Export Marketing Survey: German Market for Textile and Clothing

The European Union’s Tacis Programme for Moldova 

Support to Export Promotion and 

Investment Attraction in the 

Republic of Moldova 

Export Marketing Survey: 

German Market for 

Textile and Clothing 

June, 2010 

Author: Jens Hauser 

This project is funded by 

the European Union 

A project implemented by 

GFA Consulting Group in consortium 

with IDI

This Project is financed 

by the European Union 

Support to Export Promotion 

and Investment Attraction in 

the Republic of Moldova 

EuropeAid/126810/C/SER/MD 

This Project is implemented by a 

Consortium led by GFA 

Consulting Group 

Table of Contents 

1 INTRODUCTION AND METHODOLOGY I 

2 MAIN FINDINGS – EXECUTIVE SUMMARY III 

3 OVERVIEW OF THE GERMAN TEXTILE AND 

CLOTHING MARKET 

V 

3.1 PRODUCTION v 

3.2 CONSUMPTION iii 

3.3 PRICES v 

3.4 TRADE - EXPORT and IMPORT vi 

4 MARKET ACTORS AND ENTRY IX 

4.1 Trade Channels and Market Actors ix 

4.2 Retail Structure and Trends x 

4.3 MARKET ACCESS REQUIREMENTS xi 

5 EXPORT OPPORTUNITIES AND OBSTACLES XIII










1 INTRODUCTION AND 

METHODOLOGY 

The following market survey has been produced within the framework of the 

European Commission project “Support to Export Promotion and Investment 

Attraction in the Republic of Moldova”. The project is implemented by a GFA 

Consulting Group led consortium. The project intervention areas are: 

Component 1 

Support to Ministry of Economy and Trade and 

its agencies in coordinating and improving 

Moldova’s export and investment promotion 

systems 

Component 3 

Support to Moldovan enterprises in accessing 

export development financing 

Component 5 

Investment Promotion 

Component 2 

Support to Ministry of Agriculture and Food 

Industries in enhancing its system of testing 

laboratories 

Component 4 

Export promotion 

Methodology 

The market survey provides Moldovan producers of textile products (clothing, 

outwear) with an overview on the German market for the respective products. 

Furthermore trade channels and market access requirements are outlined as well 

as major market actors in Germany. In addition, the market survey findings are 

matched to the Moldovan production and export capacity in order to give 

recommendations on export opportunities and obstacles. 

The survey starts with a general description of the German apparel market, 

outlining production and consumption of outerwear, as well as trends. The 

market description intends to provide a sectoral overview. At the end of the 

description the pricing and trade in the apparel sector will be highlighted. 

In the following trade channels and practice, as well as market access 

requirements will be presented. This chapter aims to provide Moldovan clothing 

producers with information on the common trade practice and logistical 

requirements of importers, as well as legal and technical requirements formulated 

by EU and German policy makers. 

Finally, using the information presented in the previous chapters, as well as 

information on the Moldovan garment sector, opportunities and obstacles for 

Moldovan producers will be formulated. 

The information presented in this market study is based on quantitative and 

qualitative data, attained via desk research and interviews. Quantitative data 

sources include CBI (Centre for Promoting Imports from Developing Countries), 

Statistisches Bundesamt, EUROSTAT, as well as data from the German apparel 

associations. Interviews with German market actors have been the source for the 

qualitative data. 

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2 MAIN FINDINGS – EXECUTIVE 

SUMMARY 

Production 

Consumption 

Import and Export 

Germany is the largest clothing and outerwear market in the EU with a total 

consumption of about 51 billion € in 2009. The German clothing industry is the 

second largest consumer industry, only excelled by the food and beverage 

industry. 

Germany is the 3 rd largest producer of clothing in the EU. For more than 30 years 

the German clothing sector is facing a far‐reaching structural change, mostly due 

to low‐cost competition from Asia. As a consequence most German manufactures 

have developed an outsourcing policy as part of their restructuring process. The 

clothing production has been relocate to countries with low overall manufacturing 

costs, while central functions like design, procurement and marketing are still 

based in Germany. Basically all German clothing manufactures have more or less 

turned into creative and flexible trading enterprises with external job order 

production. At the same time the German clothing companies orientated more 

towards foreign markets, nowadays having an export share of about 40%. 

The trend in production goes towards the purchase of finished goods, while inhouse 

and job order production abroad is getting less. The concept of Fast Fashion 

is a clear trend in the production of higher quality clothing. The concept implies 

shorter intervals between collections / fashion lines, which in turn means that 

smaller, quickly changing lots of clothes are produced. 

Germans spent less than 5% of their disposable income on clothing. Germany has 

an average price level for clothing in comparison with other EU countries. The 

market for clothing is becoming more mature and saturated, with abundance of 

producers and retailers offering fashionable clothes. 

German consumers are price sensitive and are mindful of a good price‐quality 

ratio. Furthermore there is a clear tendency towards individualisation of 

consumption, leading to differentiated customer request. 

The overall development of the market reflects the growing disparity between the 

different economic strata of German society, and the increasing number of poor 

and relatively poor German residents. Thus many German consumers with lower 

incomes seek low‐price clothes in a steadily growing discount sector. On the other 

hand, quality and convenience will become more important, and the youthful 

outlook of the older consumers will strengthen designer and sports labels. 

The men’s wear market is expected to become the most dynamic, driven by the 

increasing number of men who are fashion‐conscious. 

Germany is the largest importer of clothing in the EU, importing outerwear worth 

18 billion € in 2007. Imports account for 90% of all outerwear sold in Germany. 

67% of all imports derive from countries outside the EU. Leading exporters to 

Germany are China and Turkey. Import prices are under pressure and declined 

from 2005 to 2007. A further decrease is expected. 

Germany is 4th largest exporter in the world, which derives from the fact that 

German apparel producers, due to their strong brands in the upper market and 

premium segments, successfully penetrated foreign markets. This 

internationalisation (see also chapter on production) is documented by the fact 

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Market actors and 

retail 

Market access 

requirements 

Moldovan export 

opportunities and 

constraints 

that the clothing export quota has increased from 10% in 1970 to 44% nowadays. 

German apparel brands, in particular, have a strong potential in the growing 

markets such as Asia or Eastern Europe. Exports by Germany include to a big 

extends so called re‐exports – imported products, which are exported to other 

countries, mainly EU. It is estimated that about 35% of German clothing imports 

are re‐exported. 

The traditional functions of the different market actors are changing. There is the 

general trend of integration in the value chain, which means: 

• Forward Integration: more and more manufactures open their own brand 

stores (mono‐label) in order to control the point of sale (higher margins, 

better knowledge of consumer demand) 

• Backward Integration: retailers set‐up their own design departments and 

source supply with own buying departments or agents 

With regard to the retail business textile discounters and the non‐specialists 

(hypermarkets with strong non‐food component) as well as mono‐label stores 

have shown a remarkable growth. Also globally operating apparel retail chains like 

H&M or Zara have enlarged their market share. In turn the formerly strong 

independent retailers as well as the department stores have declined strongly. 

There are legislative (set by the EU and national government) and non‐legislative 

(set by the trading partner) market access requirements. With regard to 

outerwear these requirements are based on environmental, consumer health and 

safety, as well as on social concerns. There is no quality standard for clothing. 

Opportunities for Moldova include: 

• Proximity to EU market which allows to benefit from the Fast Fashion trend 

• Upgrading within the textile value chain, using income and contacts gained 

from contract work: from CMT to value added production 

• Explore niche markets, e.g. work with own agents on commission 

Obstacles Moldova face: 

• Limited investment capacity to upgrade production 

• Limitation of labour force and absence of design capacity 

• Missing business skills and contacts (e.g. sourcing) to upgrade within the 

value chain 

• Lack of sector support structure: efficient association, fashion centre and 

competence centre 

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3 OVERVIEW OF THE GERMAN 

TEXTILE AND CLOTHING 

MARKET 

The following pages provide an overview of the German market for textile and 

apparel, focussing on clothing. The pattern and trends in consumption are 

outlined, as well as the business and strategies of the German clothing companies. 

3.1 PRODUCTION 

Outline of the 

textile and 

clothing sector 

The German textile and clothing industry, characterised by mid‐sized companies, 

is the second largest consumer goods industry only excelled by the food and 

beverage industry. The turnover amounted to 19.2 billion € in 2008, with textile 

production accounting for approximately 58%, and clothing for 42% of the total. 

Basic Data of the German Textile & Clothing Industry 

Turnover 

(in Mio. €) 

Production 

(in Mio. €) 

Imports 

(in Mio. €) 

Exports 

(in Mio. €) 

Employees 

(number) 

2000 2006 2007 2008 Change 

2007 to 2008 

26.409 19.742 19.949 19.169 ‐3,9% 

16.375 12.820 12.863 12.213 ‐5,1% 

31.730 30.864 31.721 30.398 ‐4,2% 

18.943 21.395 22.618 21.833 ‐3,5% 

185.195 104.299 102.020 97.026 ‐4,9% 

Source: German Ministry of Economy, “Branchenfokus Textil und Bekleidung”, 2010 

In 2008 both, the textile and the clothing industry, recorded a decrease in 

production, turnover, employment and number of companies: 

Decrease in production, turnover, employment and number of companies 

Textile industry 

2007 2008 Change 

2007 to 2008 

Production (in billion €) 11.2 10.8 ‐3,4% 

Turnover (in billion €) 11.6 11.1 ‐4,5% 

Employees 68.152 65.155 ‐4,6% 

Number of companies 496 481 ‐3,2% 

Clothing industry 

Production (in billion €) 1.63 1.4 ‐16,5% 

Turnover (in billion €) 8.35 8.1 ‐3,1% 

Employees 33.624 31.871 ‐5,5% 

Number of companies 207 201 ‐2,9% 

Source: German Ministry of Economy, “Branchenfokus Textil und Bekleidung”, 2010 

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Structure of the 

German textile and 

clothing industry 

The following diagrams highlight the structure of the industry according to group 

of products 

Others 

18 

Others 

4 

Spinning 

8 

Workwear 

4 

Weaving 

Finishing / Processing 

Technical Textiles 

9 

17 

20 

Warp‐and weft 

Hosiery 

2 

7 

Non‐woven 

13 

Underwear 

13 

Ready made products 

15 

Outerwear 

69 

0 5 10 15 20 25 

0 10 20 30 40 50 60 70 80 

Clothing 

manufacturers 

Germany is the 3 rd largest producer of clothing 

the EU after Italy and France. The turnover of 

the German clothing industry amounted to 8.1 

billion € in 2008. The number of manufactures 

and employees in the clothing sector is in 

decline – from 1995 to 2006 minus 61% 

employees and minus 67% companies. The 

clothing business is geographically 

concentrated with 80% of all companies being 

situated in Baden‐Württemberg, Bavaria and 

North Rhine‐Westphalia. 

Germany’s leading OPT in EU 

Germany is the leading EU country 

with regard to OPT, accounting for 

42% of the total value of OPT in the 

EU. In 2007 the three main OPT 

import countries for Germany were 

Ukraine (141 Mo. €), Macedonia 

(128 Mio. €) and Bulgaria (100 Mio. 

€). It has to be noted though, that 

the proportion of OPT, compared 

to “normal” imports of clothing, is 

low 

Basically all German clothing manufactures have more or less turned into creative 

and flexible trading enterprises with external job order production. At the same 

time the German clothing companies orientated more towards foreign markets, 

nowadays having an export share of about 40%. 

Production and procurement strategy of clothing companies are: 

1) In‐house or job order production in Germany 

2) In‐house production abroad ‐‐ establishing own factories abroad or enter 

into joint ventures in low‐cost countries 

3) Job order production abroad ‐ Subcontracting, on basis of the following 

concepts: 

‣ Outward Processing Trade (OPT): most labour‐intensive work is 

relocated 

‣ Cut, Make and Trim (CMT): entire manual production is relocated, 

material purchase is held on to for efficiency and quality reasons 

‣ Free on Board (FOB): suppliers receive only product specifications 

(e.g. design, fabric), and then manages the production themselves 

4) Imports ‐ purchase of finished goods 

Structural change 

and business 

strategies 

For more than 30 years the German clothing sector is facing a far‐reaching 

structural change, mostly due to low‐cost competition from Asia. As a 

consequence most German manufactures have developed an outsourcing policy 

as part of their restructuring process. The clothing production has been relocate 

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to countries with low overall manufacturing costs, while central functions like 

design, procurement and marketing are still based in Germany. 

Besides outsourcing the following business strategies are applied: 

Branding & Quality • Most German companies turn towards the up‐market / higher 

quality / premium segment 

• In the up‐market segment branding is literally necessity: brand 

affinity and product quality are the most important factors 

when shopping for clothing 

• A strong brand helps a company to protect itself against lowcost 

competition, and allows to withstand the margin pressure 

from the retailers 

Internationalisation 

With regard to production: 

• optimisation of production and procurement, balancing 

between costs and reliability 

• global sourcing systems that search for cost effective place for 

production, which are then integrated in the value‐chain 

management 

With regard to sales and marketing: 

• Entry to and development of foreign markets, especially in 

Eastern Europe and Asia 

• Market entry often via own retail outlets (verticalisation) 

Production trends 

Vertical Integration 

• New trade channels: clothing companies establish own retail 

outlets 

• Broadening of the value chain, thus higher margins 

• Own experience at the “Point of Sale” allows companies to 

adjust collections closer to the consumers demand 

There is a constant pressure for adjustment on the clothing business. A further 

decrease in the number of manufacturing companies is expected. At the same 

time there is a clear movement towards the purchase of finish goods, while inhouse 

and job order production abroad is getting less. 

The concept of Fast Fashion is a clear trend in the production of higher quality 

clothing. The concept implies shorter intervals between collections / fashion lines, 

which in turn means that smaller, quickly changing lots of clothes are produced. 

According to the association “textile + mode” the German clothing industry is 

prepared for competition due to its strong brands and innovative design. 

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3.2 CONSUMPTION 

Germany is the largest clothing and outwear market in the EU with a total 

consumption of about 51 billion € in 2009. Thus Germany accounted for 19% of 

the total EU clothing and outerwear market, worth 268 billion €. 

Consumption of outwear in Germany, 2003‐2009, in € million 

Total outwear 

of which: 


accessories 

2003 2005 2007 Change 2003 

to 2007 in % 

50.54 49.91 50.86 +0,2% 51.10 

1.56 1.68 1.73 +2,8% 1.80 

Leather garments 487 442 455 ‐1,1% 500 

Total clothing 58.05 57.39 58.38 +0,1% 59.00 

Source: CBI Market Survey “Outwear Market Germany” 

2009 

(estimated) 

The average per capita spending for outwear in 2007 was 618€. Every German 

household 1 spent in average 888€ for outwear, whereas a family with 2 kids on 

average purchased outwear worth 1.452€. Germans, however, spent less than 5% 

of their disposable income on clothing. 

German outwear consumption by gender, 2003‐2009, in € million 

2003 2005 2007 Change 2003 

to 2007 in % 

Total outwear 50.54 49.91 50.86 +0,2% 51.10 

Women’s outwear 28.79 28.375 28.875 +0,1% 28,90 

Men’s outwear 15.01 15.11 15.35 +0,6% 15.00 

Children’s outwear (










Consumption trends 

Price-quality 

ration 

Individualisation 

of consumption 

Fast fashion 

Growing low-price 

segment 

Dynamic men’s 

wear market 

Increasing 

demand for plus 

size 

The market for clothing is becoming more mature and saturated, with 

abundance of producers and retailers offering fashionable clothes. 

German consumers are price sensitive and are mindful of a good price‐quality 

ratio. The consumer behaviour also tends towards “cross‐shopping”, meaning 

that the customer makes use of various sales channels (e.g. online‐shopping, 

discounter, single brand store). 

Furthermore there is a clear tendency towards individualisation of consumption, 

leading to differentiated customer request. Especially the sale of clothing 

accessories benefit from this trend, as many consumers rely on fashion 

accessories to embellish an outfit to distinguish them from others. 

The market saturation and trend individualisation of consumption is leading to 

“fast fashion” ‐ a rapid change of fashion collections . For instance, the average 

number of collections on sale in 2007 was 4,7 whereas in 2010 manufactures and 

retailers will present up to 6,8 collections (of which 80% are upmarket articles). 

The outwear market in wide spread, reaching from high price luxury and upper 

middle price segment (together approx. 20% market share) to low middle and 

very low price segment (approx. 50% market share). The overall development of 

the market reflects the growing disparity between the different economic strata 

of German society, and the increasing number of poor and relatively poor German 

residents. Thus many German consumers with lower incomes will continue to 

seek low‐price clothes in a steadily growing discount sector. On the other hand, 

quality and convenience will become more important, and the youthful outlook of 

the older consumers will strengthen designer and sports labels. 

The men’s wear market is expected to become the most dynamic, driven by the 

increasing number of men who are fashion‐conscious. This is one of the major 

factors, besides also demographic changes, to boost the growth of sports and 

leisure wear. 

Furthermore the demand for plus size / oversize clothing is expected to increase 

in the coming years. 

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3.3 PRICES 

The diagram below indicates the development of Germany’s consumer price index 

for clothing and shoes during the last decade. 

104 

103 

102 

101 

100 

99 

98 

97 

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 

Source: Statistisches Bundesamt 

Margins under 

constant pressure 

Import prices 

Germany has an average price level for clothing in comparison with other EU 

member states. Above the EU average are for instance the Scandinavian 

countries, the Baltic states, Austria and Italy. Whereas Ireland, UK, Czech Republic 

and France are below the average. 

The margins at various levels of distribution are influenced by several factors (e.g. 

volume of order, competition, product/market combination), therefore it is 

almost impossible to draw up a schedule of margins. Nonetheless, fact is that 

margins at all levels of the distribution chain are under constant pressure, due to 

increasing competition, integration and consumer demand for lower prices. 

The development of the average import prices for selected apparel products – 

shown in the following diagram – indicates the negative pricing development for 

producers. In fact import prices were 4,6% lower in 2007 than in 2005. A further 

decrease is expected, which will force German apparel companies to look for 

further low‐price sourcing opportunities abroad. 

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10,00 

9,50 

9,00 

8,50 

8,00 

7,50 

7,00 

6,50 

6,00 

5,50 

5,00 

4,50 

4,00 

3,50 

2005 2006 2007 

Cotton shirts 

(men) 

Cotton shirts 

(women) 

Lightweight tops 

(women) 

Cotton trousers 

(men) 

Cotton trousers 

(women) 

Cotton skirts 

3.4 TRADE - EXPORT and IMPORT 

Germany is the largest importer of clothing in the EU, importing outerwear worth 

18 billion € in 2007. From 2005 to 2007 imports on average increased by 7%, with 

a particular strong increase of knitted outerwear (+9%). There has also been a 

strong increase in cotton products, rather than man‐made fibers. Basically imports 

account for 90% of all outerwear sold in Germany. 

Imports of outerwear into Germany, 2003‐2007 in million € 

2003 2005 2007 

Total outerwear 16,880 16,814 17,984 

Knitted outerwear 6,795 6,981 7,608 

Woven outerwear 9,444 9,497 10,037 

Leather garments 441 336 339 

Source: CBI, “The outerwear market in Germany”, 2008 

67% of all imports derive from countries outside the EU. In particular imports 

from Asia grew by more than 20%, with China accounting for more than 60% of 

the growth. But also countries like India, Vietnam, Bangladesh, Pakistan and Sri 

Lanka increased their share. Leading exporters to Germany are China and Turkey. 

Leading suppliers of outerwear to Germany 2007 

Total outerwear 

1. China, 23% 

2. Turkey, 13% 

3. Bangladesh, 7% 

4. Italy, 5% 

Woven outerwear 

1. China, 28% 

2. Turkey, 8% 


4. Romania, 5% 

Source: CBI, “The outerwear market in Germany”, 2008 

Knitted outerwear 

1. Turkey, 20% 

2. China, 16% 


4. India, 4% 

German exports 

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Internationalisation 

of 

German apparel 

producers 

Germany is the 2 nd largest export of clothing in the EU, after Italy. In 2007 its 

exports amounted to 9.9 billion €, which makes Germany the 4 th largest exporter 

in the World (after China, Hong Kong, Italy). 

Exports by Germany include to a big extends so called re‐exports – imported 

products, which are exported to other countries, mainly EU. It is estimated that 

about 35% of German clothing imports are re‐exported. 

Germany positions as 4 th largest exporter in the world derives from the fact that 

German apparel producers, due to their strong brands in the upper market and 

premium segments, successfully penetrated foreign markets. This 

internationalisation (see also chapter on production) is documented by the fact 

that the clothing export quota has increased from 10% in 1970 to 44% nowadays. 

Also German exports have increased by 17% between 2005 and 2007. German 

apparel brands, in particular, have a strong potential in the growing markets such 

as Asia or Eastern Europe. 

At present German exports mainly go to EU countries and about 25% of the 

products are sent to destinations outside the EU. 

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4 MARKET ACTORS AND ENTRY 

The following section provides an overview of the functions of the relevant 

market actors in the clothing retail. Also the market access requirements – 

legislative and non‐legislative – are described. A list of important German market 

actors can be found in the annexes. 

4.1 Trade Channels and Market Actors 

The following diagram shows the trade channel structure with the different sales 

intermediaries. It is possible for a sales intermediary (e.g. importing 

manufacturer) to take over the functions of others, in order to improve 

competitiveness and sales margin (vertical integration). 

Outerwear Trade and Distribution Channels 

Exporting Manufacturers ‐ inside and outside EU 

Importing 

Wholesalers 

Importing 

Manufacturers 

Agents 

Importing Retailers 

Department 

Store 


Multiples 

Home 

Shopping 

Buying 

Organisations 

Non‐importing Retailers 

Source: CBI „Outerwear Market in the EU“ 

The functions of the different sales intermediaries between industry and retails 

are: 

Importing 

Wholesalers 

• Buying on his own account, the wholesaler takes title to the goods and is 

responsible for their further sale and distribution 

• Development of a successful working relationship between exporting 

manufacturers and a wholesaler or importer can lead to a high level of cooperation 

with regard to appropriate designs for the market, new trends, 

use of materials and quality requirements 

• Wholesalers cater both to the specialist shops and to the department 

stores and multiple chains 

• The trend of retailers to avoid pre‐ordering and rather sell from stock, is 

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Importing 

Manufacturers 

Agents 

(sales 

representatives) 

Importing 

Retailers 

reinforcing the wholesalers’ position 

• Have their own designers, apply various production and procurement 

strategies (see chapter on production) 

• Penetrate the retail business by opening own shops (vertical integration) 

• An independent intermediary between manufacturer and retail 

• In general the agent receives a commission from the manufacturer 

• More and more agents sell from stock, to meet short‐term demands. Stock 

forming occurs on consignment basis 

• Agents mainly work with brands 

Differing from the sales agent is the buying agent. The buying agent is 

located in supplying countries and acts on instructions of his client, mainly 

retail organisations 

• Bigger retail organizations import via their own buying / sourcing 

departments, and thus cut out intermediaries 

• They purchase finished products via direct imports (sourcing ready‐made 

products) from low‐wage countries and sourcing products made according 

to their own design (backward integration) 

There is the general trend of integration in the value chain, which means: 

• Forward Integration: more and more manufactures open their own brand 

stores (mono‐label) in order to control the point of sale (higher margins, 

better knowledge of consumer demand) 

• Backward Integration: retailers set‐up their own design departments and 

source supply with own buying departments or agents 

4.2 Retail Structure and Trends 

The following diagram illustrates the development of the market share of the 

different actors in the German apparel retail: 

100% 

90% 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

10% 

0% 

12% 

18% 19% 

39% 

34% 32% 

15% 14% 14% 

10% 9% 9% 

18% 16% 16% 

6% 9% 10% 

1999 2003 2005 

Textile discounters & non 

specialists 

Independent retailers 

Department stores 

Home shopping 

Clothing mutiples 

Verticals 

Remarkable is the growth of textile discounters and the non‐specialists 

(hypermarkets with strong non‐food component) as well as the rise of verticals 

(mono‐label stores). Also globally operating apparel retail chains like H&M or Zara 

have enlarged their market share. In turn the formerly strong independent 

10










Quick response to 

consumer demand 

retailers as well as the department stores have declined strongly, with the share 

of independent retails being only around 23% in 2007. 

The market conditions are in general in favour of those retailers who can respond 

to consumer demand more quickly and at lower cost. These companies (verticals 

and global retail chains) are particularly adept at understanding what consumers 

buy in real time and responding quickly to sales trends and customer feedback. 

The rise of the retail chains has consequences for manufactures as the chains try 

to limit their number of suppliers, and have a strong position in price negotiations 

and delivery conditions. 

There is the trend toward more collections per year (fast fashion), which implies 

for manufactures that they have to be able to respond quickly. 

4.3 MARKET ACCESS REQUIREMENTS 

Legislative 

requirements 

Market access requirements are set by the EU and national government 

(legislative requirements), and by the trading partner (non‐legislative 

requirements). With regard to outerwear these requirements are based on 

environmental, consumer health and safety, as well as on social concerns. There is 

no quality standard for clothing. 

Apparel manufactures exporting to Germany and the EU have to comply to a few 

mandatory, legislative requirements. The mandatory requirements for Germany 

are set in the: 

Textilkennzeichnungsgesetzt 

(textile labeling law) 

Bedarfsgegenständeverordnung 2 

(consumer goods regulation) 

• Manufactures and traders of textile products 

have to indicate the fibre used, as well as the 

percentage of the fibre (in relation to the weight 

of the final product) 

• The consumer has to be able to identify the raw 

materials the final product is made of 

• The official language of the importing country 

has to be used 

• The consumer goods regulation are in parts 

relevant for clothing 

• Certain dyestuff, flame retardants, formaldehyde 

and other chemicals are not allowed in clothing 

products 

Care‐labeling and washing instructions, as well as the country of origin marking 

are not mandatory. 

Another relevant EU ruling is REACH, the Regulation on Registration, Evaluation, 

Authorisation and Restriction of Chemicals. REACH applies to most chemical 

substances, whether on their own, in mixtures or used in products (e.g. clothing), 

that are manufactured or used in, or imported into, the EU in quantities of over 

one ton per annum. 

Companies and manufactures based outside the EU do not have direct legal 

obligations under REACH. But as their first tier customer (e.g. importer) may do 

2 Link to download the regulation: http://www.gesetze-im-internet.de/bedggstv/index.html. 

11










have obligations, exporting companies might be required to be compliant to 

REACH (e.g. documentation of chemicals used, etc.). 

Non-legislative 

requirements 

Besides the legal regulations, literally all of the potential business partners in 

Germany have their own, individual specifications and requirements, which 

should be met by the suppliers / clothing manufacture. These individual 

specifications focus on quality and business procedures, labeling, packaging, 

consumer safety, as well as environmental and social sustainability. The business 

requirements may include the following: 

Technical requirements 

Code of Conduct (CoC) 

(process related) 

Labels and certification 

(product related) 

The technical specification outline the product and 

production related demands of the business partner, 

and can include the following: 

• Product specification (design, fibre to be used, etc.) 

• Quality requirements 

• Production volume and delivery time 

• Payment procedures and communication 

• A CoC is a set of rules outlining the responsibilities of 

or proper practices for an individual organization 

• CoC are individual and voluntary, and vary between 

organisations 

• CoC are based on internationally conventions (e.g. 

International Labour Organisation), implementation 

according local legislation 

• Labels certify that goods are produced according 

certain standards (e.g. Öko‐Tex 100, EU Ecolabel) 

• Labels are getting more and more popular among 

consumers as they are seen as an evidence that the 

product s are harmless to personal health, the 

environment 

Tariffs and quotas 

Moldova benefits from having Autonomous trade preferences (ATPs) for imports 

into the EU. The ATPs allow for unlimited and duty free access to the EU market to 

all products originating in Moldova, except for certain specific agricultural 

products. 

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5 EXPORT OPPORTUNITIES AND 

OBSTACLES 

Opportunities 

In the following possible opportunities and obstacles for Moldovan apparel 

producers to export to Germany are presented. The opportunities and obstacles 

have been formulated on the basis of the information provided in the previous 

chapters. 

Proximity to 

EU Market 

EU Trade 

Preference 

Opportunities 

Upgrading in 

the value 

chain 

Explore 

niche market 

Local Market 

Being the second largest export industry after wine, the clothing industry is of 

high importance to the Moldovan economy. Moldovan clothing producers are 

already linked to EU and German apparel companies, mainly working on contract 

and OPT basis. These existing business linkages can provide the basis for a further 

development of the sector. The following opportunities and steps are seen as 

important to, first of all, secure and further develop the position of the Moldovan 

clothing sector: 

Proximity to EU market 

Upgrading the value chain 

Explore niche market 

• Fast Fashion – the closeness to the EU market allow to 

serve for quick and flexible demand 

• Short travel distance for business partners (e.g. quality 

control visitors) 

• No time difference to business partner, and common 

cultural background 

• Upgrade within the textile value chain, without 

neglecting the contract work / using the income and 

contacts from contract work 

• Develop the capacity to fabricate value added products 

• Move up from CMT to FoB according importers 

specifications 

• Establishing of Moldovan brands and retail chains to 

target domestic market 

• Target smaller chain stores or buying organisations 

• Work with agents on commission (see chapter 4 Market 

Actors) 

• Work for high quality apparel segment (using the 

advantage of market proximity) 

13










Constraints 

Limited 

investment 

capacity 

Currency 

rate 

Constraints 

Laws and 

regulations 

Business 

Skills & 

Contacts 

Skilled 

labour force 

Despite its importance for the Moldovan economy the clothing sector seems to 

lack the necessary support to explore opportunities and to move up from contract 

work to value added production. In parts this relates to laws and regulations (e.g. 

taxation of cutting remnants), but also to the level of self‐organisation of the 

clothing sector. 

For instance an efficiently organized industry association – which can lobby the 

Government in policy issues, improve the image of the industry and offer services 

(e.g. market information, channel donor support, etc.) – is not in place. 

Further constrains are: 

Limited investment 

capacity 

• Low margins in contract work limit the capacity to invest 

in value added production schemes 

Skilled labour force 

Business skills and contacts 

• Vocational training system does not target the work 

skills need for value added production 

• Skilled labour force is moving to better paid jobs 

• Lack of design capacity 

• Knowledge and contacts for sourcing and supply is 

missing (as it is not needed for contract work) 

• Market information and marketing skills are not 

developed 

• A Fashion Centre, providing the apparel industry with 

fashion trends collected from various sources is not in 

place 

• Competence Centre, which offers technical services for 

improving technology and management skills in the 

industry, does not exist 

14

Export Marketing Survey: German Market for Textile and Clothing

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