Sacha Holub

The Design Process

Sacha Holub
The Design Process

The design process is where core decision-making begins. What kind of materials will the shoes be made from? What are the main intended uses? How will they be manufactured? What happens to the shoes after the user is done with them? When answering these questions, there are a number of legal commitments and voluntary considerations that you should be aware of.



At a very basic level, there are legal requirements that should be covered. The following information is just a brief overview, but it’s important stuff that is worthwhile sifting through - even if it is a little complicated and dry! So, which legal regulations are relevant?

The European Labelling Directive for Footwear (94/11/EC)

Labelling must give consumers information on the composition of the three main parts of footwear (upper, lining/sock and outsole) - this applies to footwear imported into the EU and not footwear manufactured in EU. *

Access the directive here

The General Product Safety Directive (2001/95/EC)

This directive was established to ensure that products put on the market are safe. For the footwear industry, there are specific criteria that affect the safety of shoes in the EU market, which you can read about here.

Access the directive here



COSHH requires UK employers to control substances that are hazardous to health. Exposure can be prevented or reduced in a number of ways as recommended by HSE e.g. by finding out what the health hazards are and planning for emergencies. ***

Read more about COSHH here

REACH regulation (EC1907/2006)

REACH stands for the Registration, Evaluation, Authorisation and restriction of Chemicals. The main aims are to “ensure a high level of protection for human health and the environment” [1]. REACH affects more than just the chemicals industry - it applies to all individual chemical substances on their own, in preparations (a mixture or solution composed of two or more substances) or in any article e.g. a car, a battery, a telephone - or in the case of our particular industry, shoes. Examples of restricted chemicals can be found here. **

Here’s a list of current REACH legislation for a spot of ‘light’ extra reading


*We find this label requirement astonishingly minimal. It only specifies whether the shoe is made from one of four categories: leather, coated leather, textiles, or “other materials”. We’re not sure who this labelling benefits - consumers can make a pretty good guess which of the broad classification their shoes would qualify as. Could this minimal labelling perhaps be for import duty purposes instead? Depending on what materials were used in the upper and soles, footwear can have higher or lower import duty.

**This is a very complex regulation. Here’s a .pdf breakdown of REACH put together by the British Footwear Association with help from HSE. It’s also worth noting that there are concerns that REACH is not doing a good enough job. For example, Greenpeace says that lobbying from the chemicals industry weakened the regulations and ChemTrust suggests that the enforcement of REACH is not up to scratch. There are approximately 30,000 substances in use in the EU and around 300 new substances are registered every year. Even though each substance is tested, there still isn’t enough information about the health and environmental effects of most of these substances. 

***The British Footwear Association has another downloadable .pdf breakdown on how COSHH specifically affects the footwear industry



Whilst legislation is the law, standards are an agreed way of doing something which you can choose to follow voluntarily. There is sometimes an overlap - standards can be used to help draft legislation. But “following a standard doesn’t guarantee that you’re within the relevant laws” because the legislation could change within the lifetime of the standard. [2]

What standards apply to shoes?

The CEN (Comité Européen de Normalisation/ European Committee for Standardization) “is an association that brings together the National Standardization Bodies of 33 European countries” [3] like BSI or ISO standards. There are several CEN standards that mention the word “footwear” in the title, so the following are just a selection. Unfortunately, they all require purchasing in order to read them in full:

  1. CEN ISO/TR 16178:2012 Footwear - Critical substances potentially present in footwear and footwear components - which describes a list of critical chemical substances, potential risks, which material they may be found in, and what test methods can be used - purchase here to read in full.
  2. EN 14602:2012 Footwear - Test methods for the assessment of ecological criteria - designed to define what test methods are needed to correctly issue the footwear Ecolabel - purchase here to read in full.
  3. EN 12940:2004 Footwear manufacturing wastes - Waste classification and management - which specifies the stages involved in generating waste in footwear manufacture and how these waste streams are normally managed - purchase here to read in full.


Certifications are also an important consideration. These are ways to verify your claims that your product meets a level of quality, through third-party testing. Certifications are a voluntary extra, but help give conscious consumers more confidence when buying your products.

What footwear certifications exist?

Specific footwear certifications do exist (e.g. SATRA) but none are widely used across the industry. There are however certifications / benchmarks that exist to promote sustainable and ethical practices.

(N.B. these are not footwear specific, but more for fashion / textile products in general)


Additional means of testing to be aware of include:

  • The Leather Working Group is made up of different members of the product supply chain, so can’t be labelled as an independent body. But it’s still worth a mention as it aims “to develop and maintain a protocol that assesses the environmental compliance and performance capabilities of leather manufacturers and promotes sustainable and appropriate environmental business practices within the leather industry.” [4] 
  • MADE-BY - Mode tracker is a transparent tracking tool that monitors fashion brands and retailers in their efforts to improve sustainability on a yearly basis - but there are a few gaps in the scorecards, so it’s not a holistic overview.
  • The Higg Index is not an example of third-party testing, but rather a set of self-assessment “modules” from the Sustainable Apparel Coalition.

Design Strategies

Before jumping straight into the aesthetics, there are a few design strategies that may help answer that brief and, at the same time, inform how the shoe takes shape.

  • Better material selection: Some of the more commonly used materials aren’t particularly sustainable. We’ve saved you a little bit of time by compiling a list of harmful materials and some of their better alternatives.

  • Alternative manufacture methods: For example, choosing processes that minimise the amount of energy needed or avoid H&S issues e.g. using a glueless construction. Check out The Creo Shoe Concept.

  • Minimal waste: This avoids the creation of waste materials during the construction process. Take a look at Nike’s Flyknit technology.

  • Multipurpose use: Enable the user to wear one pair of shoes for a range of occasions. Check out Mohop interchangable sandals and Po-Zu's collaborations with Timberland and Maharishi.

  • Minimal design: Remove unnecessary components without compromising the basic function of a shoe, like One Moment.

  • Easy-care / Repairable: Enable features to freshen up tired shoes and increase their lifespan. Resoling expands the lifespan of a shoe. Have a look at Conker Shoes and Green Shoes.

  • Custom / Customisable design: This allows the user to be involved with the design / making process, establishing a lasting relationship between the shoe and the user. One of the biggest causes of industrial waste is eliminated, as each pair of shoes is made specifically for an individual. This method avoids overproduction, which tends to result in unsold and unused goods. Have you had a play around with all the different options for Po-Zu’s Brisk?

  • Design for disassembly: Consider how footwear can be broken down into separate components once they wear off in order to minimise waste and promote repairability, recyclability, and durability / product longevity. Check out the case studies below: