Federal Labeling Laws FAQ

2017 Labeling Requirements

INTRODUCTION

As required by Federal law, all textile products must have a label listing:

1. a) Fiber content,
2. b) Country of origin (COO),
3. c) Care instructions
4. d) Identity of the manufacturer

Suggestion: Have 2 separate labels:

1. A separate label holds the company name and logo for branding effectiveness. For the fiber content and the country of origin (COO). Content and COO labels are usually woven, printed on satin, twill tape or as heat transfers.  Labels for washing and care instructions should be put right under the fiber content, with size and the country of origin. Care instructions can be sewn into the garment along the side seams.

Mechanics of Labeling – Requirements for disclosing the necessary information:

• The three required disclosures may appear on one label or on separate labels. They may appear on a label with other information — such as the care instructions. Consumers and professional cleaners find it helpful to have the fiber content on the same label with the care instructions.
• All of the required information must be clearly legible, conspicuous, and accessible.
• All parts of the fiber content information must be in type or lettering of equal size and conspicuousness. For example, your label cannot say:     80% polyester – 20% SILK
• All of the required fiber content information must appear in immediate proximity to each other.
• You can use other non-deceptive terms to accurately describe the fiber. For example: “100% crosslinked rayon” or “100% Egyptian cotton”
• The country of origin must always be on the front side of the label. Fiber content and the identity of the manufacturer or dealer may appear on the back of a label. In that case, the label must be attached to the product only at one end so that the reverse side is accessible to the consumer.

Labeling Requirements:

Country of Origin (COO)

• Products covered by the U.S. Textile and Wool Acts must be labeled to show the country of origin.
• Imported products must identify the country where they were processed or manufactured.
• Products made entirely in the U.S. of materials also made in the U.S. are to be labeled “Made in U.S.A.” or with an equivalent phrase.
• Products made in the U.S. of imported materials must be labeled to show the processing or manufacturing that takes place in the United States, as well as the imported component; ie: ”Made in U.S.A. with Imported Components”.
• Products manufactured in part in the U.S. and in part abroad must identify both aspects.

FTC Rules and Customs Regulations

• Imported products made entirely abroad

A textile product made entirely abroad must be labeled with the name of the country where it was processed or manufactured. Importers and other marketers should check U.S. Customs regulations to determine the appropriate COO designation for all imported products.

• Unqualified “Made in U.S.A.” labels  

A label may say “Made in U.S.A.” only if the product is made completely in the U.S. of materials that were made in the U.S. If a U.S. manufacturer uses imported greige goods that are dyed, printed, and finished in the U.S., for example, they may not be labeled “Made in U.S.A.” without qualification.

• Products made in the U.S.A. with imported materials

The label must indicate that the product contains imported materials. The label need not identify the country of origin of the imported material.  It can say simply: “Made in U.S.A. of imported fabric” or “Knitted in U.S.A. of imported yarn.” This disclosure must appear as a single statement, without separating the “Made in U.S.A.” and “imported” references.

• In addition to identifying fiber content and country of origin, textile labels must identify either the company name or Registered Identification Number (RN) of the manufacturers, importer, or another firm marketing, distributing, or otherwise handling the product. ​​​​​​

Label placement and attachment – the label(s) with the required information must be securely attached to the product until it is delivered to the consumer.

Note: Many consumers and professional cleaners consider it important to have fiber information on a permanent label. Also, remember that garments must have care instructions on a permanent label. Therefore, it may be useful to have the two pieces of information on the same label.

“One step removed” rule: In deciding whether to mark a product as made, in whole or in part, in the U.S., a manufacturer must consider only the origin of materials that are one step removed from the particular manufacturing process. Examples: a yarn manufacturer must identify imported fiber – a manufacturer of knitted garments must identify imported yarn – A manufacturer of apparel made from cloth must identify imported fabric.”

Note: U.S. Customs requires that the country of origin of imported goods be on a sewn-in label.

• In a garment with a neck, a label disclosing the country of origin (on the front) must be attached to the inside center of the neck — either midway between the shoulder seams or very near another label attached to the inside center of the neck. The fiber content and manufacturer or dealer identity can appear on the same label (front or back) or on another conspicuous and readily accessible label(s) on the inside or outside of the garment.
• On garments without a neck, and on other kinds of textile products, the required information must appear on a conspicuous and readily accessible