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Clothing label requirements play an important role in the apparel industry. They require manufacturers to clearly state important details such as fiber content, country of origin and manufacturer information. As a renowned manufacturer of textile and apparel labels, Wunderlabel is committed to informing its customers about labeling regulations. Read on for our brief and easy to understand overview of garment label requirements.
In the USA, the Federal Trade Commission (FTC) regulates and monitors textile labeling requirements. It ensures that the information on clothing tags is accurate and easy to understand. Apparel labeling requirements have a long history. The government passed two very important textile and wool acts: The Textile Products Identification Act (TFPIA) in and the Wool Products Labeling Act (WPLA) in . The FTC is also responsible for taking legal action if someone violates the laws.
Garment labels must be conspicuous and clearly legible. The manufacturer must affix them in such a way that they adhere to the clothing at least until the product has been delivered to the consumer. Clothing and textile labels are not expected to last the entire life of the garment or product.
The content requirements for textile and wool products include information on the material composition, country of origin and the identity of the manufacturer.
Material composition:
The components of the material must be listed in descending order, e.g: "65% viscose, 35% polyester". Only fibers that make up 5% or more of the total fiber weight can be listed. As a general rule, anything less than 5% must be listed as "other fibers". If a garment is made of only one fabric, such as cotton, you can use the phrase "All cotton" instead of "100% cotton". If part of a garment is made of a non-fiber material, such as metal, plastic or leather, it does not need to be labeled. This can include zips, buttons or beads.
Country of Origin:
The country in which an imported product is processed or manufactured is considered the country of origin. The term "Made in the U.S.A." is a strict one: Only if a whole product is made in the U.S.A. with materials that also come from the U.S.A. can the textile goods be labeled as such.
If the clothing products are not made in the United States, a DIY clothing label such as "Made in Malaysia, finished in the U.S.A." is a good solution. The manufacturer must provide the country of origin information in English.
Name of the Manufacturer:
The identity of the manufacturer must also be displayed on clothing labels. This can be either the company name or a registered identification number. These identification numbers are issued by the FTC, but are not required to open a business in the US. Please note that the name given must be the name under which the company operates. It is not the designer of the garment.
The FTC also specifies where manufacturers should place labels on garments. For example, the country of origin of garments with collars must be sewn inside center of the neck, i.e. between the shoulder seams. Information about the composition of the material and the identity of the manufacturer must be clearly visible. It does not matter whether it's a label attached to the inside or outside of the garment as long as it is accessible to the consumer. Placing it on the inside of the elbow, for example, would be inappropriate because the consumer would not be able to see it well there.
In the USA, there is no nationwide textile labeling laws or legislation for size labels. Although size labeling is not required, it has become a practical aid for customers and an industry standard. However, some states may have specific size label requirements. Manufacturers should therefore check local laws and regulations.
The Federal Trade Commission (FTC) regularly monitors compliance. If they find a violation of the Textile, Wool and Fur Act, it can be costly: each instance of mislabeling is considered a separate violation and can cost the manufacturer up to $51,744. Proper labeling and adhering to the rather stringent requirements is definitely in the best interest of the manufacturer.
Products containing textile fibers, fur, and wool, that are imported or manufactured in the United States, are covered by the labeling rules and requirements outlined in 16 CFR Parts 303, 301, and 300.
Additionally, care labeling might be required for some products (e.g. wearing apparel), according to 16 CFR Part 423. Other regulations such as CPSIA or the Flammable Fabric Act also sets labeling requirements for textiles products based on the age group or fabric characteristics.
In this guide, we explain what products are covered by the relevant regulations, and what are the labeling requirements. Note that, while some of these regulations might also contain documentation, testing, and other requirements, in this article we focus on the labeling requirements.
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16 CFR Part 303 &#; &#;&#;Rules and Regulations Under the Textile Fiber Products Identification Act16 CFR Part 303 sets requirements for textile products. This section explains its scope, exemptions, and labeling requirements.
Here are the general requirements of 16 CFR Part 303:
a. Textile products must include a label that contains the required information (e.g. fiber composition).
b. Advertisements of textile fiber products must comply with the Act&#;s requirements.
c. Documentation requirements related to maintenance of records, invoicing, and the guaranty, which is optional.
d. Lab testing.
Here we list several textile products covered by the act, the rest of which are listed in 16 CFR Part 303.45(a):
Products labeled under the Wool Products Labeling Act are exempt from 16 CFR Part 303. Furthermore, here are examples of exempted products, as listed in 16 CFR Part 303.45:
a. Armbands, diaper liners, garters, handicraft looper clips, shoelaces, and tapestry cloth.
b. Textile products that company store operators make and sell exclusively to their employees.
c. Coated fabrics.
d. Single-use and disposable non-woven products.
e. Curtains primarily consisting of wooden slats.
Textile products are subject to labeling requirements regarding fiber composition content, traceability, country of origin, and claims.
Fiber content
Per 16 CFR Part 303.16, labels of textile products must contain:
a. The fibers&#; common name (e.g. &#;cotton&#;).
b. The percentages by weight of the constituent fibers in amounts exceeding 5%.
Fibers must be listed in order of predominance by weight. The term &#;other fibers&#;, that is fibers present in an amount lower than 5%, must be listed last, if present.
Traceability requirements
Traceability information must appear on an obvious and easily-accessible label that is attached either inside or outside the textile product.
This information must contain the manufacturer&#;s name or a registered identification (RN) number.
Country of origin
The disclosure of the product&#;s country of origin (e.g. Made in Vietnam) must appear on the label&#;s front side.
Textile products with a neck must include the country of origin on a label that is affixed to the inside and center of the neck, and midway between the shoulder seams, or close to the label affixed to the inside center of the neck.
Claims
Labels containing the constituent fibers&#; common name may also include descriptive terms, provided that they are not deceptive and are proper and truthful to the product. Examples of such claims, as provided in 16 CFR Part 303.16(d), include:
Placement
Labels must be securely affixed to each textile product, package, or container. These labels must be visually obvious and durable enough to remain attached to the product and its packaging until it reaches the ultimate consumer.
You can find specific provisions for hosiery products and socks under 16 CFR Part 303.15.
16 CFR Part 301 &#; Rules and Regulations Under Fur Products Labeling Act16 CFR Part 301 requires manufacturers to comply with the labeling rules and regulations under the Fur Products Labeling Act.
Fur products require the following:
a. Relevant labeling information.
b. Advertising in compliance with the Act&#;s rules and requirements.
c. Relevant documentation (e.g. invoices, maintenance of records, or the optional guaranty).
This part covers fur products, including wearing apparel made from fur. The term wearing apparel includes:
a. Clothing and coverings.
b. Attached furs that are assembled, used, or wasted.
c. Attached furs that are garment shells, plates, mats, or furs flat off the board.
d. Furs that were artificially colored, bleached, dyed, or tip-dyed.
16 CFR Part 301 does not cover fur products containing fur from animals that were trapped, hunted, and sold in secret at a short-term place (e.g., craft fair) by the trapper or hunter whose revenue from such products is not the main source of income.
Manufacturers of fur products should ensure that they adhere to the requirements listed below.
Fur products name
Fur product labels, invoices, and advertisements must use the applicable animal name as listed in 16 CFR Part 301.0. We list several examples of permissible names:
When manufacturers use fur from an animal that is in the US but is not listed in the Name Guide, they must use either the true name of the animal, in English; or the proper identifying name of the animal.
Note that 16 CFR Part 301.7 prohibits the describing of furs using certain breed names (e.g., &#;Chinchilla Rabbit&#;), and 16 CFR Parts 301.8 to 301.10 permits specific lamb-related terms (e.g., &#;Broadtail Lamb&#;).
Per 16 CFR Part 301.11, manufacturers are also prohibited from providing names of fictitious or factually non-existent animals on the labels of fur products.
Traceability requirements
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The manufacturer must provide, on fur product labels, either the manufacturer&#;s full business name or their registered identification numbers.
Per 16 CFR Part 301.25, manufacturers must not use trademarks, trade names, or other names that are not the full business name.
Country of origin
Manufacturers of fur products imported into the US mainland from a foreign country (including colonies, possessions, or protectorates of the US) must provide the country of origin of those fur products.
The fur product&#;s country of origin must be preceded by the term &#;fur origin&#; (e.g. Fur Origin: Norway).
Claims
Deception via the provision of misleading and incorrect information on labels, invoices, or advertisements of furs or fur products is not allowed.
For example, to avoid deception as to the nature of the business, the name of the non-manufacturing company that appears on the label or invoice must be accompanied by relevant terms. The names, for instance, should state: &#;Distributed by __________&#; or &#;__________ Wholesalers&#;.
Placement
The required labels on a fur product, its packaging, or container, must be obvious, durable, and remain affixed until the product reaches the end user.
16 CFR Part 300 &#; Rules and Regulations Under the Wool Products Labeling Act ofManufacturers of wool products must comply with the labeling rules in 16 CFR Part 300 under the Wool Products Labeling Act.
Wool products generally require:
a. Labels that contain the required information (e.g., fiber content).
b. Compliant advertising details (e.g., the processed wool&#;s origin country).
c. Relevant documentation (e.g., maintenance of records, optional guaranty, or invoices).
This part covers products that are made from wool, as well as products that contain both wool and other constituent fibers.
According to Section 68j of the FTC&#;s Title 15, Chapter 2, products excepted from the wool products labeling requirements include items such as:
Manufacturers should ensure that they properly label their wool products concerning their fiber content and country of origin. They should also ensure that any claims and traceability information made are factually correct.
Fiber content
Wool products, excluding &#;permissive ornamentation&#;, must bear the fiber content on their label.
Here is an example:
&#;55% Wool
35% Cotton
10% Angora Rabbit&#;
If less than 5% of the wool product is made of constituent non-wool fibers, the term &#;other fiber&#; can be used.
Traceability requirements
Manufacturers of wool products must provide traceability information, such as their company&#;s name or their registered identification number.
They may place their registered identification number on stamps, tags, or labels attached to the wool product.
Country of origin
Country of Origin information is required. If the wool product was manufactured in the US with wool with imported materials, the country of origin information should, for instance, read &#;Made in USA of imported fabric&#;. You find more examples in 16 CFR Part 300.25.
Manufacturers of wool products with necks must disclose their product&#;s country of origin on an easily-accessible label affixed to the neck&#;s inside center, in the middle between the shoulder seams. They must place the country of origin disclosure on the label&#;s front side.
Claims
Manufacturers must not deceptively claim and falsely indicate on their labels that their wool product is made, in part or whole, of a particular fiber, when this is not the case.
Generally speaking, covered wool products must not carry stamps, tags, labels, or marks containing information that is:
Placement
Wool products, their packages, or containers, must carry a securely affixed label. These labels must be conspicuous, durable, and stay attached until the product reaches the ultimate consumer.
16 CFR Part 423 &#; Care Labeling of Textile Wearing Apparel and Certain Piece Goods as Amended16 CFR Part 423 covers the provision of care labeling of textile wearing apparel and certain piece goods, which are defined as pieces of textile form bolts or rolls used for making home sewn textile wearing apparel. It requires importers and manufacturers of such wearing apparel and materials thereof to provide consumers with care instructions.
You can use the standard terms from the glossary in Appendix A to Part 423 to meet the care instruction requirements. Here are a few examples of care instructions from that glossary:
You might also use care symbols to complement care terms. However, if you use the symbols established in ASTM Standard D&#;96c, it is not necessary to also use care terms.
SizeTo our knowledge, there aren&#;t any mandatory sizing requirements. However, the ASTM&#;s Subcommittee D13.55 on Body Measurement for Apparel Sizing has published a list of standards that cover apparel sizing. Here, we provide some examples:
a. ASTM D-15 &#; Standard Terminology Relating to Body Dimensions for Apparel Sizing.
b. ASTM D/DM-19 &#; Standard Tables of Body Measurements for Girls, Sizes 2 to 20 (Reg & Slim) and Girls Plus.
c. ASTM D/DM-19 &#; Standard Tables of Body Measurements for Boys, Sizes 4 to 20 Slim and 2 to 20 Regular.
d. ASTM D/DM-19 &#; Standard Tables of Body Measurements for Boys, Sizes 4H to 20H Husky.
Note that, even if size information might not be mandatory, from a practical point of view it is still important to provide this information as retailers, distributors or consumers might refuse to buy some types of products (e.g. apparel) if the size is not specified.
Other Labeling Requirements for TextilesFor some textile products, additional labeling requirements might apply.
The CPSIA requires children&#;s products, that is products meant for children 12 years or younger, to bear a tracking label.
The tracking label, which is also relevant for textile products, should include information such as:
Some standards under the Flammable Fabric Act also set labeling requirements for specific types of textiles.
Here, we provide a short summary:
a. 16 CFR Part &#; Standard for the Flammability of Clothing Textiles and 16 CFR Part &#; Standard for the Flammability of Vinyl Plastic Film set labeling requirements for fabrics not customarily washed or dry-cleaned.
b. 16 CFR Part &#; Standard for the Flammability of Children&#;s Sleepwear: Sizes 0 Through 6X and 16 CFR Part &#; Standard for the Flammability of Children&#;s Sleepwear: Sizes 7 Through 14 contain specific labeling requirements for children&#;s sleepwear (e.g., garment production identification).
c. 16 CFR Part &#; Standard for the Surface Flammability of Carpets and Rugs and 16 CFR Part &#; Standard for the Surface Flammability of Small Carpets and Rugs set labeling requirements concerning fire-retardant treatment and alternate washing procedures.
You can find more information on the eCFR website.
FAQHere are some answers to frequently asked questions regarding whether labeling and care instructions are required for different textile products.
Manufacturers must provide labeling for clothing textiles, which should include the following information:
According to the product, e.g. children&#;s sleepwear, additional labeling requirements might apply.
Manufacturers must provide care labeling on clothing textiles, either using care terms, as provided in Appendix A of 16 CFR Part 423, the symbols established in the ASTM D&#;96 standard, or a combination of care terms and symbols.
To our knowledge, there may not exist any mandatory sizing requirements. However, ASTM did publish several sizing standards that manufacturers may refer to.
Also note that even if sizing is not mandatory for clothing, consumers may not purchase &#; or return &#; clothes if said items do not indicate size.
The requirements set out in 16 CFR Parts 303, 301, and 300 still apply to children&#;s clothing, as well as the care labeling requirements set in 16 CFR Part 423, and the requirements set by the Flammable Fabrics Act.
Additionally, the CPSIA regulates the manufacture, importation, and sale of children&#;s products in the US, including children&#;s clothing.
According to the CPSIA, importers, and manufacturers of children&#;s clothing must carry tracking labels that provide traceability information.
According to 16 CFR Part 303.45, manufacturers must provide labeling for home textiles, such as:
Other home textile products might also require labeling.
We could not find any specific examples of requirements regarding the labeling of textile accessories. However, some accessories might be subject to some the labeling requirements listed in this article.
For instance, the CPSIA&#;s labeling requirements might apply to children&#;s accessories for textile products.
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