The legalities of labeling

I notice the Federal Trade Commission has prepared a document entitled Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts regarding labeling requirements for sewn product manufacturers in cooperation with the now defunct American Apparel Manufacturer’s Assoc. There’s a pdf version if you prefer to print it out for offline reading.

I recommend that DEs file for an RN number, even I have one. With an RN number, any retailer who is shopping their competition and sees your product line and thinks you’d be a good fit for them, can find you. It doesn’t matter if your location is not listed on your hang tag because they can search the RN database which is free and open to the public (online).

There are no fees to get one. To file an application for an RN number, you can either use the print form or use the secure online filing procedure . Similarly, if you’d like to know the manufacturer behind a given label, you can search for it here. This is a free service open to consumers and businesses alike.

Important: While you may not have an RN number or be required to have one, you are legally required to comply with labeling regulations. There is no small company exemption. This extends beyond sewing in the appropriate label. Consider this passage below; it is more typical to find people are in violation of this rule than they are likely to be compliant.

When a textile or wool product is advertised in a catalog or other mail order promotional material, either printed or disseminated on the Internet, the description must include a clear and conspicuous statement that the item was either “made in U.S.A.,” “imported,” or “made in U.S.A. and [or] imported.” Of course, catalog information about origin must be consistent with the information on the label. (See Country of origin in mail order advertising.)

This means that those who fail to disclose the country of origin (country of manufacture) within the advertising and catalog guidelines are in violation of the FTC regulations. While it’s highly unlikely that a manufacturer who fails to disclose their products are “made in the USA” are subject to sanction, failing to disclose off-shore production origin can constitute unfair trade practices.

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15 comments

  1. kathleen says:

    This is a compilation and crude importation of all the comments posted at the original site for this document. Feel free to add your comments.
    ————————
    4/2/2005 09:53:20 AM Mike C said:
    What’s interesting is that almost no apparel websites, even those of the large companies, follow the labeling rules for websites.

    4/2/2005 08:13:27 PM Kathleen said:
    yeah, I noticed that too. that’s kind of why I thought to mention that specifically.

  2. Apparel manufacturing in Canada pt 2

    As I was saying – in addition to a world class reputation for quality, the primary advantages of partnering with our friendly neighbors to the north are: 1. NAFTA 2. Terms of trade 3. Shared language and cultural history 4….

  3. DaniMc says:

    I apologize if its there and I’ve missed it, but what are the labeling requirements for domestically produced leather fashion accessories?

  4. Johnny says:

    I am designing a T-shirt line and I was wondering how creative one can get with the labeling requirements. I read “Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts,” but hopefully someone can provide a bit more clarification.

    On p.28 it says “In a garment with a neck, a label disclosing the country of origin must be attached to the inside center of the neck.” I just came back from Bloomingdale’s and I noticed that some of the T-shirt brands only have their company name inside the center of the neck. Or some will only have their company name and size, but not the country of origin as stated in the rules above. I noticed that they put the country of origin on the front of the care label tag sewn inside the body. Am I misinterpreting the rules? How do they get away with this?

    From what I have read, the main things to include are the fiber content, country of origin, and business name. I have seen a few brands get somewhat creative with their label, and I was wondering if it matters what order you put the above requirements in?

    The document also states “Other non-required info can be included with required info as long as it is not deceptive.” I would like to write something like the following, in this exact order for my label:
    *My company name
    *100% Cotton
    *Something interesting about each screen-print.
    *Made in El. Salvador by my Uncle. Or, Made by my Uncle in El.Salvador

    Does the above label look legal? Thanks for all the help and hopefully someone knows if one can arrange the label essentials in any order and how creative one can get.

    Thanks,
    Johnny

  5. vee says:

    I own an apparel business and was curious about the labels. My suits that I purchase from New York are already labeled but now I am understanding the hats and scarfs I make must have a label with my company name, designers name which is me, origin, care and content along with RN. After I register for an RN number, I must then order labels that include all of this information. I retired and started my business this year and I believe I finally understand having labels in my hats and on my scarves.

  6. David says:

    Hey there… just wanted to say great work for this very interesting series regarding the legal issues related to the fashion industry. I think this type of information and help is really valuable to fashion entrepreneurs and students… thumbs up ;)

  7. vee says:

    I applied for my RN number and recieved it today. I read and understand that everything I sell does not have to have an RN number. This will help my business tremendously.

  8. ConnieD says:

    I am purchasing wholesale tshirts made in Vietnam and screen printing on them. I am removing the manufacturer tags and replacing with my brand name, RN number and all content information that were on the labels I removed.
    Do I need my RN# and the country of origin to appear on the front of the label, or can they be on the back (it is a folded label) with the additional info?
    I couldn’t find the answer to this on the FTC website, hope you can help.
    Thanks

  9. Trish says:

    As always, a fabulous post, thanks.

    For me the pdf version of Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts would not come up. Will you see if it works for you and if not, repost it?

  10. Trish, I tried using IE 6.0 and Firefox 3.6.8 and I can access the link and download the pdf in both. I can try later on my mac at home, but it doesn’t seem to be a problem with the link.

  11. Kathleen says:

    Not too long ago I had to edit this post with a new link to the FTC site and the pdf link was fine then -but I couldn’t get it to load this afternoon. So, I’ve updated it. Hopefully it’ll be a few more years before they change it again (this is the third or fourth time!).

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