FTC clothing requirements and textile labeling: Avoid penalties
27 March, 2025
Navigating the Federal Trade Commission’s (FTC) rules for clothing and textile labeling can be complex, but it’s crucial for any clothing business, especially small businesses specializing in wholesale and retail. Incorrect or missing labels can lead to significant fines and damage your brand’s reputation.
This guide breaks down the essential FTC requirements, providing practical advice on ensuring your garment labels are fully compliant. By understanding these regulations, the reader will be able to confidently label products, avoid penalties, and build trust with customers.
1. Why Are Accurate Labels Important?
1.1 Legal Compliance (Avoiding Penalties)
The Federal Trade Commission (FTC) actively enforces labeling regulations to protect consumers. Non-compliance, whether intentional or accidental, can lead to significant consequences. These can range from substantial fines to potential lawsuits, all of which can severely impact a business’s finances and reputation. Staying informed and adhering to FTC guidelines is essential for avoiding these costly penalties.
1.2 Building Consumer Trust
In today’s market, consumers are increasingly discerning and value transparency from the brands they choose. Accurate and complete labels provide essential information, allowing customers to make informed purchasing decisions. When customers see that a business is upfront about fiber content, care instructions, and country of origin, it builds confidence and reinforces a positive brand reputation. This transparency is key to establishing long-term customer loyalty.
1.3 Ethical Business Practices
Accurate labeling goes hand in hand with broader ethical considerations within the fashion industry. Providing clear and honest information about products aligns with principles of fair competition and consumer rights. It demonstrates a commitment to transparency, which extends beyond legal obligations and reflects a dedication to responsible and ethical sourcing practices.
2. What Laws Govern Textile Labeling in the US?
2.1 The Textile Fiber Products Identification Act (TFPIA) – Overview
The TFPIA is the cornerstone of textile labeling, requiring accurate disclosure of fiber content, country of origin, and manufacturer or importer identity on most textile products. This allows consumers to know what they are buying.
2.2 The Wool Products Labeling Act (WPLA) – Overview
The WPLA sets specific requirements for labeling products containing wool, including recycled wool. It ensures consumers are informed about the type and percentage of wool fibers present.
2.3 The Fur Products Labeling Act (FPLA) – Overview
The FPLA mandates specific labeling requirements for garments containing fur, including the animal’s name, country of origin, and if the fur is dyed, pointed, or otherwise artificially altered.
2.4 The Care Labeling Rule – Overview
This rule requires manufacturers to provide clear and permanent care instructions for garments, detailing washing, drying, ironing, and other care procedures. This enables consumers to properly maintain their clothing.
2.5 Relationship to the Fair Packaging and Labeling Act (FPLA) – Briefly explain
The Fair Packaging and Labeling Act (FPLA) is a broader law that covers the labeling of many consumer products, including textiles. While the FPLA establishes general principles, the TFPIA, WPLA, FPLA, and Care Labeling Rule provide the specific, detailed requirements that directly apply to clothing and textile labeling. These textile-specific laws build upon the foundation of the FPLA to ensure comprehensive consumer protection.
3. Who Enforces These Regulations?
3.1 The Role of the Federal Trade Commission (FTC)
The FTC is the primary agency responsible for setting and enforcing the labeling regulations outlined in the TFPIA, WPLA, FPLA, and the Care Labeling Rule. The FTC develops the specific requirements, conducts investigations into potential violations, and takes enforcement actions against companies that fail to comply. These actions can include issuing cease-and-desist orders, imposing civil penalties (fines), and pursuing legal action.
3.2 The Role of U.S. Customs and Border Protection (CBP)
CBP plays a crucial role in enforcing labeling regulations for goods imported into the United States. CBP officers inspect imported textile and apparel products at ports of entry to ensure they comply with all applicable labeling laws. If CBP finds violations, they may seize the goods, refuse entry, or require corrective action before the products can be released for distribution in the U.S. market.
4. Fiber Content Disclosure
4.1 Generic Fiber Names (and acceptable ISO names)
The FTC requires the use of generic fiber names, rather than trademarks or brand names, to identify the fibers in a garment. The International Organization for Standardization (ISO) names are also generally accepted. For example, instead of “Dacron,” you must use the generic name “polyester.”
Examples of Common Fiber Names:
- Cotton
- Polyester
- Rayon/Viscose
- Spandex/Elastane
- Wool
- Silk
- Linen
- Nylon
4.2 Percentage by Weight (Descending Order)
Fiber percentages must be listed by weight in descending order. This means the fiber present in the largest amount is listed first, followed by the next largest, and so on. For example, a label showing “60% Cotton, 40% Polyester” indicates that the garment is composed of 60% cotton and 40% polyester by weight.
4.3 The 5% Rule and Exceptions (Wool, Functional Fibers)
Generally, if a fiber makes up less than 5% of the total fiber weight, it can be listed as “other fiber.” However, there are important exceptions:
Wool: Any amount of wool must always be disclosed, regardless of percentage.
Functional Fibers: If a fiber is present in less than 5% but serves a specific functional purpose, it must be listed by its generic name. For instance, spandex added for elasticity or nylon added for reinforcement must be disclosed.
4.4 “All” vs. “100%”
The terms “All” and “100%” can only be used when a garment is made entirely of one fiber, excluding minor ornamentation or trim. “100%” is commonly used, while “All” is also acceptable.
4.5 Dealing with Unknown Fibers (Scraps, Recycled Materials)
When using recycled materials or scraps where the exact fiber content is unknown, specific wording is required. The label should clearly state that the fiber content is undetermined.
4.6 Biconstituent and Multiconstituent Fibers
Fibers that combine two or more fibers blended together. The fiber content of the combined fibers still needs to be stated as a percentage, such as “60% Acrylic, 40% Modacrylic”.
4.7 Premium Cottons (Pima, Egyptian, etc.) – How to Label Correctly
When using premium cotton varieties like Pima, Egyptian, or Sea Island cotton, it’s crucial to be accurate and avoid misleading consumers. If the garment is made entirely of one of these cotton types, it can be labeled as “100% Pima Cotton,” for example. If it’s a blend, the percentage of the premium cotton must be disclosed.
Unacceptable: Simply stating “Pima Cotton” on a blend without specifying the percentage is misleading and not permitted.
5. Country of Origin
5.1 Determining Country of Origin (Substantial Transformation)
“Substantial transformation” is a key concept in country of origin determination. It means that the country of origin is the country where the product was significantly changed into a new and different article of commerce. Simply sewing together pre-cut fabric panels might not be considered a substantial transformation if the fabric itself was manufactured in another country. If fabric is knitted in China and then cut and sewn into a garment in Vietnam, the country of origin would likely be Vietnam. However, if pre-cut fabric panels are imported into the US from China, and those panels are simply sewn together in the US, the country of origin would remain China.
5.2 “Made in USA” Claims (Specific Requirements)
To claim a product is “Made in USA,” it must be “all or virtually all” made in the United States. This means that all significant parts and processing that go into the product must be of U.S. origin. The product should contain no, or negligible, foreign content.
5.3 Imported Products – Labeling Requirements
Imported products must clearly and conspicuously display the country of origin in English. The labeling must be permanent enough to reach the ultimate consumer.
Examples of Acceptable Country of Origin Statements
- Made in China
- Made in Vietnam
- Made in Bangladesh
- Assembled in Mexico from US Components
- Made in Italy
- Product of Thailand
6. Manufacturer or Dealer Identification (RN Number)
6.1 What is an RN?
An RN is a unique identification number assigned by the Federal Trade Commission to businesses involved in the manufacture, importation, distribution, or sale of textile, wool, and fur products covered by the relevant Acts. This number allows the FTC to trace products back to their source, facilitating enforcement and consumer protection.6.2 How to Obtain an RN. Businesses can apply for an RN free of charge through the FTC website. The application process is straightforward and can be completed online. Here’s the link to the FTC RN application website: https://rn.ftc.gov/
6.2 Using a Company Name Instead of an RN (Requirements)
A company name may be used on the label instead of an RN only if the company’s full name and address are used, and if that company is, in fact, the manufacturer, importer, or a responsible party for the product. This name and address must be current and accurate. Simply using a brand name or a trade name is not sufficient unless that name is also the full legal name and address of the responsible company.
7. Care Instructions (Care Labeling Rule)
7.1 Required Elements of a Care Label
A care label must include at least one safe method of care, along with any necessary warnings. This typically involves instructions for:
- Washing: (e.g., machine wash cold, hand wash, do not wash)
- Drying: (e.g., tumble dry low, line dry, dry flat, do not tumble dry)
- Ironing: (e.g., iron low, do not iron)
- Dry Cleaning: (e.g., dry clean, do not dry clean)
- Bleaching: (Use of bleach or not)
7.2 Standard Symbols and Their Meanings (Link to a resource for symbols)
While written instructions are required, the use of standard care symbols is highly recommended and widely adopted in the industry. These symbols provide a concise and internationally understood way to convey care information. A comprehensive guide to standard care symbols can be found at resources like the American Cleaning Institute: https://www.cleaninginstitute.org/industry-resources/care-symbols
- Symbol Meaning
- Circle inside Square Tumble Dry
- Triangle Bleaching
- Iron Ironing
- Circle Dry Clean
- Washtub Washing
7.3 Providing Clear and Accurate Instructions
Care instructions must be clear, unambiguous, and based on reasonable grounds. The instructions must apply to all parts of the garment, including any trim or ornamentation. Warnings should be included if a particular care procedure that a consumer might reasonably expect to use would damage the garment (e.g., “Do not dry clean” if dry cleaning would harm the fabric).
7.4 Permanence of Care Labels
Care labels must be permanently attached to the garment and remain legible throughout the useful life of the product. This typically means using a durable label material and printing method that can withstand repeated washings and wear. Sew-in labels are generally preferred for their permanence.
8. Trimmings, Ornamentation, and Linings
8.1 The 15% Rule for Decorative Trim
Decorative trim, such as ribbons, braids, or embroidery, that makes up less than 15% of the surface area of the garment does not need to be included in the fiber content disclosure. However, if the trim makes up 15% or more of the surface area, its fiber content must be disclosed.
8.2 The 5% Rule for Ornamentation
Ornamentation refers to decorative designs or patterns that are integral to the fabric itself, such as a woven pattern or a printed design. If the ornamentation covers less than 5% of the surface area of the product, its fiber content does not need to be included. However, if it covers 5% or more of the surface area, it must be included in fiber disclosure.
8.3 “Exclusive of Decoration/Ornamentation”
When trim or ornamentation is exempt from fiber disclosure (under the 15% or 5% rules, respectively), the label may include the phrase “Exclusive of Decoration” or “Exclusive of Ornamentation.” This clarifies that the stated fiber content refers only to the base fabric of the garment.
8.4 Linings Used for Warmth – Disclosure Requirements
Linings used primarily for warmth, even if detachable, must have their fiber content disclosed separately. This is because the lining contributes significantly to the garment’s function and consumer expectations.
8.5 Sectional Disclosure (Examples)
When different parts of a garment have different fiber compositions (e.g., a shell and a lining, or a garment with significant trim), sectional disclosure is required. This means listing the fiber content of each section separately.
9. Products Covered and Not Covered
9.1 List of Covered Items (Clear, Concise List)
The following items generally require full labeling, including fiber content, country of origin, manufacturer/dealer identification, and care instructions:
- Clothing (shirts, pants, dresses, suits, coats, etc.)
- Underwear and sleepwear
- Scarves, shawls, and handkerchiefs
- Handbags and other textile accessories
- Bedding (sheets, blankets, comforters, pillowcases)
- Towels and washcloths
- Curtains and draperies
- Upholstery fabrics (intended for home use)
- Piece goods sold for making wearing apparel
9.2 List of Exempt Items (Clear, Concise List)
The following items are generally exempt from the full labeling requirements of the Textile and Wool Acts:
- Hats, gloves, and footwear
- Belts
- Suspenders
- Armbands
- Neckties
- Labels, zippers, and other findings
- Textile products intended for industrial use (not for household consumers)
- Floor coverings (carpets and rugs)
- Toys.
- Wall hangings.
9.3 Items Not Covered Unless Fiber Content is Stated
Diapers, bandages, and items used for cleaning. These items are exempt unless they are declared fiber content.
10. Wool-Specific Requirements
10.1 Defining “Wool” and “Recycled Wool”
Under the WPLA:
- Wool: Refers to the fiber from the fleece of the sheep or lamb, or the hair of the Angora or Cashmere goat (and may include the specialty fibers listed below).
- Recycled Wool: Refers to wool fibers that have been previously woven or felted into a wool product and then reduced back to a fibrous state. This distinction must be clearly stated on the label.
10.2 Specialty Wool Fibers (Cashmere, Alpaca, etc.) – Specific Criteria
Certain animal fibers are considered “specialty wool fibers” and can be listed by their specific names, provided they meet specific criteria:
- Cashmere: Must be the fine undercoat fiber produced by a Cashmere goat.
- Alpaca, Llama, Vicuna: Must be the hair from these respective animals.
- Camel Hair: Must be the hair from the Bactrian camel.
- Mohair: Must be the hair of the Angora goat.
If a product contains a blend of wool and specialty wool fibers, the percentage of each fiber must be disclosed.
10.3 “Super” Numbers for Fine Wool Fibers
“Super” numbers, such as Super 80s, Super 100s, Super 120s, etc., are sometimes used to indicate the fineness of wool fibers. These numbers are related to the diameter of the wool fibers, with higher numbers generally indicating finer fibers. While not specifically regulated under the WPLA, if these terms are used, they must be accurate and not misleading to the consumer. The FTC provides guidance on acceptable use of these terms.
10.4 Fur-Specific Requirements (Brief Overview)
The Fur Products Labeling Act (FPLA) sets forth specific requirements for the labeling of garments and products containing fur. Key requirements involve disclosing the animal’s name, country of origin, and whether the fur is dyed, bleached, or otherwise artificially altered. If your business deals with fur products, it is crucial to consult the full text of the FPLA and related FTC guidance to ensure full compliance.
Hang-tags can be a valuable tool for providing extra information to consumers, such as marketing messages, brand story, or special features of the garment. However, they cannot be used to replace the required information that must be permanently attached to the garment itself (fiber content, country of origin, manufacturer ID, and care instructions). Hang-tags are considered supplemental.
If a hang-tag includes any information about fiber content (even a partial listing), it must also include a clear and conspicuous statement directing the consumer to the permanently attached label for the complete fiber content disclosure. A common and acceptable phrase is: “See label for full fiber content and care instructions.
11.3 Fiber Trademarks on Labels and in Advertising
When using fiber trademarks (e.g., Lycra®, Tencel™) on labels or in advertising, always follow the trademark owner’s guidelines. Generally, this involves using the trademark symbol (® or ™) and capitalizing the trademark name correctly. The generic fiber name must also be included (e.g., “Spandex/Elastane (Lycra®)”). Misuse of trademarks can lead to legal issues.
12. Best Practices for Creating Compliant Labels
12.1 Checklist for Label Creation
Use this checklist to ensure your labels include all required information:
- Generic fiber names (or ISO equivalents) used.
- Percentages by weight listed in descending order.
- 5% rule and exceptions (wool, functional fibers) followed.
Country of Origin:
- Country of origin clearly and conspicuously stated.
- “Made in USA” claim meets “all or virtually all” requirement (if applicable).
- Imported products labeled correctly.
- Manufacturer/Dealer Identification:
- RN number or full company name and address included.
Care Instructions:
- At least one safe care method provided.
- Necessary warnings included.
- Standard symbols used (recommended).
- Instructions are clear and accurate.
Label Permanence:
- Label is permanently attached.
- Label and printing will remain legible for the life of the product.
- Trimmings, Ornamentation, and Linings
- The 15% rule is used for trim
- The 5% rule for ornamentation
12.2 Record Keeping Requirements
Businesses are required to keep records demonstrating compliance with labeling regulations. These records should include:
- Information on fiber content, including sourcing documentation.
- Records related to country of origin determination.
- Copies of labels used.
- Any testing or verification data related to care instructions.
- These records should be kept for at least three years.
12.3 Working with Suppliers and Manufacturers
- When working with external suppliers and manufacturers, clear communication and verification are essential:
- Clearly Communicate Requirements: Provide your suppliers and manufacturers with detailed specifications for labeling, including all required information and placement instructions.
- Request Documentation: Obtain documentation from your suppliers verifying the fiber content and country of origin of the materials they provide.
- Conduct Quality Control: Implement quality control checks upon receipt of goods to ensure labels are accurate and compliant before products are distributed.
- Establish Written Agreements: Formalize your labeling requirements in written agreements with your suppliers and manufacturers.
By following these best practices and incorporating the checklist into your workflow, a business can confidently create compliant labels, build consumer trust, and avoid costly penalties. This proactive approach contributes to a more ethical and sustainable fashion industry.
12.4 Common Mistakes to Avoid
Even with careful attention, mistakes in textile labeling can happen. Being aware of common errors can help businesses avoid costly non-compliance issues. Here are some frequent mistakes to watch out for:
- Using Trademark Names Instead of Generic Fiber Names: Always use the approved generic fiber name (e.g., “polyester” instead of “Dacron”).
- Incorrect Fiber Percentage Calculation: Ensure percentages are calculated by weight and listed in descending order.
- Ignoring the 5% Rule Exceptions: Remember that any amount of wool, and functionally significant fibers under 5%, must be disclosed.
- Misusing “All” or “100%”: Only use these terms when the garment is made entirely of one fiber (excluding minor trim).
- Incorrect Country of Origin: Determine the country of origin based on “substantial transformation,” not simply where the garment was assembled.
- Missing or Incomplete Care Instructions: Provide clear and complete care instructions, including washing, drying, ironing, and dry cleaning (as applicable).
- Using a Hang-tag to Replace Required Information: Hang-tags can supplement, but not replace, the permanently attached label.
- Failing to Disclose Lining Fiber Content: Linings used for warmth must have their fiber content disclosed separately.
- Incorrect Use of “Made in USA”: This claim requires that “all or virtually all” of the product is made in the US.
- Omitting Manufacturer/Dealer Identification: An RN or the full company name and address is required.
- Using Labels That Are Not Permanent: Labels must be permanently attached and remain legible for the life of the product.
- Not Keeping Adequate Records: Maintain records demonstrating compliance for at least three years.
- Incorrect Labeling of Premium Cottons: Clearly state if blended.
- Not Separating Parts with Different Fiber Content: Clearly label the parts separately if the garment parts have different fiber contents.
By being vigilant and avoiding these common pitfalls, businesses can significantly reduce their risk of labeling errors and ensure compliance with FTC regulations.
13. Consequences of Non-Compliance
13.1 FTC Enforcement Actions
The Federal Trade Commission (FTC) actively monitors the market for labeling violations and has the authority to take various enforcement actions, including cease-and-Desist Orders: These orders require businesses to immediately stop the non-compliant practices. The FTC may conduct investigations into suspected violations, which can be time-consuming and disruptive. The FTC can file lawsuits in federal court seeking civil penalties and other remedies.
13.2 Fines and Penalties
Non-compliance with labeling regulations can result in substantial financial penalties. The FTC can impose significant fines for each violation, and these fines can quickly add up, especially for businesses with multiple violations or large volumes of mislabeled products.
13.3 Damage to Reputation
Beyond legal and financial consequences, non-compliance can severely damage a company’s reputation. Consumer complaints, negative publicity, and loss of trust can have long-lasting effects on brand image and customer loyalty. In today’s market, where transparency and ethical practices are increasingly valued, labeling violations can lead to significant reputational harm and loss of business.
14. Related Questions
14.1 Can I use abbreviations on my care labels?
A: While standard care symbols are widely accepted and encouraged, abbreviations for written care instructions are generally discouraged. It’s best to use clear, unambiguous wording (e.g., “Machine wash cold” instead of “MWC”). This ensures that consumers understand how to properly care for their garments.
14.2 My clothing is made in multiple countries. How do I determine the country of origin?
The country of origin is the country where the last substantial transformation occurred. This is often where the fabric is cut and sewn into the finished garment. However, if the fabric is made in one country and simply assembled in another, the country where the fabric was made may be the country of origin. Consult the CBP guidelines for specific scenarios.
14.3 Do I need to update my labels if the fiber content changes slightly?
Yes. If the fiber content of a garment changes, even by a small percentage, the label must be updated to reflect the new composition. Accuracy is crucial, and any deviation from the stated fiber content is a violation.
Read more:
Navigating the complexities of FTC clothing and textile labeling regulations may seem daunting, but it’s an essential aspect of running a responsible and successful garment business. By understanding the requirements, implementing best practices, and staying informed about any updates to the regulations, businesses can confidently create compliant labels, build trust with customers, and avoid costly penalties.
Accurate and transparent labeling is not just a legal obligation; it’s a cornerstone of ethical business practices and a key to building a strong and sustainable brand. Remember, My Pack Love brand, with more than 8 years of experience in the garment industry, especially in processing labels, tags, and patches for shirts, is a place to provide a solution for labeling needs.
