Can I Label My Product as Made in the UK?
A Simple Guide to Rules of Origin for Fashion Textile and Homeware Brands
If you're running a clothing, textile or homeware business and you're trying to figure out whether your product qualifies as "Made in the UK," you're not alone.
This is one of the most common questions I get asked. And it’s no wonder: the rules are complex, confusing, and often buried in government jargon that makes them hard to understand.
But if you're making products in the UK or planning to export, you need to get this right. Especially now, with tariff changes like the proposed US 'Trump Tariffs' and the government's refusal to back a 'Buy British' campaign, understanding the Rules of Origin has never been more important.
In this article, I'm breaking it all down in plain English, based on my recent video masterclass (you can watch the full video below). By the end, you'll understand what qualifies as a UK-made product, how to work it out for your business, and how to make sure you're not misleading your customers or paying more duty than you need to.
What Are the Rules of Origin?
The Rules of Origin are the rules that decide what country a product officially comes from. It’s not just about where you bought your fabric, or where your supplier is based. It’s about where your product was last substantially transformed.
This matters because:
- If you’re exporting, it affects whether your product qualifies for lower tariffs under a trade deal.
- If you’re importing, it affects whether you can claim preferential tariffs.
- And if you're labelling something as Made in the UK when it doesn't qualify, you could be misleading customers or breaking the law.
The Big Question You Need to Ask
To work out whether your product can be labelled as Made in the UK, ask yourself:
"Where did the last substantial transformation take place?"
That means: when did your product change from being a set of raw materials or parts, into the final thing you’re selling?
If the last big transformation happened in the UK, it probably counts as Made in the UK. If that transformation happened in another country, it doesn't.
What Does ‘Substantial Transformation’ Mean?
Substantial transformation usually means the product changed its form or use – and in doing so, changed its commodity code (also called a tariff classification).
Here’s a simple way to think about it:
If you bring in fabric from overseas and stitch it into T-shirts in Leicester, that’s a substantial transformation. But if you bring in ready-made T-shirts and print your design on the front, it’s still the same commodity code. So it doesn’t count.
Typical Examples for Fashion, Textiles and Homeware Brands
Let’s look at some real-world examples to make it clearer:
T-shirts
- You import the fabric from China and stitch it into garments in the UK = Made in the UK
- You import ready-made blank T-shirts and just add a print in the UK = Made in China
Ceramic mugs
- The mug is formed and fired in Stoke = Made in the UK
- The mug is made overseas, and you just print a design in the UK = Made in Indonesia (or wherever the firing took place)
Shoes
- You import the uppers and soles but last and finish the shoes in Northampton = Made in the UK
- You import fully made shoes and just polish or add laces = Not Made in the UK
Beauty Products
- You blend different oils and package the final formula in the UK = Made in the UK
- You import a finished product and just label it = Not Made in the UK
Why the Confusion around Imported Materials?
If you’ve read everything above and are now thinking, “Hang on, I import fabric but my product still counts as UK-made” – you’re right.
That’s because not every product needs to be wholly made in the UK to qualify. The key is whether it meets the rules set out in a trade agreement.
In some cases, the last substantial transformation is enough (like cutting and sewing a T-shirt from imported fabric).
In others, especially when exporting, you’ll also need to meet the Value Added Rule – which measures how much of the total cost was added in the UK. This is where it gets confusing, because you might need both rules to be true depending on the destination and the agreement in place.
How to Use the Value Added Formula
Here’s the simple formula:
(selling price - cost of non-UK materials) ÷ selling price x 100 = % value added in the UK
Let’s say:
Your selling price is £100
You spent £40 on imported fabric
(100 - 40) ÷ 100 x 100 = 60% UK value added
If the trade agreement says you need to add at least 50% UK value, you qualify. If your number is too low, your product will be treated as originating from where the materials came from.
What is a Commodity Code and How to Find Them?
Every product has a commodity code – a number that tells customs what it is.
You can find yours using the UK Government’s Trade Tariff Tool: https://www.gov.uk/trade-tariff
Here are a few example codes for common textile and fashion products:
- 6109 10 00 – Cotton T-shirts
- 6204 42 31 – Women’s cotton dresses
- 6302 31 00 – Cotton bedlinen
- 6912 00 49 – Ceramic tableware
Knowing your code helps you work out:
- If your product has changed classification (substantial transformation)
- What rules apply under a specific trade agreement
Preferential vs Non-Preferential Rules
There are two types of rules of origin:
- Preferential rules apply when you're claiming reduced tariffs under a trade agreement.
- Non-preferential rules are used when no preference applies but the country of origin still needs to be declared (e.g. for labelling or quotas).
If you're exporting to a country with a trade deal, you'll usually be working with preferential rules. That’s when the Value Added rule or the Change of Tariff Classification rule comes into play.
What Processes Don't Count as Made in the UK?
Certain processes are not enough to claim Made in the UK status. These include:
- Simple packaging or labelling the product in the UK
- Only the dyeing, printing or embroidery done in the UK
Remember: Unless you're changing the product’s essential nature or classification, it doesn’t count.
Checklist to Work Out How to Label Your Product
Here's a step by step guide:
1. Find your product’s commodity code here: https://www.trade-tariff.service.gov.uk/find_commodity
2. See what trade rules apply for the country you’re exporting to here: https://www.gov.uk/government/collections/the-uks-trade-agreements
3. Look at the specific rule for your code: does it need value added, a change in classification, or something else?
4. Use the government’s guidance on rules of origin here: https://www.gov.uk/government/collections/rules-of-origin
5. Get proof of origin for exports here: https://www.gov.uk/guidance/get-proof-of-origin
What to Do if You’re Still Unsure if Your Product can be Labelled as Made in UK
Still Confused? Watch the Full Video
There are a lot of grey areas and confusing examples – which is why I recorded a full masterclass on this.
In the video, I cover:
Want help to start or scale your UK-made brand?
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