Define the finished product first. Have the responsible importer or adviser confirm classification, economic-operator duties, label language, chemical evidence, customs code, EORI, VAT and duty treatment for the actual SKU and shipment. This guide is general information, not legal, tax or customs advice, and it does not assert a CE-marking requirement.
1. Define what is being imported
A broad description such as “reusable hygiene textile” is not enough for product review or customs planning. Create a separate identity sheet for each SKU: intended use, product type, model, sizes, materials and fibre composition, construction or layer sequence, closures, accessories, care instructions, retail pack contents, product and artwork revisions, and country of origin. For a cloth diaper, identify shell and inserts separately; for a menstrual pad, map face, absorbent core, backing and fastening; for a wet bag, record its construction and intended use.
Do not choose a customs classification based only on another seller’s listing or a supplier’s shorthand. The importer and its broker should assess the actual goods and the relevant tariff nomenclature, using current official tools and, where appropriate, a binding decision process. Classification can depend on product nature, construction and use. Preserve the reasoning and the version of the product description used for the review.
2. Review the responsible economic operator and product safety
Ask who places the product on the EU market, who is named on the product or packaging where required, and who maintains product identification, safety information and records. Review the General Product Safety Regulation (GPSR) against the actual product, parties, selling arrangement and current official guidance. Determine whether any product-specific legislation or other obligations also apply. A product’s reusable nature does not settle its legal classification, and this checklist does not determine the responsible person for your transaction.
Prepare a technical file proportionate to the importer’s review: product description and identifiers, risk assessment inputs, material and component information, relevant test or supplier records, label and instruction artwork, traceability details and change history. Confirm how the EU responsible-party information and product identification should appear in the particular sales context. Check obligations for online offers as well as physical product presentation when relevant. Ask the importer’s compliance lead or qualified EU adviser to document the decision and any open points.
3. Check textile composition and Italian-language presentation
Regulation (EU) No 1007/2011 sets rules for textile fibre names and composition labelling. Compare the written composition with the exact fabric and finished SKU. Ask for each relevant textile component’s fibre names and percentages, and make sure the label does not use a generic material name where the regulated fibre name is needed. A catalogue description, sample photo or component certificate is not a substitute for composition information.
Review whether the product is within the regulation’s scope and how the label must be supplied for your buyer-to-business or consumer-facing route. For a consumer product in Italy, have the responsible party verify the required Italian-language information and presentation before printing; check the applicable official guidance and Italian rules rather than translating wording informally. Care and safety instructions, warnings, business contact details and online listing information may involve requirements beyond textile fibre labelling. Save the approved label file with its product revision and approval date.
For certificate claims, check the precise certificate holder, the scope, current validity and the SKU or material named. A component/material certificate does not automatically cover a finished product. Claims depend on the exact holder, scope, validity and ordered SKU. Do not infer that all products from one supplier are certified.
4. Request chemical evidence with its boundaries
Ask what evidence supports the buyer’s specific chemical-risk questions. For a report, match the sample identification to the material or finished construction, identify the laboratory and method, review the substances or restrictions considered, result, reporting limits where relevant, issue date and limitations. Determine whether prints, coatings, waterproof layers, colourways or other components differ from the tested sample. A general “REACH compliant” statement does not show which substances, restrictions, sample or version were considered.
Check the current ECHA information on REACH restrictions and determine with your technical adviser which requirements and evidence are relevant to the product and market. A test report is evidence only for its stated sample, method and scope; it does not automatically establish compliance of an untested finished SKU. Record accepted gaps and follow-up actions rather than implying that a broad category has been cleared.
5. Confirm EORI, customs, VAT and duties with official tools
For an import into the EU, establish which party lodges the customs declaration and whose EORI identifier will be used. The EU’s official EORI guidance explains the registration framework; the importer should check its own status and validate the number through the relevant customs authority. Confirm who acts as declarant or representative, the agreed Incoterm and named place, and which party handles clearance and import charges.
Ask the broker to confirm the tariff classification, origin, customs value basis, freight and insurance treatment, duty rate and any other applicable measures for the exact item. Use the European Commission’s Access2Markets My Trade Assistant and official EU customs guidance as starting points, then verify the details for the actual shipment with the competent authority or customs representative. Ask the importer’s tax adviser to confirm import VAT treatment, registration, deduction or accounting arrangements for its circumstances. Do not rely on a supplier’s estimate as a guaranteed landed cost; duty and VAT depend on transaction and classification facts and current rules.
Before goods leave, reconcile the commercial invoice, packing list and transport details: product description, SKU, quantity, unit and total values, currency, origin information, carton count, net and gross weights, consignee and shipment terms. The importer or broker should confirm which additional records are needed. Retain the final declaration and supporting records according to the importer’s recordkeeping requirements.
6. Approve samples and shipment details before bulk
Request a sample that represents the proposed SKU, material build, closures, label, care information and retail pack. Mark it with a version and compare it with the written specification. Record dimensions, materials, workmanship, pack contents and any agreed tests or acceptance criteria; do not convert a visual check into a performance claim. If the supplier proposes a substitute, treat it as a new version and repeat the relevant review.
For a freight comparison, provide destination postcode, number and dimensions of cartons when known, weights, preferred transport mode, delivery point and proposed Incoterm. Ask which charges are included and which remain for the importer or broker. Transit estimates are not customs-clearance guarantees. Agree how production, inspection, dispatch and document handover milestones will be reported.
Keep approved sample, purchase order, product specification, label artwork, document register, invoice and shipment records linked. If product or packaging changes after approval, assess whether the label, safety file, customs description or evidence review needs an update before dispatch. See sample approval before bulk production, European shipping inputs and the document pack guide.
Italy order readiness checklist
- Written SKU definition, intended use, origin and revision.
- Importer’s documented classification and GPSR/responsible-operator review.
- Fibre composition, label artwork and Italian-language review completed by the responsible party.
- REACH-related evidence matched to the exact material or finished-product sample and limitations recorded.
- Importer and broker confirm EORI, customs code, declaration party, VAT and duty inputs from official sources.
- Sample and packaging version approved; substitutions are recorded and reviewed.
- Incoterm, destination, carton data, shipping documents and record owners agreed.
Official sources
- Regulation (EU) No 1007/2011 on textile fibre names and labelling and Your Europe textile label guidance.
- European Commission GPSR summary and official regulation text.
- ECHA: substances restricted under REACH, Annex XVII.
- EU EORI guidance, Your Europe customs and import procedures and Access2Markets My Trade Assistant.
Important: This guide is general information, not legal, tax, customs or compliance advice. The importer must confirm current requirements for the exact product and transaction with competent authorities or qualified advisers. No CE-marking requirement or product-compliance conclusion is made here.