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.