Quality Assurance Manual

Quality Assurance Manual

Version: v13.00_EN

Latest update: 15/05/2026

Effective from: 01/07/2026

Collaboration with our Business Partners is essential to the way we grow as a business and ensures delivery of only safe and high-quality products to our fashion platform for customers’ joy.

Table of Changes

1. Introduction

The continuous growth and success across our markets is based on trust, enabling customers to enjoy articles that are not just fashionable, but also of high quality.

We recognise our responsibility to protect consumer health, the environment and our supply chain, and we reinforce our commitment to excellence in product quality, safety and sustainability through trustful relationships with our business partners.

By engaging in a business relationship, you confirm your understanding and acceptance of - depending on your business relationship with Zalando - either our Zalando Platform Rules or our General Conditions of Purchase of Zalando SE, which mandate compliance with all requirements outlined in this manual.

The manual is part of the contract between Zalando and the Partner, regardless of whether or not the Partner has signed it separately. Zalando will provide the Quality Assurance Manual to the Partner upon request at any time.

Berlin, 15/05/2026

Johanna Maentynen

Director Corporate Product Compliance

1.1 About this Manual

The Quality Assurance Manual (hereafter QAM) is binding to all business partners (hereinafter Partners) engaging in a business relationship with any Zalando SE proposition (hereinafter Zalando), namely Lounge by Zalando (Lounge), Partner Program (PP), Zalando Fulfilment Solutions (ZFS), and Zalando Wholesale (WHS).

The QAM outlines Partners’ product-related quality assurance obligations to comply with. The term ‘products’ herein encompasses physical consumer goods with associated consumer information and warnings, product packaging, and accompanying product documents and product data. Partners and their respective products that don’t comply with the QAM are violating our contractual agreement.

It is imperative for Zalando to enter into a mutually beneficial business relationship with its Partners. However, a breach of contractual agreements may result in:

• Termination of the business partnership

• Contractual fines associated with non-compliances

• Product withdrawal and/or recall

• Stock return and order cancellation

• Notification to market authorities

1.2 How to read this Manual

Partners are required to adhere to the QAM and its specifications, effectively communicating them to relevant parties within and outside their organisation. While the legislative requirements outlined in this manual are not exhaustive, it's crucial to seek expert advice when necessary.

Partners are required to strictly adhere to the scope as per Chapter 2. Scope of Operation and ensure that products intended for sale comply with all national requirements of agreed sales countries and associated language requirements, unless otherwise agreed.

Regardless of the product category or any individual agreements, Partners must adhere to the generally applicable Partner responsibilities and ensure compliance with all general requirements detailed in Chapter 3. Partner Responsibilities.

Chapter 4. Product-specific requirements expands the general requirements by additional obligations that only apply to product categories with more complex legal nature. However, Chapter 4 only supplements the general requirements in Chapter 3, which always applies to all products.

Partners should be aware that the referenced chapters, linked information, and details provided in the annexes are equally important. In this context we emphasise the importance of Zalando specific requirements in Annex I: Product Restricted Substances List and Chemical Policy, Annex II: CE-Marked Products, Annex III: Guidelines to Classification of Product Defects, Annex IV: Testing of children’s products, Annex V: Testing of Infant and Toddler Products , Annex VI: Mandatory Onboarding Conditions for new Partners, Annex VII: Prohibition of EUDR-relevant Products and Annex VIII Upcoming legislative requirements.

This approach keeps the main content concise and focused while making all necessary details easily accessible, thereby promoting better understanding and ensuring compliance.

2. Scope of Operation

Partners must adhere to Zalando's desired product scope and are required to ensure compliance with applicable legislation in all agreed Zalando sales countries.

2.1 Sales Countries and Languages

Products at Zalando must comply with country-specific legislation for agreed sales countries, and the product labelling must be in the official languages. As the scope of sales countries for Zalando Wholesale (WHS), Lounge (Lounge), Partner Program (PP), and Zalando Fulfilment Solutions (ZFS) differs, particular attention must be given to accepted sales countries and required languages, indicated by the ‘•’ symbol, as shown in the table below. Sales countries left blank are prohibited. If deviating from the general sales scope, product-specific sales countries are outlined in chapter 4.

¹ = Delivery via zalando.ch; ² = Delivery via zalando.fr

2.2 Product Scope

The product scope is limited to consumer goods for personal use. Products that are designed and manufactured for professionals, which are likely, however, under reasonably foreseeable conditions, to be used by non-professionals, are strictly prohibited.

Partners must assess the products and ensure that they align with the product scope.

As the product scope of Zalando Wholesale (WHS), Lounge (Lounge), Partner Program (PP), and Zalando Fulfilment Solutions (ZFS) differs from each other, attention must be given to the ‘permitted’, ‘restricted’ and `prohibited` product categories for each proposition in the table below.

Permitted product categories are indicated by the ‘•’ symbol, while categories left blank are prohibited. Some product categories are restricted and only accepted if they have an EU responsible person (which must also be correctly labelled on the product), other than Zalando. Restricted product categories are indicated with the ‘EEA’ symbol. If a product falls into multiple categories and at least one category is prohibited, Zalando does not permit the sale of such products.

Note: ¹ = Applicable upon the enforcement date of the EUDR. Please refer to Annex VII: Prohibition of EUDR-relevant Products for detailed information.

2.3 Legislative Reference

It’s imperative that products intended for sale must comply with the respective national legislation in Zalando sales countries as well as the EU General Product Safety Regulation (GPSR) 2023/988, as well as the UK General Product Safety Regulations 2005 and the Swiss Product Safety Act (PrSG).

The partners are required to assess the national transpositions of legislation for the agreed Zalando sales countries and ensure that products consistently meet the stricter national requirements. The legislative references in this manual and summarised legal requirements may not be comprehensive or up to date due to ongoing legislative changes.

Link to legislative platforms

• EU:

  https://eur-lex.europa.eu

• CH:

  https://www.fedlex.admin.ch

• UK:

  https://www.legislation.gov.uk

Non-comprehensive overview of relevant legislation, excluding amendments, secondary legislation and transposition into national law:

3. Partner responsibilities

Zalando prides itself on differentiating itself through its high quality standards. Ensuring and maintaining excellent product quality throughout the entire supply chain is our fundamental expectation from our Partners.

3.1 Pre-Sale Data Provisions

Zalando reserves the right to cancel any order, refuse delivery, or ban articles from our platform for which relevant pre-sale data conditions are not fully met, where the provided information is incomplete, or where the information reveals non-compliance.

3.1.1 Data Provision applicable to all Partners

• Product Files (Technical Documentation)

  The Partner warrants it will ensure the manufacturer's complete and accurate Technical Documentation is available for ten (10) years after the last unit is sold and will provide it upon a reasoned request. Furthermore, the Partner must cooperate fully and promptly with any inquiry from a market surveillance authority and provide a direct communication channel for transmitting technical files from the product's responsible person.

• Product Data

  The Partner warrants that all requested product data is submitted via Zalando's data sourcing interface. Further, the partner warrants the product data is complete, accurate, and in exact match to the information on the physical product's labeling, packaging, and accompanying documentation (e.g. user manuals).

• Designated Responsibility

  The Partner warrants that a legal Responsible Person established in the EEA is designated for each product. The Partner must ensure that the name and contact details (physical and email address) of both the Responsible Person and the manufacturer are clearly marked on the product, or its packaging. The Partner must also submit this information accurately as product data and promptly update it if it changes.

3.1.2 Additional Data Provision applicable only to our Direct Suppliers for resale (Wholesale & Lounge Procurement Model)

EEA Suppliers

• Product Imagery

  The Partner must submit clear, high-resolution digital images of all final product labels and packaging via Zalando’s data sourcing interfaces.The partner warrants that the information shown on images match the physical product and comply with applicable legal requirements for product labelling and comply with the Zalando languages requirements of agreed sales countries.

Non-EEA Suppliers

• Product Imagery

  The Partner must submit clear, high-resolution digital images of all final product labels and packaging via Zalando’s data sourcing interfaces.The partner warrants that the information shown on images clearly and visibly shows the label of the EEA responsible person such as the complete Zalando importer address and that images match the physical product and comply with applicable legal requirements for product labelling and comply with the Zalando languages requirements of agreed sales countries.

• Product Files (Technical Documentation)

  Partners established outside the European Economic Area (EEA) not only warrant the availability, additionally they must provide Zalando with unrestricted access to a complete digital copy of the product's Technical Documentation via Zalando's data sourcing interfaces before shipping any order. The Partner acknowledges its obligation to provide all necessary information to support Zalando in fulfilling its legal duties as an importer under the General Product Safety Regulation (GPSR).

3.1.3 Additional Data Provision applicable only to our Marketplace Traders (ZFS & PP Direct-to-Consumer Model)

• Distant Seller Contact Details

  The Partner warrants that its name, trade name or trademark, postal address, and electronic contact details are accurately registered and clearly displayed to customers on the Product Detail Page. As the Distributor and Distant Seller established in the EEA under the General Product Safety Regulation (GPSR), the Partner acknowledges it is solely responsible for fulfilling all associated legal duties.

3.2 Product Documents and Data

Partners are required to provide and maintain product documentation and product data in digital format, while ensuring prompt and accurate responses to Zalando’s document and data inquiries during onboarding and throughout the ongoing business relationship.

3.2.1 Technical Files

Partners are required to assess the regulatory requirements for the technical documentation of products and ensure to comply with such requirements and provide these documents for each article in scope offered at Zalando. Upon reasoned request from Zalando, Partners are required to transfer associated product documentation in a format and language specified by Zalando. The standard language for the product documentation is English. Partners are obligated to retain the documentation for a period of 10 years from the date when a product (or the last batch) was placed on the market.

The technical documentation is created by the manufacturer, containing information demonstrating the products' conformity with applicable legislative requirements. Requirements for maintaining records of the technical file and associated documentation for a specified period, typically at least 10 years after the product is placed on the market.

3.2.2 Digital Product Data

Each Partner must ensure that product data and information are submitted through our online interfaces. All submitted data must be accurate, complete, up-to-date, and correspond to the actual product being offered.

The partner agrees to regularly review this data and report any errors to Zalando immediately. Missing, misleading or incorrect information is a subject to non-compliance and might result in return, cancellation or removal of the article from sales.

Digital product data serves multiple purposes, such as integration into customer-facing content directed to our online product offering and file-based verification.

3.3 Notification and Reporting Duties

Where a partner considers or has reason to believe, on the basis of the information in that partner's possession, that a product is a dangerous product, the partner shall immediately inform Zalando thereof. This includes notifying the market surveillance authorities in the Member States where the product has been made available, through the Safety Business Gateway.

3.3.1 Reporting of Product Issues

Partners are required to report any product issues to Zalando Product Quality and Safety Departments (specific contact details are available here: 6. List of contacts) no later than 2 business days after identification and to inform the responsible government authorities in their country immediately in the event of justified safety concerns. If Zalando does not receive a copy of the Partner's report to the authorities, Zalando will inform the competent authorities. Partners must address product issues and safety concerns formally through a legal statement, including clear information about the product, risks, remedies, and customer rights.

Upon reasonable request and in case of product failures, Partners are required to provide Zalando with independent 3rd party assessments, e.g. physical or toxicological risk assessments within 7 business days.

Partners are required to register on public product safety alert platforms, and thoroughly monitor products before selling them. Vice versa Partners must also maintain open communication channels and provide access to information on product identification, risks, and actions taken on their website.

Partners agree to recognise reasonable recall decisions and related compensation for direct costs and damages incurred by Zalando. The partners also agree that Zalando will publish the information on its own website and inform its affected customers by email. In addition, partners agree to withdrawal products and customer-facing content suspected of being harmful or illegal.

Useful links:

• EEA:

  Business Safety Gateway

  ,

  RASFF Window

• DE:

  Lebensmittelwarnung.de

  ,

  BAuA

• UK:

  GOV.UK

• CH:

  RecallSwiss

  ,

  BFK

• FR:

  Rappel

• Global:

  OECD

3.3.2 Collaboration on Complaint Data

Partners are required to cooperate with Zalando on legitimate customer complaints in cases of known product risks or legitimate concerns. Partners keep a comprehensive register of complaints from B2B and B2C customers, of non-conforming products and recalls, and keep Zalando informed of any such monitoring. This register should include relevant details such as the nature of the complaint, date received, action taken and current status of resolution. The information shared should be limited to what is necessary to investigate complaints. Protecting the confidentiality and security of customer information stored in the register and ensuring compliance with data protection regulations such as the EU's General Data Protection Regulation (GDPR) is paramount. This data should only be retained for as long as necessary for investigative purposes, but no longer than five years after initial entry.

3.3.3 Substances of Very High Concern

All Partners are required to identify if their products contain Substances of Very High Concern (SVHCs) and provide information on whether or not SVHCs are present above 0.1% weight by weight (w/w) to Zalando prior to any sales. Zalando, in turn, will communicate this information to requesting consumers. In the event that SVHC information is not available at the time of the customer’s request, Zalando grants the Partner a lead time of 5 working days to obtain this information.

Relevant to EEA-Partners: EEA-Partners are required to ensure that the responsible EU manufacturer or EU importers has submitted information of products containing SVHCs above 0.1% w/w to the SCIP database. The database aims to improve transparency regarding SVHCs in products throughout their lifecycle. Zalando tracks the Partner’s submission of SVHC information and facilitates the provision of information upon third-party request.

Relevant to Non-EEA Partners: Non-EEA Partners are required to share information of products containing SVHCs above 0.1% w/w with Assent, a third-party provider commissioned by Zalando, who requests SVHC information on style/component levels biannually. If products contain no SVHCs above the threshold, a declaration confirming this status is required.

3.4 Due Diligence Processes

Partners are required to demonstrate compliance through established due diligence procedures, including the provision of product test reports, certificates, and internal inspection records, based on documented pre-market safety risk assessments for each product intended for sale. Upon request, partners must provide the required proof in a digital format and in the language specified by Zalando. The standard language for all documents is English. Partners must retain all documents for a period of 10 years from the date when a product (or the last batch) was placed on the market.

3.4.1 Quality Assurance Procedures

Partners commit to effective product quality assurance processes and procedures. We expect Partners to continuously improve product quality, using feedback to refine processes. Quality standards are actively communicated, understood and effectively demonstrated throughout the Partner’s organisation. This includes diligent management of internal documents and product related files.

Partners are required to align their quality assurance procedures with the QAM, integrating testing, control measures, inspections, and certification throughout the stages of production and supply chain. This includes ensuring matching descriptions and size charts within acceptable limits, maintaining quality cutting tools like blades, scissors, and knives, implementing good housekeeping practices for clean and hygienic workstations, and delivering A-grade quality products in suitable packaging.

Furthermore, partners must implement an internal Metal Control Policy, establishing a documented broken needle recovery and cutting tool management protocols; passing all products through a metal detector is highly recommended. The use of staples (in products or packaging), metal clips/pins in formal shirts, or safety pins in children’s products is strictly prohibited.

3.4.2 Material Compliance

General material due diligence

Due diligence in product compliance is essential for companies operating within the EU to ensure that their products do not contain restricted substances that could pose risks to human health and the environment. This process involves a comprehensive assessment of potential restricted substances as defined by the REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) regulation, Persistent Organic Pollutants (POP) regulation, and Biocidal Products Regulation. To effectively conduct due diligence, companies must implement thorough testing and assessment procedures to evaluate the presence and concentrations of restricted chemicals. This includes, testing for restricted substances, assessment of chemical concentrations, notification and reporting.

Material used for product packaging and accompanied paper documents

Business partners are required to assess and comply with additional regulatory requirements for all product packaging including the reduction of heavy metals and/or the restriction of banned substances for packaging as defined by EU legislation, as well as national legislation on prohibition of mineral oils used in the printing of packaging. The prohibition also applies to any printed materials accompanying the product, such as user instructions, operation manuals, or other documents.

Products containing wood and rubber-based materials

Business partners not affected by the restriction set out in section 2.2 are required to assess and comply with the EU Deforestation Regulation (EUDR), which repeals and replaces the EU Timber Regulation (EUTR). The EUDR applies to the following relevant commodities and their derived products: cattle, cocoa, coffee, oil palm, rubber, soya, and wood. Partners must ensure that all relevant products are deforestation-free, produced in accordance with the relevant legislation of the country of production and are covered by a due diligence statement or a simplified declaration

Products containing conflict minerals

Business partners are required to assess the quantity and supply chain origins of products containing tin, tantalum, tungsten, and gold (commonly referred to as 3TG minerals) to ensure that these materials are not contributing to the funding of armed groups or security forces in conflict-affected regions. The EU Conflict Minerals Regulation mandates that partners follow the due diligence recommendations outlined in the OECD Due Diligence Guidance, to responsibly source these minerals and ensure ethical practices throughout the supply chain.

Materials in contact with food

Business partners are required to assess and comply with all regulatory requirements applicable to food contact materials, and ensure that products coming in contact with food meet chemical thresholds and migration limits defined in specific Union legislation on certain materials, including on plastic, metals and ceramics, as well as with National legislation on other materials. In addition to this Regulation, all Food Contact Materials (FCM) must be manufactured in accordance with Good Manufacturing Practices.

Substances of Concern in Packaging

All packaging must comply with the Packaging and Packaging Waste Regulation (PPWR) by minimizing substances that negatively affect material recyclability or safety. The sum of concentration levels for Lead, Cadmium, Mercury, and Hexavalent Chromium is strictly limited to 100 mg/kg. Partners must maintain and provide, upon request, technical documentation or laboratory reports verifying compliance with these mandatory concentration limits.

3.4.3 Product Testing, Certification and Inspection

Partners are required to demonstrate that each product’s manufacturing / delivery batch went through internal quality checks and independent accredited testing laboratories, ensuring compliance and mitigation of assessed risks. Zalando accepts in general only proofs that are not older than 12 months (Zalando only accepts test reports that are no older than one year from the date the product or batch was introduced to the market/ delivered to Zalando), referencing the applied test methodologies, product identification details, batch number, and component-level results. In detail that includes:

Chemical testing

Partners ensure chemical compliance by ruling out chemical risks and presence of chemical substances, harmful to human health or the environment beyond required chemical limits. Tests are crucial for quantifying chemical concentrations in raw materials, finished products. Partners are expected to comply with regulatory limits set by regulatory bodies like the European Chemicals Agency (ECHA) and limits outlined in Zalando's Product Restricted Substance List (PRSL) (see Annex I Product Restricted Substances List and Chemical Policy )

Physical testing

Partners ensure physical compliance by ruling out mechanical risks such as the structural integrity, durability, and mechanical properties, harmful to human health in particular to vulnerable customer groups, following relevant standards. Techniques such as mechanical testing, thermal analysis, and microscopy are utilised to assess product performance under various conditions. Products must be designed and manufactured to minimise physical risks during normal use.

Artwork testing

Partners ensure compliant artwork by ruling out formal non-compliance and health risks ensuring complete physical, mental and social well-being due to missing, misleading or humiliating visual and graphic elements, following product-related legislation and standards. This also encompasses assessments of colour accuracy, legibility of text, and inclusion of mandatory product identifiers, consumer information, and compliance markings.

Proof of Certification

Partners ensure that product (marketing) claims are sound and compliant and backed by credible certifications and evidence to not mislead consumers about the performance or environmental benefits of a product. By undergoing third-party certification, Partners demonstrate their commitment to the claim, build trust with consumers, and differentiate their products in the marketplace.

Quality Inspections reports

Partners ensure that production and delivery batches are inspected. Inspection reports must record production/delivery batch, inspection date, inspection method, detailed inspection result and include functionality check e.g. for zippers as well as packaging and labelling checks. Each Delivery is free from any damage, contamination (such as mould* or insects), or free from sharp objects (needles, safety pins etc.).

*Zalando does not recommend a preferred mould prevention supplier. Any mould prevention products used must be registered according to REACH Regulation EC No - 1907/2006 and, if applicable, according to Biocide regulations (EU) No 528/2012 at partners’ responsibility. All devices should be marked with the product name / product manufacturer and with appropriate safety instructions.

3.4.4 Risk Assessment

Partners must ensure that all products undergo a comprehensive internal pre-market safety risk assessment in line with GPSR Article 6, as well as any additional essential requirements set by applicable EU harmonisation legislation. The manufacturer is responsible for conducting this assessment, proportionate to the product's complexity and potential risks. This includes identifying all possible hazards associated with the product. The analysis must be documented in the technical file, along with the documentation of implemented measures to mitigate or eliminate identified hazards.

Demonstrating adherence with European standards published in the European Union Official Journal (OJEU) indicates that products meet safety requirements. If no harmonised standards are available, verifying product safety requires evaluating several key factors. These include national standards that align with European standards not yet harmonised, European Commission guidelines on product safety assessments, industry-specific codes of good practice, the latest technology and industry insights, and Zalando's reasonable expectations for safety.

In terms of risk reduction measures, if assessed risks are deemed unacceptable, steps are taken to mitigate or eliminate identified hazards. This might entail product redesign, incorporation of safety features, provision of warnings or instructions, or implementation of safeguards e.g. testing to minimise risks. The following aspects, among others, must be taken into account:

• Characteristics, design, technical features, composition, and packaging

• Interactions with other products, non-embedded items

• Presentation, labelling, age suitability, warnings and user instructions

• Vulnerable consumer groups e.g. children, older people and persons with disabilities

• Potential misuse / confusion with other products e.g. child appealing, food imitating

3.4.5 Assessment of Economic Operator Role

Partners must evaluate their own economic operator role as well as the role of other legal persons involved in the supply chain and determine if affected products have a designated responsible person within the European Economic Area (EEA).

Economic roles

• Manufacturer

  : The legal entity identified on the product label, established within or outside the EEA, responsible for manufacturing or designing and producing the product under its own name, trademark, or brand.

• Importer

  : Where the manufacturer is not established in the EEA, this refers to the legal entity identified on the product label, established in the EEA, who places a product from a third country on the Union market.

• Distributor

  : The legal entity established in the EEA, other than the manufacturer or the importer, who makes a product available to consumers and/ or business partners in the EEA.

• Authorised Representative

  : Legal entity established within the EEA who has received a written mandate from a manufacturer to act on that manufacturer’s behalf in relation to specific tasks regarding the manufacturer’s obligations.

• Fulfilment Service Provider

  : Legal entity in the course of commercial activity, at least two of the following services: warehousing, packaging, addressing, and dispatching, without owning the products involved, and excluding postal services as defined.

If no legal entity established in the European Economic Area (EEA) other than Zalando is responsible for the affected products in the EEA, nor is any EEA legal entity indicated on the product label as required by chapter 3.5 Product Labelling and Packaging, and Zalando agrees with the Partner to act as the EU importer (thus becoming the EU responsible person for the items), the Partner is always obliged to:

1. Submit the Technical Documentation

Provide comprehensive ‘Technical Documentation’ for each product through Zalando’s interfaces. At a minimum, the technical documentation should cover the elements outlined in Chapter 3.2 Product Documents and Data.

1. Apply the Zalando Importer Address

Label each individual product with the Zalando Importer Address as specified in Chapter 3.5.1 Product Traceability and Identification.

3.4.6 Zalando Due Diligence Programs

Partners are required to participate in testing and due diligence programs upon Zalando requirements. Partners might be obliged to register with external service partner websites and to commission a third party laboratory at Zalando's request. Partners are also aware that Zalando conducts random compliance checks and may commission independent third parties to conduct them.

Inbound deliveries may be subject to warehouse inspections based on Industry Standard Acceptable Quality Level (AQL) of 2.5 for Major defects and 4.0 Minor defects. This helps to objectively monitor partner performance, reduce faulty items, and prevent them from reaching customers. No critical defects are accepted.

Critical defects are severe flaws making a product unsafe, non-compliant, unusable, or hazardous to health or the environment, potentially contaminating other inventory. Examples include mold, sharp objects, pest contamination, and missing, misleading or incorrect safety instructions or warnings.

During Inbound QC Inspection: The discovery of one or more critical defects during the quality control inspection of an incoming delivery will result in the immediate and automatic rejection of the entire delivery. The shipment will be returned to the Partner at their sole cost and expense.

During an Inventory Check: If a critical defect is found in stock that has already been accepted, we will immediately quarantine all units of the affected product. We reserve the right to return the entire quarantined stock to the Partner, also at their sole cost and expense.

Zalando reserves the right to change the AQL level and/or inspection procedure if deemed necessary due to Partner performance or business needs. In order to avoid failures of AQL which require a full inspection, there is a need to implement a Quality Assurance System in the supply chain.

Useful links:

• Annex III: Guidelines to Classification of Product Defects

• Annex VI: Mandatory Onboarding Conditions for new Partners

3.5 Product Labelling and Packaging

Partners are required to assess the legal labelling requirements and ensure that products comply with them. The requirements apply also to exhibition and photoproduction samples. Mandatory information must be prominently displayed on the product, appropriately sized, readable, and durable, remaining intact after opening. All labelled information must be affixed in the languages of agreed Zalando's sales markets. Information solely accessible via supplied internet links, is generally insufficient when not explicitly permitted.

Product labelling requirements:

• Affixed solely in the responsibility of the manufacturer

• Visible, legible and indelible, proportionate to the specification

• On the product or, to the packaging and accompanying documents

• If missing, incorrect, misleading, or misused, products shall not be sold

3.5.1 Product traceability information

Partners assess the applicable regulatory requirements for product identifiers and ensure their products comply with them. They must identify and trace their products throughout the lifecycle, and monitor any arising product issues. Product identifiers aid in narrowing down the impact of potential product issues.

Batch, Serial Numbers or other identification elements

Products must be marked with a batch or serial number, or other identification elements. Partners are required to track their products across the supply chain and provide traceability attributes of individual units.

EU address and contact details

Products must be sold solely under the responsibility of an EU responsible person. The EU responsible person must be marked with both the postal and electronic address on the product. Where the single contact point at which e.g. customers or market authorities can reach out to, differs from the EU responsible person’s postal and electronic address, the contact point’s address details must be additionally indicated on the product. Where this is not possible due to the nature of the product, the respective EU address and contact details must be affixed on the product packaging and/or accompanying documents:

• Name and postal address of the manufacturer/ importer/ responsible person, established in the European Union.

• Electronic contact address (email address or website*) of the manufacturer/ importer/ responsible person, established in the European Union. * ‘Electronic address’ means a single point of contact that enables the efficient redirection of digital communications to the appropriate service for consumers and market surveillance authorities. It serves as a direct interface for communications regarding product safety issues and must be either a web address leading to a digital contact form or an email address.

Zalando Importer Address

If no legal entity established in the European Economic Area (EEA), other than Zalando, is responsible for the affected products in the EEA, and if Zalando agrees with an affected Partner to act as the EU importer (thereby becoming the responsible person for the purchased items in the EEA), the Partner is required to label each individual product with the Zalando address prior to delivery, as follows:

Imported by:

Zalando SE Valeska-Gert-Str. 5 10243 Berlin, Germany

Email: askproductcompliance@zalando.de

Website: https://zalando.de

3.5.2 Safety Information and Warnings

Partners are required to assess the regulatory requirements and any additional need for instructions for use and warnings and ensure that products comply with such requirements and needs.

Instructions for use and warnings must be in the languages of agreed sales countries, they must be easily understood by consumers and end-users and offer comprehensive guidance for the proper use, maintenance, and disposal of the product. This includes all necessary information for safe use, covering assembly, installation, operation, storage, maintenance, care, and disposal.

3.5.3 Sorting and Disposal Information

Product waste

Partners are required to assess EU-wide and country-specific sorting and disposal requirements for waste, including associated labelling and registration requirements, and ensure that their products comply with such requirements. Sorting and disposal information shall not mislead consumers. Partners may be required to provide a copy of the assessment and registration certificate.

Triman logo

Triman logo and associated sorting information must be at least 1 cm x 1 cm, accompanied by language indication, packaging pictograms, and disposal instructions in French.

Packaging Waste

Packaging must display packaging waste identification codes and comply with additional national legislative requirements in relation to waste disposal labelling requirements such as for Italy, Spain, France, and Portugal (see below). All packaging (all primary, secondary and tertiary packaging), including primary product packaging, must be registered in the applicable national Extended Producer Responsibility (EPR) registries of the respective sales countries.

Möbius loop on Packaging

Triman logo on Packaging

Triman logo and associated sorting information must be at least 1 cm x 1 cm, accompanied by language indication, packaging pictograms, and disposal instructions in French.

Spanish Sorting Label on Packaging

Labels must indicate the container in which packaging waste must be disposed of (e.g. blue for paper, yellow for plastics, etc.), preferably in order to avoid confusion (but not necessarily) in Spanish.

Portuguese Sorting Label on Packaging

Labels must indicate the container in which packaging waste must be disposed of (e.g. blue for paper, yellow for plastics, etc.). The text must be in Portuguese.

3.5.4 Packaging Volume and Weight Information

The packaging of Partners’ must also comply with relevant manufacturing and composition requirements, as laid down in the EU Packaging and Packaging Waste Regulation. As such, Partners must ensure that the packaging they are using is limited by volume and weight to the minimum adequate amount to maintain the necessary level of safety, hygiene, and acceptance for the packed products and for the consumers i.e. product packaging must be reduced to the minimum necessary for its functionality.

3.5.5 Use of the claim “Reusable”

From August 2026 packaging can only be called reusable, if all of the conditions laid out in Article 11 of the PPWR are met. In particularly the following:

• Packaging has been conceived, designed and placed on the market with the objective to be re-used multiple times;

• it has been conceived and designed to accomplish as many rotations as possible in normally predictable conditions of use;

• It can be emptied or unloaded without causing damage to the packaging which prevents its further function and re-use.

Partners must ensure compliance with these requirements if the claim “reusable” is used for packaging. Zalando reserves the right to request the EU Declaration of Conformity (DoC) upon demand

3.5.6 Digital Product Passport Information (not yet obligatory)

The Digital Product Passport (DPP) aims to provide comprehensive information about the product, in order to promote transparency, responsible consumption, and make information available to every actor along the value chain of a product, including the producers, retailers, customers, repairers, and recyclers.

The DPP will create a “digital twin” of every product and will be the core data source for product data. The following information can be part of the DPP (please note, this is not an exhaustive list and more specific guidance on what information must be included will be issued in the near future).

Essential Information

The digital product passport shall include the following information:

1 Unique product identifier

2 Name and address of the manufacturer (and authorised representative)

3 Name and address of the economic operator responsible

4 Manufacturer’s DPP statement

5 Object of the digital product passport

6 Commodity code as defined in Regulation (EEC) No 2658/87

7 References to all Union law that the product is in compliance with

8 References to the relevant harmonised standards used

9 Manufacturer communication channel such as telephone number, electronic address or a dedicated website section

10 Reference of the digital product passport service provider

The digital product passport may include the following information:

1 Safety information and warnings

2 Instructions of use

3 Materials, substances and fragrances present and under specific labeling requirements

4 The CE marking

5 DPP replacement statement of the EU Declaration of Conformity

Even if the DPP is not obligatory yet, it is expected to come into force in 2027 and will then be prohibited to market products without a DPP available. Therefore, early preparation for its requirements and data will ensure its compliance once it comes into force.

3.6 Compensation for Defective Goods

Partners must adhere to the QAM and ensure products comply with assessed requirements. In this context, Partners also commit to indemnify Zalando for direct damages and costs resulting from non-compliance. Zalando reserves the right to apply contractual fees outlined in the table below and may further penalise Partners who attempt to supply non-compliant products.

Following cases, the list is not exhaustive, result in product non-compliances and a chargeback or the affected products:

• Product recalls** / Safety warnings

• Non-A Grade*** Deliveries (e.g. damaged goods, mouldy goods)

• Missing mandatory Article Master Data Sheet (AMD Sheet)

• Missing, misleading or incomplete labelling/marking (e.g. missing CE-mark)

• Direct losses and damages from not being able to market the delivered goods

Associated costs are based on the actual purchase price, administrative and operational costs associated with the process including cost for processing communication to the end customer and, if applicable, cost of inventory check.

A detailed list is available here:

**Please note that, in case of legal failures a recall from end users must be conducted for the failed products. Regarding returned units from customers due to recalls, Zalando reserves the right to handle the stock at its own discretion unless otherwise agreed. All Fees of handling these items (e.g. return to partner) is going to be charged to Partners

Zalando`s product safety teams require return labels from Partner Program to execute the customer communication about non-compliance. Also, a full refund to the customer is needed for returned items. Unless otherwise agreed, the partner is responsible for tracking returns & refunds from the customer

***A-grade deliveries are delivery/items that meet the highest standard of quality, labelling/ marks, performance and conditions.

4. Product-specific requirements

4.1 General Clothing and Textile Products

Partners must assess and ensure compliance with additional regulatory requirements for clothing and textile products in agreed sales markets. Textile products—such as clothing, furniture coverings, mattress coverings, and tents—are subject to the Textile Fibre Regulation if they consist of at least 80% textile fibers by net textile weight.

Key Chapters and Requirements for General Clothing and Textile Products

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.1 General Clothing and Textile Products

• Annex I: Product Restricted Substances List

• Annex IV - Testing of children`s products

Risk Assessment

The risk assessment of clothing in smaller sizes shall address vulnerable user groups, such as children, even if not marketed for children, as outlined in the table below.

Product Testing, Certification and Inspection

Clothing intended for children must be free of metal and safety pins, including for label attachments, to reduce injury risk. Partners must also ensure children's clothing complies with relevant standards in Annex IV - Testing of children`s products to mitigate the identified risks.

Additional Labelling Requirements

Textile fibre composition label

The textile fibre composition label shall meet the following criteria, including but not limited to:

• Only fibres names, which are officially listed in (EU) No 1007/2011 shall be used.

• Trademark or company names may be placed before or after fibre descriptions.

• ‘100%’, ‘pure’, or ‘all’ labels apply to single fibre type products.

• Multifibre products list fibres by descending weight.

• Fibres under 5% can be labelled ‘other’ if they don’t exceed 15% of total weight; total is 100%.

• Multi-component textiles must list each component's fibre content.

• Components under 30% of total weight (excluding main linings) don’t require separate labelling.

• For unified products, label only one item if both share the same composition.

• Label “Contains non-textile parts of animal origin” for containing feather, bone, leather, pearl or horn

Care Instructions

Care labels shall be in accordance with standard EN ISO 3758:2023. They offer essential guidance for washing, bleaching, drying, ironing, and professional care of textiles.

Made in labels

Made in labels are voluntary and indicate a product’s true country of origin, ensuring no misleading claims, such as suggesting EU origin for items made outside the EU.

4.2 Clothing with UV Protection

Partners must assess and ensure compliance with additional regulatory requirements for UV-protective clothing in the agreed sales markets. Such clothing, intended to protect against natural sunlight (including partial or full-body coverage), falls under the Personal Protective Equipment (PPE) Regulation (see 4.8 Body Protection Gear) and must carry CE marking (see Annex II: CE-Marked Products). Additionally, UV-protective clothing is subject to the Textile Labelling Regulation (see 4.1 General Clothing and Textile Products) and must meet all general product and packaging requirements.

Key Chapters and Requirements for Clothing with UV protection

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.1 General Clothing and Textile Products

• 4.2 Clothing with UV Protection

• 4.8 Body Protection Gear

• Annex I: Product Restricted Substances List

• Annex II: CE-Marked Products

Due Diligence

Product Testing

In absence of harmonised standards, products must comply with essential requirements. Clothing with UV protection must be tested against EN 13758-1:2007-03. Zalando additionally recognizes testing according to UV STANDARD 801 or AS/NZS 4399.

Additional Labelling and Technical Documentation

Labelling, assessment and documentation as per Annex II: CE-Marked Products

• The CE mark affixed by the manufacturer.

• The DoC by the manufacturer or the authorised representative.

UPF rating label

The Ultraviolet Protection Factor (UPF) rating must be clearly stated. This rating indicates how effectively the fabric blocks ultraviolet (UV) radiation. For example, a UPF rating of 50+ means that the fabric allows only 1/50th (2%) of UV radiation to pass through it.

Care label

The care instructions shall specify the maximum number of wash cycles until the product loses UV protection abilities and provide guidance on identifying signs of ageing.

Warnings

There should be appropriate warnings and instructions for use, such as:

• "Only covered areas are protected."

• "Protection may be reduced if the fabric is stretched, wet, or worn out."

• "The protection offered by this item may be lessened with use, age, and if washed or cared for incorrectly."

4.3 Infant and Toddler Products

Partners are required to assess additional regulatory requirements for infant and toddler products and ensure compliance with such requirements in agreed sales markets.

Infant and toddler products, such as dummy chains, pacifiers, changing mats, cot bedding, bibs, and harnesses, specifically designed for children under the age of 3, may be subject to the Textile Labelling Regulation and food contact products in addition to the legislation that applies to all products and packaging.

Key Chapters and Requirements for Infant and Toddler Products

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.1 General Clothing and Textile Products

• 4.3 Infant and Toddler Products

• Annex I: Product Restricted Substances List

• Annex IV: Testing of children’s products

• Annex V: Testing of Infant and Toddler Products

Vulnerable user groups

Risk Assessment

When assessing the safety of infant and toddler products, it's essential to consider various risks. These risks may include the potential for injury, choking, strangulation, suffocation, chemical contamination, and other health hazards.

Product Testing

Infant and toddler products must be free of metal and safety pins to be used for any attachments such as labels, to prevent injuries. Additionally Partners are required to ensure that infant and toddler products are tested against applicable standards (see Annex V: Testing of Infant and Toddler Products)

4.4 Travel Goods, Saddlery and Leatherwear

Partners are required to assess additional regulatory requirements for travel goods, saddlery and leatherwear and ensure compliance with such requirements in agreed sales markets.

Travel goods, saddlery and leatherwear, such as bags, backpacks, belts and suitcases, are subject to the general legislative requirements applicable to all products without exception.

Key Chapters and Requirements for Travel Goods, Saddlery and Leatherwear

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.3 Travel Goods, Saddlery and Leatherwear

• Annex I: Product Restricted Substances List

Specific labelling requirements

Prohibited Marketing Claims

For saddlery and travel goods, non-animal materials may be labelled optionally but must not mislead. Use “artificial” as a prefix; terms like “faux”, “vegan” or “synthetic leather” are not allowed. Non-textile animal parts must be declared. Optional claims or symbols may be used if permitted or licensed.

Permitted Terms for Leather:

• Full grain leather: Leather with the original grain surface intact, not polished, de-grained, or split.

• Dyed leather and hides: Tanned animal skins with largely intact fibre structure; hair or wool may be removed. Coatings must not exceed 0.15 mm. Reconstituted hides are excluded.

• Coated leather: Leather with a surface coating or lamination thicker than 0.15 mm but not exceeding one third of the total thickness.

• Split leather: Leather in which the grain layer has been completely removed.

4.5 Footwear

Partners must assess and ensure compliance with additional regulatory requirements for footwear in the agreed sales markets. Footwear—including shoes, boots, sandals, and slippers—must meet the Footwear Labelling Directive and all general product and packaging regulations.

Key Chapters and Requirements for Footwear

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.5 Footwear

• 4.7 Electrical Appliances and Batteries

• Annex I: Product Restricted Substances List

• Annex II: CE-Marked Products

• Annex IV - Testing of children's products

Due Diligence

Risk Assessment and Testing of Children’s Shoes

The risk assessment and testing methods for children's shoes, including smaller sizes unless designated for adults, must demonstrate compliance with Annex IV.

Testing of High Heels

Pumps: Footwear with heels of more than 5 cm in height must be tested against ISO 22650/DIN EN 12785 or an equivalent standard.

Labelling Requirements

Material Declaration

Footwear must have a material label showing main parts (upper, lining and sock, outer sole) via pictograms in accordance with the Footwear Labelling Directive:

• Three main components (upper, lining & sock, outer sole).

• Declaration shall cover at least 80% of each part’s surface area or volume.

• If no material reaches 80%, list the two main materials.

4.6 Jewellery

Partners must assess and comply with additional regulatory requirements for jewellery in the agreed sales markets. Jewellery, including rings, necklaces, bracelets, earrings, and brooches made from precious metals, gemstones, or other materials, must meet specific labelling requirements beyond general product and packaging regulations.

Key Chapters and Requirements for Jewellery

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.6 Jewellery

• Annex I: Product Restricted Substances List

Sales Restrictions

Deviating from the usual requirements, jewellery containing precious metals and gemstones are prohibited to sales countries Netherlands, Czech Republic, United Kingdom, Romania, Switzerland, Lithuania.

Recycled Jewellery

Items from the same recycled casting are treated as one batch and must meet the same safety standards as conventional jewellery.

Specific labelling requirements

Hallmarking

The marking of precious metals is regulated by national legislation. Jewellery with gemstones and precious metal alloys, may require an obligatory hallmarking of a national assay office. The hallmark stamp on the jewellery, shall be in a location that does not detract from the design or aesthetic.

Fineness

The marking of the purity of precious metals is regulated by legislation. The fineness of platinum, gold, palladium, and silver articles, as certified by hallmarks, is determined as follows and must not fall below the specified limits in order to be marketed as a precious metal alloy. If the fineness is not specified, the product is assumed to be made to 100% of the pure precious metal. The fineness stamp on the jewellery, shall be in a location that does not detract from the design or aesthetic.

Prohibited marketing claims

Zalando prohibits literal claims and material descriptions such as "nickel free," as this implies the complete absence of nickel. Jewellery must not be labeled as "nickel free" if even trace amounts of nickel are detectable through chemical testing.

In addition, Zalando prohibits not only literal claims but also article titles and color descriptions that include the terms “platinum,” “gold,” “palladium,” or “silver” without an appropriate qualifier—either the suffix “-colored” for color descriptions, or an indication of the metal’s fineness in brackets (e.g., “gold (585)”) to denote purity. If the fineness is not specified, the claim is understood to imply a fineness of 999, suggesting that the product is made of 100% pure precious metal.

Care instructions

Zalando expects that all jewellery is equipped with sufficient care instructions.

4.7 Electrical Appliances and Batteries

Partners must ensure compliance with additional regulatory requirements for electrical and electronic equipment (EEE) in the agreed sales markets. EEE, including electronic beauty devices, light sources, and mobile media equipment, must adhere to the LVD, RoHS, and EMC Directives. EEE with digital elements and radio capabilities, such as smartwatches, fitness trackers, mobile phones and Bluetooth speakers, must comply with the RED Directive and Cyber Resilience Act (effective from September 11, 2026). Batteries, whether included in the EEE or sold separately, must comply with the Batteries and Waste Batteries Regulation.

In addition, partners must adhere to the Common Charger requirements mandated under the Radio Equipment Directive (2014/53/EU) and ensure all plugs and sockets comply with the national regulations of agreed sales markets where the product has been made available.

Key Chapters and Requirements for Electrical Appliances and Batteries

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.7 Electrical Appliances

• Annex I: Product Restricted Substances List

• Annex II: CE-Marked Products

Due Diligence

Electrical safety

Electrical testing primarily evaluates the safety and performance of electrical components and systems within products. Key parameters include insulation resistance, electrical continuity, and protection against overcurrent and overvoltage. These tests aim to prevent electric shock, fires, and other hazards, while also ensuring accurate labelling and user instructions.

Materials used in electronic products

Business partners are required to assess and comply with all regulatory requirements applicable to electronic articles, and ensure that all electronic products meet the environmental and safety standards before sale or distribution in relation to restricted substances under the Restriction of Hazardous Substances (RoHS) Directive.

Battery removability and replaceability (effective from 18 February 2027)

Partners offering products with portable batteries must ensure the product design permits the end-user to easily remove and replace the battery at any time during the product’s lifetime. Portable batteries must be readily removable and replaceable using commercially available tools, without requiring specialized technical knowledge or the application of heat or solvents for disassembly, unless the battery is specifically designed to be removed only by independent professionals for safety or medical reasons. Clear and comprehensive instructions, including safety information regarding potential hazards and handling, must be provided with the product and made available online, detailing the safe removal and replacement process. Furthermore, compatible batteries must be made available as spare parts for a minimum of five years after the last unit of the product model has been placed on the market, offered at a reasonable and non-discriminatory price. Specific exemptions to end-user removability are only permitted where a continuous power supply is strictly necessary for safety, performance, medical purposes, or data integrity.

Additional Labelling and Technical Documentation

Labelling, assessment and documentation as per Annex II: CE-Marked Products

• The CE mark affixed by the manufacturer.

• The DoC by the manufacturer or the authorised representative.

Sorting and Disposal Information

Crossed out wheeled bin

Electrical appliances and Batteries must display the crossed-out wheeled bin symbol accompanied with disposal and sorting information for the waste of batteries (WBA). EEA-Partners must register and report WBA to national registers in Zalando's sales markets and provide the registration number upon request. Batteries containing Hg, Cd, or Pb must display the corresponding chemical symbols.

Labelling of Energy-Related Products

Example: Energy Label

Partners assess if an energy label is required for electronic equipment, ensure it is affixed, and provide digital versions for web display. The label, ranging from A (most efficient) to G (least efficient), must be at least 36mm x 75mm or 20mm x 54mm. It includes a QR code linking to the EPREL database, energy efficiency classes, specific rating, energy consumption, non-energy parameters (e.g., noise, water use, capacity), and a reference to the relevant regulation.

Durability Label on Batteries

Batteries should be valid for at least 12 months upon receipt and have a removable seal, with the expiry date clearly marked.

Capacity label on Batteries

All portable rechargeable batteries must have a capacity label. For NiCad, Ni-MH, and lithium batteries, capacity is shown in mAh (integer) or Ah (decimal). For lead-acid batteries, capacity is indicated as a decimal in Ah. Power tool batteries are excluded.

4.8 Body Protection Gear

Partners must assess the relevant regulatory requirements for body protection gear and ensure compliance with them, in addition to the outlined requirements in the QAM.

In addition to general legislation that applies to all products and packaging, body protection gear, such as helmets, protective gloves, sunglasses, shin guards, ski and swimming goggles, is subject to the PPE Regulation. Under PPE category classification are also falling interchangeable components for equipment which are essential to its protective function.

Key Chapters and Requirements for Body Protection Gear

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.7 Electrical Appliances and Batteries

• 4.8 Body protection gear

• Annex I: Product Restricted Substances List

• Annex II: CE-Marked Product

Additional Labelling and Technical Documentation

Labelling, assessment and documentation as per Annex II: CE-Marked Products

• The CE mark affixed by the manufacturer.

• The DoC by the manufacturer or the authorised representative.

Essential information

• The pictogram indicating the user instructions

• Instructions for storage, use, cleaning, maintenance, servicing and disinfection

• Restriction of use as per applied harmonised standard other restrictions deemed appropriate

• Performance data, level or classes of protection

• Where applicable:

• Accessories and the characteristics of the appropriate spare parts

• Different protection classes and their corresponding usage limits.

• The expiration date of the PPE or its components.

• the type of packaging suitable for transport

• Address details and identification number of the notified body

• The instructions for for care and cleaning

• Description of significance of any markings

• The risk against which the PPE is designed to protect

• The reference to the PPE Regulation and applicable EU harmonisation legislation

• The references to harmonised standard(s), or other technical specifications

• A copy of the EU Declaration of Conformity, or the internet address where it can be accessed

Additional Information for Sunglasses

• Identification of model

• Name and address of the manufacturer

• Reference to EN ISO 12312 standard

• Type of filter, if photochromic and/or polarising

• Number of the filter category marked preferably on the frame of the filter

4.9 Toys

Partners must assess the relevant regulatory requirements for toys and ensure compliance with them, in addition to the outlined requirements in the QAM.

Toys are subject to the toys safety Directive as well as general legislation, which applies to all products and packaging (see 2.3 Legislative Reference).

Key Chapters and Requirements for Toys

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.9 Toys

• Annex I: Product Restricted Substances List

• Annex II: CE-Marked Product

Sales Restriction

Deviating from the general sales scope, toys are restricted to following countries:

Due Diligence

Packaging Requirements

Packaging materials can pose suffocation risks to children, so all toy packaging must meet EN 71-1 safety standards for mechanical and physical hazards. Packaging with play value or intended as a toy for children under 14 must also comply with EN 71 standards for safety.

• Minimum thickness of 40µm

• No drawstring closures

• Minimum of 4 air holes of minimum 4mm diameter, spaced on a 30mm grid

• Safety warning on the polybag

Materials used in toys

Business partners must ensure that all toys comply with applicable regulations, including the chemical requirements outlined in the EU Toy Safety Directive, Annex II (III.), Appendices A, B, and C. CMR substances (those that may cause cancer, genetic mutations, reproductive harm, or harm to an unborn child) are prohibited in accessible toy parts beyond the limits set by the Regulation on Classification, Labelling, and Packaging, unless deemed safe through scientific evaluation. Nineteen heavy elements, such as mercury and cadmium, are restricted in accessible parts of toys, as specified by the Toy Safety Directive. Additionally, 55 allergenic fragrances are banned, with some exceptions; 11 additional fragrances may be used if listed on the label and compliant with specific requirements.

Additional Labelling and Technical Documentation

Labelling, assessment and documentation as per Annex II: CE-Marked Products

• The CE mark affixed by the manufacturer.

• The DoC by the manufacturer or the authorised representative.

Instructions for use and warnings

Age-based warnings enhance children's safety by guiding parents to choose suitable toys, reducing accidents. Toys are tested for age-specific risks, and clear age guidelines are required on packaging. Warnings should specify hazards, like small parts or choking risks, while age recommendations alone are sufficient if no hazards exist.

4.10 Cosmetic Care

Partners must assess and ensure compliance with additional regulatory requirements for cosmetic products in agreed sales countries. Cosmetic articles, such as skincare products, lipsticks, shampoos, and perfumes, are defined as “cosmetic products” under Article 2(a) of the Cosmetic Products Regulation. These products are subject to the Cosmetic Products Regulation and general product and packaging legislation (see 2.3 Legislative Reference).

Key Chapters and Requirements for Cosmetic Products

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.10 Cosmetic care

Sales Restriction

Deviating from the general sales scope, the sales are restricted to the following countries:

Due Diligence

Good Manufacturing Practices

All cosmetic products must be manufactured according to ISO 22716 Good Manufacturing Practices (GMP) across the production and supply chain and maintain consistency in formulation and quality across batches.

Materials used in cosmetic products

Business partners are required to assess and comply with all additional regulatory requirements applicable to cosmetic products, ensuring that these products meet the chemical safety standards set forth in specific EU legislation. This includes adherence to the Cosmetic Products Regulation, which mandates comprehensive safety assessments and ensures that cosmetic products are safe for consumers under foreseeable conditions.

Packaging sealing

All openings of beauty and cosmetics products must be sealed to prevent contamination, oxidation, and tampering. Unbroken seals indicate unopened products suitable for resale. Seals should be highly adhesive and damage upon removal. For products in cartons, the carton must be sealed visibly on the outside. Seals should not cover essential product information.

Prohibited Marketing Claims

Statements about a cosmetic product's properties, benefits, or effects must meet six criteria: legal compliance, truthfulness, evidence, honesty, fairness, and promoting informed choices. Partners must provide evidence to support claims. Claims suggesting medical benefits classify a product as medicinal and are not allowed.

Labelling

Product Identifiers

• A responsible person in the Union market.

• The batch number or identification reference

• The country of origin, if the product is manufactured outside the EU

Ingredients Declaration

Ingredients must be labelled on the external side of the packaging with the term ‘ingredients’. The ingredients listed follow the names of the International Nomenclature of Cosmetic Ingredients (INCI names) without translation and are arranged in descending order of weight at the time of addition.

Nanomaterial ingredients are explicitly marked with 'nano' in brackets. Colorants, excluding hair dyes, may be listed after other cosmetic ingredients. In decorative cosmetic ranges with multiple shades, all non-hair dye colorants may be listed with 'may contain' or '+/-' symbols, using CI (Colour Index) nomenclature where applicable.

Information for use and warnings

Reference to enclosed or attached information

Must be on both the primary container and secondary packaging. If this is not possible, the information must be provided with an enclosed leaflet indicated by a referencing symbol.

Product function information

Printed on the container and packaging unless it's easily deduced from factors like its presentation (such as shape or size), name, trademarks, claims (including accepted foreign terms like "waterproof mascara"), or accompanying visuals like pictures or logos.

Nominal content mark

The ℮-mark, indicating nominal weight or volume, is required on packaging except for containers under 5 ml or 5 g, free samples, and single-use packs. Content disclosure isn't needed for pre-packaged items sold in fixed quantities if the count is visible on the packaging or if items are usually sold individually.

Minimum Durability Label

Based on finished product stability studies, two labelling situations apply.

Date of minimum durability (DOMD)

For products with a durability of 30 months or less, indicate the Date of minimum durability (DOMD) with the 'hourglass' symbol or 'Best before the end of' followed by MM/YYYY or DD/MM/YYYY. If the date isn't next to the symbol or phrase, its location must be clearly explained.

Period-after- opening (PAO)

For products with a durability over 30 months, indicate the Period-After-Opening (PAO) with an 'open jar' symbol, accompanied by the period in months or years, usually shown as “x M”. This can be located inside or outside the symbol.

Single use plastics symbol

Single-use plastic products must display the 'plastic in the product' symbol. This applies to items like sanitary towels, tampons, tampon applicators, wet wipes, and other relevant products, marked on either packaging or the product itself.

Product Documents

Product Information file (PIF)

A complete product information file (PIF) must be available before dispatch of the product. The PIF shall include all the particulars relating to identity, quality, safety for human health and the proof of all effects claimed for the cosmetic product. A cosmetic product safety (CPSR) report is included in the PIF.

Wholesale: EEA-based suppliers selling products in non-EEA (e.g. Switzerland) markets must guarantee the availability of, and provide, complete technical documentation (e.g., PIF) for confidential compliance assessment by Zalando or a preferred third-party laboratory upon request.

Notification and Reporting

Pre-market notification

The EU responsible persons must issue a pre-market notification on the Cosmetic Products Notification Portal (CPNP). This must be done for each cosmetic product, regardless of its type. The responsible person must notify the product to the European Commission and is in charge of the cosmeto-vigilance and of the public access to information according to Art. 21 of the Cosmetic Product Regulation.

4.11 Non-Cosmetic Care/Mixtures

Partners are required to assess additional regulatory requirements for non-cosmetic care products and room fragrance and ensure compliance with such requirements in agreed sales countries.

Non-cosmetic care products that are mixtures, such as shoe care products and room fragrances are subject to the CLP Regulation as well as to general legislation, which applies to all products and packaging (see 2.3 Legislative Reference).

Key Chapters and General Requirements for Non-cosmetic Care

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.11 Non-cosmetic care products

• Annex I: Product Restricted Substances List

Due Diligence

Risk Assessment

Business partners are required to assess and comply with all regulatory requirements applicable to mixtures, and ensure that products meet the classification, labelling, and packaging requirements under CLP Regulation before sale or distribution. This is to ensure that any potential risks to health or the environment are clearly communicated to consumers, workers, and those involved in the handling and transportation of the mixture. Mixtures can consist of solids, liquids, or gases, and they retain the properties of their individual substances.

Labelling

Essential information

• Name, address and telephone number of the supplier(s);

• Nominal quantity of the mixture in the package;

• Trade name or designation of the mixture and

• Identity of all substances in the mixture contributing to the classification

• Where applicable:

◦ hazard pictograms

◦ signal word

◦ hazard statements

◦ precautionary statements

◦ supplemental information

Hazard Statements and Pictograms

Hazard pictograms signify particular dangers, along with the appropriate signal word "Danger" or "Warning". Additionally, provide essential safety information. Labelling is performed in accordance with CLP regulation and related guidance.

Prohibited Marketing Claims

Statements such as "non-toxic", "harmless", "environmentally friendly", "ecological", or any other statements indicating the absence of hazardous properties of substances or mixtures, or not consistent with their classification, should not appear on the label of a hazardous substance or mixture.

Notification and Reporting

Safety Data Sheets

Partners must provide a Safety Data Sheet (SDS) for products classified as hazardous under the CLP Regulation, as PBT or vPvB, or listed on the REACH candidate list. The SDS, prepared by a qualified individual, ensures health, safety, and environmental protections, follows a specified format, and must be retained for 10 years after the last product use.

The SDS must be provided free of charge in paper or electronic form for hazardous substances or mixtures upon first delivery and for non-hazardous mixtures on request if certain thresholds are exceeded. Suppliers must update the SDS promptly with new hazard information and share it with previous recipients within 12 months.

Notification to registries

Notification to Poison Centers (PNC) for mixtures and the CLP Inventory for substances is mandatory. Before marketing mixtures, they must be classified and labelled per CLP Regulation, with relevant information recorded in the Poison Centers inventory to ensure compliance and facilitate hazard communication.

If toxicological data meets CLP classification criteria, hazards must be indicated by assigning the mixture to a specific hazard class and category, encompassing physical, health, and environmental risks.

Manufacturers and importers must notify the European Chemical Agency (ECHA) C&L Inventory for substances and submit a Poison Center Notification (PCN) for each country of sale. The PCN must be formatted correctly and include the Unique Formula Identifier (UFI) code. For classification requirements and exemptions, refer to the CLP and REACH Regulations.

Partners must inform their relevant Quality Assurance team if any of the products being sold by Zalando require Poison Centre Notification and confirm for which markets they have carried out the Poison Centre Notification.

Additional Requirements for Scented Candles

Scented candles are subject to the CLP Regulation (EC) No 1272/2008 and standard EN 15494 as well as to general legislation, which applies to all products and packaging (see 2.3 Legislative Reference).

Product Testing

In absence of harmonised standards, products must comply with essential requirements. Candles must be tested against EN 15493 and:

• EN 15426:2018 - Test relating to the emission of soot from candles

• EN 15493:2019 - Fire Safety Test: flame height, combustion test, etc.

• EN 15494:2019 - Safety Labels

Instructions for use and warnings

Warnings must comply with EN 15494 in size, shape and content, accompanied by safety symbols in 5 mm minimum height. Note: the supplementary safety information symbols or texts shall be placed below and/or to the right beside the general warning sign. Borders are optional.

• General warning sign

• Never leave a burning candle unattended.

• Keep away from things that can catch fire.

• Keep away from children and pets.

• Use a heat resistance candleholder. Note: not applicable for floating candles.

• Use in a suitable bowl filled with water. Note: For floating candles only.

4.12 Crockery, Cutlery and Kitchenware

Partners are required to assess additional regulatory requirements for crockery, cutlery and kitchenware and ensure compliance with such requirements in agreed sales countries. If a product is intended to come into contact with food, or if it can reasonably be expected to do so, such as crockery, cutlery and kitchenware including food containers, plates, cups, drinking bottles, are subject to food contact material (FCM) legislation as well as to general legislation, which applies to all products and packaging (see 2.3 Legislative Reference).

Key Chapters and General Requirements for Crockery, Cutlery and Kitchenware

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.12 Crockery, Cutlery and Kitchenware

• Annex I: Product Restricted Substances List

Product Testing

Crockery, cutlery and kitchenware encompass a variety of materials, including plastic, ceramic, regenerated cellulose film. Compliance with both chemical limits and migration limits such as for bisphenol A, epoxy derivatives, N-nitrosamines, N-nitrosatable compounds, polyamide, and melamine is essential.

Food contact label

Food contact

Products must be labelled with the words "for food contact" or a specific indication of its intended use in all languages required, such as "coffee machine," "wine bottle," "soup spoon" or the appropriate symbol.

Additional Labelling and Technical Documentation

For articles intended for food contact, a so-called "Declaration of Compliance" and supporting documents must be provided upon request. These documents must demonstrate that the food contact materials comply with the rules applicable to them, alongside supporting documentation of test conditions and results, calculations, toxicological analyses, and safety evidence or logical reasoning that justifies the material's suitability for use.

Additional requirements for Pressure cooker

Partners are required to assess additional regulatory requirements for pressure cookers and ensure compliance with such requirements in agreed sales countries. Pressure Cookers are subject to the pressure equipment Directive and legislation applicable to food contact materials as well as to general legislation, which applies to all products and packaging (see 2.3 Legislative Reference).

Key Chapters and General Requirements for Pressure cooker

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.12 Crockery, Cutlery and Kitchenware

• Annex I: Product Restricted Substances List

• Annex II: CE-Marked Product

Labelling and Technical Documentation

Labelling, assessment and documentation as per Annex II: CE-Marked Products

• The CE mark affixed by the manufacturer.

• The DoC by the manufacturer or the authorised representative.

Essential labelling information

• Year of manufacture

• Essential maximum/minimum allowable limits

• Volume (V) in litres

• Test pressure (PT) in bar and date

• Safety device set pressure in bar

• Intended use

• Filling ratio in L

• Fluid group

Instructions for use and warnings

Warnings affixed to the pressure cooker accompanied by instructions for use, drawings, and diagrams to aid understanding. The information must highlight any risks associated with misuse and address specific safety design features.

4.13 Furniture

Partners must assess and ensure compliance with additional regulatory requirements for furniture and ensure compliance with such requirements in agreed sales countries. Furniture items, including chairs, tables, and closets for indoor or outdoor use, are subject to general legislation for all products and packaging (see 2.3 Legislative Reference).

Key Chapters and General Requirements for Furniture

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.13 Furniture

• Annex I: Product Restricted Substances List

Risk Assessment

Different furniture types have specific safety demands:

• Children's furniture is accompanied with proper instructions and warnings

• Outdoor furniture is assessed and tested for stability and durability.

Sales Restrictions

Furniture with electric motors, hydraulic or lever functions, are prohibited.

4.14 Floating leisure articles

Partners must assess and ensure compliance with additional regulatory requirements for floating leisure articles in agreed sales countries. Floating leisure articles for use on and in water, such as inflatable boats for rowing or paddling of near oval shape with or without transom, canoes and kayaks, inflatable boats made from plastic sheets or from reinforced materials, are subject to general legislation, which applies to all products and packaging (see 2.3 Legislative Reference).

Key Chapters and General Requirements for Floating leisure articles

• 2. Scope of Operation

• 3. Partner responsibilities

• 4.13 Floating leisure articles for use on and in water

• Annex I: Product Restricted Substances List

Due Diligence

Risk assessments and subsequent testing of floating leisure articles must demonstrate that products comply with the following non-harmonized standards:

• DIN EN ISO 25649-1:"Floating leisure articles for use in and on water - Part 1: Classification, materials, general requirements and test methods".

• DIN EN 25649-2"Floating leisure articles for use on and in water - Part 2: Consumer information".

• DIN EN 25649-3 "Floating leisure articles for use on and in water - Part 3: Additional specific safety requirements and test methods for Class A devices".

• DIN EN 25649-4"Floating leisure articles for use on and in water - Part 4: Additional specific safety requirements and test methods for class B devices”

• DIN EN 25649-5"Floating leisure articles for use on and in water - Part 5: Additional specific safety requirements and test methods for Class C devices".

• DIN EN 25649-6"Floating leisure articles for use on and in water - Part 6: Additional specific safety requirements and test methods for Class D devices".

• DIN EN 25649-7"Floating leisure articles for use on and in the water - Part 7: Additional specific safety requirements and test methods for Class E devices”

5. Disclosure

This document comes into effect immediately and is binding for the entire duration of the business relationship between the Partner and Zalando. It ensures that all agreed Partner obligations and Zalando's product standards are met. Changes or additions to this document do not require further written approval.

Zalando SE is responsible for the content of this document. Partners are obliged not to distribute this document to third parties without written consent from Zalando, with the exception of our partners' business partners engaged in the supply chain.

Some links in this manual direct to external websites. These links are provided for convenience and informational purposes only; they do not imply endorsement or approval by Zalando. Zalando assumes no responsibility for the accuracy, legality, or content of external sites or subsequent links. For questions regarding the content, please contact the external site directly.

6. Contacts

Contract-related inquiries

Please contact the responsible Partner Manager at Zalando. Your personal contacts will be happy to assist you with any questions you may have.

Quality assurance at Zalando

• Zalando Wholesale:

  productsafety-whs@zalando.de

  productquality@zalando.de

• Lounge by Zalando:

  productsafety@zalando-lounge.de

• Partner Program:

  partner-care@zalando.de

• Zalando Fulfilment Solutions:

  partner-care@zalando.de

Responsible for the content of this document

Zalando SE Corporate Product Compliance

Valeska-Gert-Straße 5 10243 Berlin Germany

Fon: +49 (0)30 20968 7000 Email: product_compliance@zalando.de

Annex I: Product Restricted Substances List & Zalando Chemical Policy

The industry is transparent about the fact that advanced chemistry is essential for making fashion and lifestyle items in our wardrobe more creative, colourful, comfortable, durable and affordable. However, it is also anticipated that hazardous chemicals will be selected responsibly to eliminate harm to consumers, environment and workers within the supply chain.

We believe that due to the scale of our fashion platform, we can make a significant contribution and impact by setting stringent standards and collaboratively work on achieving them with our Partners.

To control chemical compliance Zalando established a Product Restricted Substances List (PRSL) which specifies permitted limits of toxic and harmful substances. The PRSL was developed in line with legislative and regulatory requirements set by the EU Commission and by trading territories that Zalando operates within.

There is no way to prove that a product is compliant without it undergoing full testing.

All Zalando Brands and Partners are required to implement a robust chemical management system and due diligence testing to ensure compliance with Zalando Product Restricted Substances List (PRSL) and relevant international standards and legislation.

Product packaging

All product packaging as defined as such by the EU Packaging and Packaging Waste Regulation shall comply with Zalando Restricted Substance List as outlined before. Below matrix shall provide a guide on potentially relevant scope.

Migration limit from toy items

Category I: Compressed paint tablets, materials intended to leave a trace or similar materials in solid form appearing as such in a toy (e.g. the cores of colouring pencils, chalk, crayons); Pliable modelling materials, including modelling clays and plaster.

Category II: Liquid paints, including finger paints, varnishes, lacquers, liquid ink in pens and similar materials in liquid form appearing as such in the toy (e.g. slimes, bubble solution); Glue sticks.

Category III: Coatings of paints, varnishes, lacquers, printing inks, polymers, foams and similar coatings; Polymeric and similar materials, including laminates, whenever textile reinforced or not, but excluding other textiles; Paper and paper board; natural or synthetic textiles; Glass, ceramic, metallic materials; Other materials whether mass coloured or not (e.g. wood, fibre board, hard board, bone and leather).

Zalando strongly encourages all Brands and Partners to exceed requirements set in RSL and to promote best practices and continuous improvement. Zalando commits to provide you with support and guidance in exchange for transparency.

Annex II: CE-Marked Products

Partners are required to assess additional regulatory requirements for CE marked products and ensure compliance with such requirements in agreed sales markets.

Conformity Assessment: Products required to be affixed with a CE marking, undergo Conformity assessment, assessed by the products manufacturer. Its assessment needs to demonstrate that it meets all legislative requirements of applicable product legislation. Zalando recommends referring to ISO/IEC 17050-1:2004 - Conformity assessment in addition to applicable EU product legislation.

Declaration of conformity (DoC): As part of conformity assessment, the manufacturer or the authorised representative must draw up the DoC. The Declaration may follow a standard format provided in Annex III of Decision No 768/2008/EC and must be translated into English:

‘EU DECLARATION OF CONFORMITY’

1. No … (unique identification of the product)

2. Name and address of the manufacturer or his authorised representative:

3. This declaration of conformity is issued under the sole responsibility of the manufacturer (or installer):

4. Object of the declaration (identification of product allowing traceability. It may include a colour image of sufficient clarity to enable the identification of the product, where appropriate.)

5. The object of the declaration described in point 4 is in conformity with the relevant Union harmonisation legislation:

6. References to the relevant harmonised standards used, or references to the specifications in relation to which conformity is declared:

7. Where applicable: the notified body ... (name, number)… performed … (description of intervention)… and issued the certificate:

8. Additional information: Signed for and on behalf of: (place and date of issue) (name, function)(signature)

User Instructions

The results of the risk assessment should be reflected in the technical documentation and also in the manufacturer’s instructions and information so the user is able to estimate the risk reduction when using the product (in a quantitative or qualitative manner) under the foreseeable conditions of use.

CE mark

CE mark

The CE marking is a certification mark that indicates conformity with health, safety, and environmental protection standards for products. By affixing the CE marking to a product, a manufacturer declares that the product meets all the legal requirements for CE marking and can be placed in the EEA, UK and CH. The marking must be placed visibly and legibly on the product or, if not possible due to the nature or size of the product, must be affixed to the packaging and the accompanying document. Vertical dimension may not be less than 5 mm.

UKCA marking: The UK government (UK/ Great Britain: England, Wales and Scotland) extended the recognition of goods that meet EU requirements (including CE marking), indefinitely beyond 31 December 2024 for many products.

Annex III: Guidelines to Classification of Product Defects

Definition of Critical, Major and Minor product defects identified in Zalando’s Due Diligence Programs such as during product compliance checks and inbound deliveries that are subject to warehouse quality inspections.

Critical Defects

Critical defects cause products to lose their fit for marketability as they represent severe flaws that make products unsafe, unusable, or hazardous to human health and/or the environment, or formally non-compliant. These defects can pose risks to physical, mental, or social well-being. Examples include, but are not limited to:

Safety Hazards: Unsafe operation, presence of mold, or hazardous foreign objects (such as, but not limited to, metal fragments, staples, clips, or pins).

Biological Contamination: Evidence of insect or rodent contamination or infestation.

Regulatory Non-Compliance: Deviations from statutory product requirements, including missing, misleading, or incorrect user instructions, statutory markings, and labelling such as relevant safety information or mandatory warnings.

Critical defects found during an inspection, at the customer side or at inbound can trigger a complete inventory check of a product or delivery. If it is the case that the inventory check cannot be conducted by our internal inspectors as the defect could endanger health, Zalando reserves the right to quarantine the whole stock and return the whole delivery, at the Partners’ costs.

Major Defects

Major Defects are significant defects that adversely affect the product performance or visual appeal. If present, would highly likely lead to a return/complaint from the consumer and would result in product failure or discount (e.g. dirt spots in front of strong visible areas, broken or missing components, dysfunctional closures, etc.).

Minor Defects

Minor Defects are small, typically insignificant issues, not affecting the functionality or visual appeal of the product but is nevertheless a defect beyond defined quality standard. If evident, would most likely not lead to a return/complaint from the consumer (e.g. untrimmed thread, small dirt spots inside or on outsole).

Annex IV: Testing of children’s products

Annex V: Testing of Infant and Toddler Products

Annex VI: Mandatory Onboarding Conditions for new Partners

Partners must complete business unit-specific onboarding to gain business approval from operational compliance teams. This process assesses partners' capabilities to adhere to Zalando’s QAM.

If required to fulfil Zalando's due diligence obligations, partners will be asked to provide proof of individual product compliance prior to deliveries. No products will be placed on the market nor released for delivery before product compliance is sufficiently proven. In case multiple non compliances will be detected Zalando reserve the right to:

• Increase % share of technical documents required for submission,

• Terminate business relationships with repetitive offenders.

Even if Zalando verifies only a percentage of products each season, each Partner must have all technical documents available (see 3.2.1 Technical Files).

Costs associated with product testing necessary to demonstrate compliance are to be borne by the partner.

Detailed information on how to exchange technical product documentation will be shared alongside with a compliance check nomination.

The product compliance verification conditions detailed above are not applicable to Partner Program (PP) or Zalando Fulfilment Solutions (ZFS) partners.

Annex VII: Prohibition of EUDR-relevant Products

Effective from 30th December 2026, products falling within the scope of the EU Deforestation Regulation (EUDR) 2023/1115, as defined in Annex I of this regulation, are permitted under the Partner Program (PP) and Zalando Fulfilment Solutions (ZFS) only, whereas they are strictly prohibited under Zalando Wholesale (WHS) and Lounge. Examples of relevant categories, including but not limited to HS codes and commodity groups; these categories are strictly Prohibited. Excluding Bamboo, Rattan, Straw, Osier, or 100% Post-Consumer Recycled wood or paper.

* = Excluding Bamboo, Rattan, Straw, Osier, or 100% Post-Consumer Recycled wood or paper

If Zalando Wholesale (WHS), Lounge (Lounge) explicitly agrees to purchase products in scope of the EU Deforestation Regulation (EUDR), suppliers must strictly ensure:

• All products must be deforestation-free and legally produced.

• Suppliers (operators) must proactively provide valid Due Diligence Statement (DDS) reference numbers for every shipment. => Delivery documents must clearly link each DDS number to the specific products, quantities, and HS codes.

Zalando is legally prohibited from accepting or selling any goods that arrive without this mandatory compliance data.

Annex VIII: Upcoming legislative requirements

Legislation undergoes frequent updates, which we have compiled below for your reference. The upcoming legislative requirements in this Annex and associated legal requirements are not comprehensive.

PFHxA restriction Regulation (EU) 2024/2462

To protect human health and the environment by restricting the use of undecafluorohexanoic acid (‘PFHxA’) and PFHxA-related substances. These substances are subject to a ban on sale and use in various consumer product categories following specific transitional periods. A deadline of 10 October 2026 applies to clothing, footwear, accessories, leather, furs, hides, cosmetic products, and consumer mixtures such as waterproofing sprays. Subsequently, a deadline of 10 October 2027 is established for other consumer textiles, leather, furs, and hides.

Deforestation-free Products (EUDR) Regulation (EU) 2023/1115

Effective from 30 December 2026, it mandates deforestation-free supply chains. In December 2025, the European Union granted a second 12-month additional phasing-in period, making the law applicable on 30 December 2026 for large and medium companies and 30 June 2027 for micro and small enterprises.

Artificial Intelligence Acts (EU) 2024/1689

To ensure product safety and risk management for AI systems. Prohibitions on unacceptable risks and AI literacy requirements apply from 2 February 2025. Transparency rules for AI-generated content and obligations for most high-risk systems apply from 2 August 2026. Requirements for high-risk AI embedded in regulated products apply from 2 August 2027.

Packaging Regulation (EU) 2025/40

Replaces Directive 94/62/EC to introduce stricter, harmonized rules for waste reduction and circularity. While it entered into force on 11 February 2025, general application begins 12 August 2026, covering packaging minimization and substance restrictions. Subsequent phases include harmonized labeling by 12 August 2028, followed by mandatory recyclability and recycled content targets on 1 January 2030.

Toys Safety Regulation (EU) 2025/2509

Replaces Directive 2009/48/EC to strengthen rules on chemical and mechanical hazards. Entering into force on 1 January 2026, it introduces stricter bans on endocrine disruptors and PFAS, while establishing the Digital Product Passport (DPP). The general date of application is 1 August 2030, with a transition period allowing toys meeting the old Directive to be sold until this date and existing certificates remaining valid until 1 February 2031.

Registration, Evaluation, Authorisation and Restriction of chemicals (REACH) - Amendment of Regulation (EC) No 1907/2006 - Revision

Expected to progress through targeted amendments in 2026, it tightens restrictions on hazardous chemicals, including PFAS and endocrine disruptors. While the broad legislative overhaul remains under discussion, a final scientific opinion on the Universal PFAS ban is anticipated by late 2026, defining future transition periods and exemptions for consumer products.

Directive on the liability for defective products (EU) 2024/2853

Published in November 2024, this directive replaced the 1985 Product Liability Directive 85/374/EEC, modernizing the rules to cover new technologies like software and AI-powered products. The directive entered into force on 9 December 2024. Member States have until 9 December 2026 to transpose it into national law, at which point the new rules will apply to all products placed on the market.

Persistent Organic Pollutants (POPs) - Amendments of Regulation (EU) 2019/1021

Expected to introduce further environmental protections through upcoming listings and threshold reductions. New restrictions for MCCPs and LC-PFCAs are anticipated to enter into force in late 2026. Additionally, a stricter concentration limit for brominated flame retardants (PBDEs) in recycled materials will apply from 30 December 2027.

Classification, Labelling, and Packaging (CLP) - Regulation (EC) No 1272/2008

Amended by Delegated Regulation (EU) 2023/707 and Regulation (EU) 2024/2865, this update adds new hazard classes for endocrine disruptors and persistent substances. New mixtures must comply with these classification rules by 1 May 2026, the application of specific rules for online advertisements and distance-selling disclosures, alongside new formatting standards such as font size and line spacing, has been postponed via Regulation (EU) 2025/2439 and will now become mandatory on 1 January 2028. Existing mixtures already on the market have until 1 May 2028 for reclassification, with a final sell-through deadline of 1 January 2029 to clear remaining stocks.

Ecodesign for Sustainable Products Regulation (EU) 2024/1781

Establishes a framework for the Digital Product Passport (DPP) to enhance transparency for textiles, footwear, and furniture. A mandatory ban on destroying unsold apparel and footwear for large enterprises applies from 19 July 2026, followed by disclosure requirements for discarded products in February 2027. The first product-specific DPP requirements for textiles are anticipated for adoption in 2027, with full application expected by 2028 or 2029.

Regulation (EU) 2024/1328 as regards octamethylcyclotetrasiloxane (D4), decamethylcyclopentasiloxane (D5) and dodecamethylcyclohexasiloxane (D6) amending REACH

Cyclopentasiloxane (D5), in leave-on products: max 0.1% from June 6th, 2027; Cyclohexasiloxane (D6), in wash-off products: max 0.1% from June 6th 2026, in leave-on products: max 0.1% from June 6th, 2027

Regulation (EU) 2023/1545 amending Regulation (EC) No 1223/2009

Effective from 16 August 2023, it expands the list of fragrance allergens in cosmetic products for 56 fragrance ingredients.

Rolling List of (groups of) substances for restriction updating Annex I to the Restrictions Roadmap under the Chemicals Strategy for Sustainability SWD(2022) 128

Revised version 1 July 2024 under https://ec.europa.eu/docsroom/documents/60674

Regulation (EU) 2023/1542 on batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and repealing Directive 2006/66/EC

Effective from August 18, 2026, new labeling requirements covering producer data and substance content will apply, subject to the adoption of the relevant Delegated Acts. From February 18, 2027, batteries must feature a QR code and comply with mandatory removability and replaceability design standards for consumer electronics. Furthermore, from August 2028, batteries must meet defined performance and durability criteria. Partners must ensure that all relevant electronic articles align with these upcoming technical and design specifications.

Cyber Resilience Act (Regulation (EU) 2024/2847)

Published in November 2024, establishes mandatory cybersecurity requirements for hardware and software products with digital elements. The regulation entered into force on 10 December 2024. While the general application date for most obligations is 11 December 2027, certain provisions, such as the obligation to report vulnerabilities and severe incidents, will apply earlier, from 11 September 2026.

Food Contact Materials (FCMs) / Plastic Quality Amendment (Commission Regulation (EU) 2025/351)

Published in February 2025, this regulation amends the existing rules for plastic Food Contact Materials, introducing stricter purity requirements and new safety standards for reusable articles. It entered into force on 16 March 2025. Substances and intermediate materials must comply by 16 December 2025, and finished plastic articles placed on the market must comply by 16 September 2026.

Revision of Textile Labelling Regulation (EU) 1007/2011

Expected as a formal proposal in Q2 2026, this revision modernizes fiber composition rules to support the EU’s green and digital transition. Key updates include the introduction of the Digital Product Passport (DPP), mandatory disclosures for recycled content, and standardized sizing. Following anticipated adoption, a transition period is expected to make these new compliance obligations mandatory by mid-2028.