety Regulation This regulation sets safety requirements for consumer products, including sleeping bags. Several standards set methods for testing such products. For instance:

a. EN ISO 23537-1 – sleeping bags should undergo testing to ensure they do not exceed the limit temperature of −20 °C.

b. EN 16781 – sleeping bags should undergo testing to ensure children can safely use them unsupervised in sleeping environments.

Biocidal Products Regulation This regulation sets requirements for biocidal products and articles treated with such. Treated articles should undergo testing to ensure they only contain approved substances (e.g. Deltamethrin).
REACH Regulation This regulation sets substance restrictions. You should have your sleeping bag products tested to ensure they do not contain restricted substances (e.g. phthalates) over permitted limits.
Persistent Organic Pollutants (POPs) Regulation This regulation also restricts substances used in consumer products. You should have your sleeping bags tested to ensure the POP substances within (e.g. PFOA) comply with the regulatory substance restrictions

Sleeping bag testing companies

Here are some companies that claim they can test sleeping bags against EU regulations:

  • Intertek
  • Eurofins
  • IDFL
  • SGS
  • (USA & EU)

    FREE CONSULTATION CALL (US, EU & UK)

    • Request a free 30-minute call with Ivan Malloci to learn how we can help you with:
    • Find product requirements
    • Certification and labeling
    • Lab testing

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    Disclaimer: The Site cannot and does not contain legal advice. The legal information is provided for general informational and educational purposes only and is not a substitute for professional advice. Accordingly, before taking any actions based upon such information, we encourage you to consult with the appropriate professionals. We do not provide any kind of legal advice. THE USE OR RELIANCE OF ANY INFORMATION CONTAINED ON THE SITE IS SOLELY AT YOUR OWN RISK.

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    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • ec.europa.eu
    • echa.europa.eu
    • ecfr.gov
    • cpsc.gov
    • ftc.gov
    • fcc.gov
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