Government Regulations and Labeling

Government regulations on apparel products range from those requiring informative labeling on
garments to those providing assurances to the consumer that products will not present hazardous
risk. Labels provide a means for the consumer to learn about the garment and assist the consumer in
making informed decisions about selecting and caring for clothing. Beyond the voluntary
information that may be included, clearly and accurately written labels reflect the requirements of a
variety of government regulations. These regulations apply to all apparel products made in and
imported into the United States. Apparel and household textile products destined for export to other
countries may need to meet the requirements of different labeling regulations. For example, many
European countries limit or prohibit the use of azo dyestuffs.

1. REGULATIONS ON APPAREL LABELING

U.S. law mandates that all apparel sold in the United States contain permanent labels that fulfill the
requirements of the Textile Fiber Products Identification Act and the Care Labeling Rule. Garments
made of wool or a wool blend must conform to the requirements of the Wool Products Labeling Act.
Garments fully or partially made of fur must conform to the Fur Products Labeling Act. Labels on
leather products must meet the requirements of the Guides for Select Leather and Imitation Leather
Products. Garments containing feathers or down filling must be accurately labeled to reflect the
type of plumage and the correct ratio of down to feathers. Silk apparel must conform to the Silk
Labeling Regulation. All these regulations are administered by the Federal Trade Commission
(FTC).
Information may be woven in or printed on the label, and labels may be attached in a variety of
ways. Care labels must be permanently affixed and must remain legible throughout the useful life of
the garment. Country-of-origin labels must also be permanently attached. Fiber ID labels need only
be secure at the point of sale. However, fiber ID, country-of-origin, and care information are
commonly combined on one permanently affixed label. FTC regulations specify the location of
country-of-origin labels inside the center back neckline or, if the garment has no neck, in a
conspicuous location elsewhere inside or outside the garment; other labels usually share these
locations. For packaged garments, both the garment and packaging must be labeled unless the
garment's label is visible through the package.

1.1 Textile Fiber Products Identification Act

The Textile Fiber Products Identification Act (16 CFR Part 303), or TFPIA, became effective in
1960 (last amended in 1986). The TFPIA is commonly called "Fiber ID Regs" in the industry, but it
involves more than just fiber identification. It requires labels to disclose three things to consumers:
(1) fiber content, (2) manufacturer or importer, and (3) country of origin. TFPIA labeling must be
permanently affixed to all garments sold in the United States.

1.1.1 Fiber Content Identification.

A garment's fiber content affects its appearance, ease of care, comfort, durability, and cost. Labels
meeting fiber ID requirements disclose the fiber content as a percentage of each fiber in the garment,
in order of predominance by weight. The percentage must be accurate within 3% (with a zero
tolerance for 100% contents). The label must list any fiber constituting more than 5% of the total
weight as other fiber unless the fiber makes a significant contribution to the performance of the
garment. For example, spandex is identified because it affects elasticity even if present as only a
small portion of the total fiber used. Another exception to the 5% rule is wool fibers, they must
always be identified even if they constitute less than 5% of total weight. Garments of unknown fiber
content must be so labeled, for example, 5% undetermined fibers.

1
The fibers used in garment trim, such as lace or ribbon, need not be identified if they cover less than
15% of the garment's surface area, but the fiber content label must include the term exclusive of
decoration. If fiber ornamentation, such as embroidery, constitutes less than 5% of the total weight,
it need not be identified, but the label should read exclusive of ornamentation. If elastic makes up
less than 20% of the garment's surface area, it need not be identified but the label should read
exclusive of elastic. The fiber content of linings and interlinings need to be identified only if they
are incorporated for warmth, in that case the label should identify the fiber content separately from
that of the garment.
The fiber ID regs require that labels refer to fibers by generic names in English. A generic name, as
established by the FTC, denotes a family of fibers with a similar chemical composition. Allowed
are non-English or non-U.S. names (for example. wolle for wool, coton or baumwolle for cotton,
soie for silk. and polyamide for nylon) as long as they appear in conjunction with the English
generic name. Increased global trade makes this a common practice. More recently, the FTC also
allows the use of generic names recognized by ISO, such as viscose for rayon and elastane for
spandex.
The law also permits a trademark to accompany the generic name. The trademark is the registered
brand name for the generic fiber made by a particular producer. For example, polyester is a generic
name. Dacron is a trademark for polyester fibers produced by DuPont. The trademark and generic
name must appear in lettering of the same size and importance and on the same side of the label. In
addition, labels may contain descriptions of fibers in conjunction with their generic names. For
example. the words combed or Pima may be used to describe finer grades of cotton; the terms
worsted or Merino to describe premium wools. The law forbids terms implying the presence of
fibers that are not a part of the garment and terms that are promotional in nature. For example, the
term silky luster may not be used to describe a fabric made of non-silk fibers.
Most manufacturers accept the fiber content information provided by their domestic suppliers, and
most consumers do not question the fiber content on the labels of the garments they buy. Imported
fabrics, however, are generally tested to confirm fiber content due to U.S. Customs regulations.
Occasionally, mislabeling occurs. For example, a garment labeled cashmere may contain sheep's
wool instead of fibers from the Kashmir goat. Another form of mislabeling uses the correct fiber
names but inflates the percentage of one of the fibers. Some trade organizations, such as the Wool
Bureau and Cotton Inc., perform laboratory analyses of random garment samples to check the
accuracy of fiber content labels. Likewise, stringent regulations are applied by U.S. Customs to the
accuracy of labels on imported apparel products.

1.2 Country-of-Origin Identification.

Labels on apparel sold in the United States must identify country of origin, or where the garment
was produced. Because of perceptions about the quality of imported apparel and the effect of
apparel imports on the U.S. economy, country of origin is a noteworthy part of apparel labeling for
customers who want to "buy American". On the other hand, many consumers, especially younger
ones who identify closely with the concept of a global community, may not perceive country of
origin as important in making a purchase decision.
Luxury imported apparel constitutes a limited portion of total imports. Unlike low-price imports,
consumers perceive these goods to be of high quality because of the mystique of the label, for
example, Made in France or Made in Italy. Many luxury imports indeed do possess high quality,
especially those made of natural resources that are the specialties of certain nations. For instance,
wools from Britain, silks from China, linens from Ireland, leathers from Italy, and cottons from
Egypt are among the finest available. In other cases, luxury goods represent uncommon quality in
labor, made possible by generations of experience in a particular craft and an emphasis on factors
other than lowering costs and increasing production volume. For example, London is known for its
exquisite menswear tailoring and Paris for its couture fashions.

2
Low-price imports constitute the majority of apparel imports into the United States. Consumers
often associate these low-price imports with low quality and low fashion appeal. However, country
of origin is not a valid clue to quality; no consistent evidence exists to show that one country of
origin indicates higher or lower quality than another. The sophistication, fashion appeal, fit, and
durability of low-price imported apparel have improved dramatically, so stereotypes about low-
price imported apparel are no longer valid. By the same token, although many U.S. manufacturers
have excellent quality records, others have low quality records. High quality and low quality result
from conformity or nonconformity to quality standards, not from country of origin. By setting
appropriate standards and maintaining them, manufacturers anywhere in the world can produce
quality apparel.
To determine country of origin, the manufacturer is required to name the country where the garment
(or fabric) was "substantially transformed". Substantial transformation is a U.S. Customs Service
term that refers to the transformation of a product by means of a substantial manufacturing process
into a new and different article of commerce, having a new name, character, or use. Since 1984,
garments made in the United States must bear a label reading Made in U.S.A. To qualify for "Made
in the U.S.A." status, a product must be substantially made in the United States; merely finishing or
modifying a partially or nearly complete foreign product is not enough.
Manufacturer Identification.
All garments must contain labels identifying their manufacturer. (For many imports, the name of the
"Importer of Record" is substituted for the manufacturer.) The manufacturer's current identification
number as registered with the FTC, or brand if it is registered with the FTC, must appear on the
label. The reputation of the manufacturer who produced the garment can influence the consumer's
perception of the quality of the garment if the name is also listed, because consumers expect
garments made by a specific manufacturer to be of consistent quality.
A manufacturer's, retailer's, or importer's registered identification number is the number you see
following the letters RN (registered number) on garment labels. A manufacturer may have more
than one RN for various divisions. Some older manufacturers have a WPL number, or Wool
Products Labeling Act number, instead of an RN number. The RN or WPL pinpoints the maker of
the garment, although it can be confusing for a manufacturing retailer using a contractor. Does the
contractor's number get used or the retailer's? Some manufacturers put their own RN on the label
plus an additional number that denotes the contractor who sewed the garment.

1.3 Wool Products Labeling Act

Since 1939 (last amended in 1986), the Wool Products Labeling Act (WPLA) has regulated the
labeling of garments containing hair fibers. It is commonly called the "Wool Act" in the industry.
New wool and virgin wool refer to fibers that have not previously been processed in any way.
Lamb's wool comes from animals younger than seven months old; because it is the first shearing, it
is finer and softer than other wool. Recycled wool refers to wool previously fabricated, possibly
used, and then reclaimed into fiber form. Recycled wool, also called shoddy, represents lower
aesthetic quality than new fibers; otherwise, it is as warm to wear as new wool. Recycled wool is
confined to interlinings and, occasionally, outer fabrics for low-price coats. In addition to wool, the
WPLA also regulates the identification of specialty fibers such as mohair, camel, and cashmere.

1.4 Fur Products Labeling Act

The Fur Products Labeling Act (FPLA) regulates the labeling of garments made of fur-fibers still
attached to the animal skin. It is commonly called the "Fur Act" in the industry. The act, in place
since 1952 (last amended in 1980), requires fur products to carry a label bearing the English name
of the animal. It also requires the label to indicate the country of origin of the fur. The label must
disclose if the fur is waste fur or has been used, damaged, dyed, bleached, or otherwise treated to

3
artificially change the color. Fur trim and fur Items costing under US$150 may be exempt from
some of the FPLA requirements.

1.5 Guides for Select Leather and Imitation Leather Products

The FTC also administers the Guides for Select Leather and Imitation Leather Products (16 CFR
Section 24). This guide applies to most leather and simulated-leather products, including apparel
accessories such as handbags, wallets, footwear, and belts not sold as part of a garment. The guides
generally define how leather products should be labeled. If a product or a part of the product
appears to be leather but is not, the fact that it is not leather should be disclosed (for example,
Manmade Materials or Vinyl Backing). The kind and type of leather should be disclosed when the
product has been processed to simulate another kind or type of leather (for example, Top Grain
Cowhide With Simulated Pigskin Grain). Ground, pulverized, shredded, reconstituted, or bonded
leather products should not be represented as leather, and their labels should disclose the percentage
of leather and nonleather substances in the material. The guides also require a basis for claims such
as waterproof, scuff proof, scratch proof, scuff resistant, and scratch resistant.

1.6 Feather and Down Products

Feather (the outer covering of fowl) and down (the undercoating of waterfowl) products must be
accurately labeled and advertised. Items made of crushed, damaged, or used feathers or down must
be so labeled. Labels also must not misrepresent the content of any filling by erroneously
suggesting that it contains feathers or down, or that it contains feathers or down from a particular
type of fowl, or that the product has been chemically treated to improve its performance, if such is
not the fact. Until recently, the Guides for the Feather and Down Products Industry regulated the
labeling of feather- and down-filled products. The Guides, last revised in 1971, were rescinded by
the FTC in 1998, partly because modern production techniques allow much tighter tolerances
(Within 2-5% rather than Within 30%) for regulating the ratio of down to feathers in a product
labeled "down" than those cited in the Guides. In place of the Guides, the FTC issued a general
enforcement policy statement that continues to prohibit deceptive labeling and advertising of feather
and down products.

1.7 Silk Labeling Regulation

In 1932, the Silk Labeling Regulation ruled that any product labeled pure silk or pure dyed silk
could contain no more than 15% weighting if black and no more than 10% weighting for other
colors. Such weighting, once a common treatment done by soaking the silk in a solution of metallic
salts, increases the weight and improves the hand and dyeability of silk. However, weighted silk is
less durable and wrinkles more easily. Little silk on today's U.S. market is weighted.

1.8 Care Labeling Rule

The Care Labeling Rule, titled Care Labeling of Textile Wearing Apparel and Certain Piece Goods
(16 CFR Part 423), has been in effect since 1972 (last amended in 1984). It requires that apparel
carry a permanently affixed care label providing full instructions for the regular care of the garment.
All ready-to-wear apparel sold to the public must be permanently care labeled, with the exception of
garments that can withstand any care method and items such as hosiery on which a label would
detract from appearance or usefulness. However, such garments must provide care information to
the customer on the product package or on a temporary care label. Garments consisting of more
than one piece require only one care label, although a label in each piece is preferable.

4
1.8.1 Care Symbols.

5
A voluntary standard that provides a set of care symbols and a system for their use was carefully
developed by ASTM Committee D-1362 on Care Labeling to indicate to consumers the
recommended care for apparel and other textile products. In 1996 the FTC approved the ASTM
symbols as the official U.S. care symbols and the following year began allowing their use without
any accompanying words on the label. Other countries are using similar care symbol systems, but a
single, consistent set of care symbols recognized internationally does not exist at the time of this
writing. Several countries participated in the development of the ASTM symbols, a step in the
direction of true global interaction.
The ASTM voluntary system of care symbols consolidates the common elements from the systems
of several different countries. The system uses five basic symbols - a washtub shape representing
washing, a triangle representing bleaching, a square representing drying, an iron representing
ironing, and a circle representing dry-cleaning. An X over the symbol means "do not do it" and may
be used only when the procedure will damage the apparel item. If dots are added to the symbols, the
number of dots indicates the recommended temperature of the procedure, with more dots
representing a higher temperature or heat setting. The machine cycles are represented by underlines,
or "minus signs" below the symbol. "Minus signs" under the symbol reduce the action of the
appliance from the normal cycle to the permanent press cycle (one underline or minus sign) and to
the gentle/delicate cycle (two underlines or minus signs).
Care symbols overcome language barriers in providing care instructions for garments that are
imported or exported, which is important as international trade in apparel continues to grow. These
symbols are useful only to the extent that consumers understand them. The Federal Trade
Commission is coordinating a multifaceted educational campaign to make U.S. consumers more
aware of care symbols and their meanings.

1.8.2 Words Accompanying Care Symbols.

ASTM Committee D-13 has developed a list of Additional Words to Use With Care Symbols. This
list provides supplemental information to be used with care symbols, when necessary. This allows
the writing of consistent care labels and simplifies the production and use of care labels.
The Care Labeling Rule requires that all washing instructions suggest a particular method of
washing - machine wash or hand wash. Drying instructions also must suggest a method - tumble dry,
line dry, or dry flat. The label must be specific about the variation of the method to use if other
variations harm the garment or others being cleaned with it. For example, if a label says Machine
Wash, the consumer can assume that any water temperature and cycle is safe. Otherwise, the label
must state, for instance, Machine Wash, Cold, Delicate Cycle. If the label does not prohibit bleach
in conjunction with washing instructions, the consumer can assume that any form of bleach is safe.
If the garment could harm other garments being washed with it, the label must so warn; for example,
Wash Separately or Wash with Like Colors. The label qualifies the type of solvent or other aspect
of the dry-cleaning process. If trim on the garment requires special care, the label must warn
Remove Trim. Warnings about damaging the apparel need be given only for variations of the care
procedure recommended on the label, not for all possible procedures. In other words, if the label
states Dry Flat, it does not have to warn Do Not Tumble Dry .

1.8.3 Implied Warranty.

A care label is an implied warranty by the manufacturer that if the customer follows the care
instructions, the garment will retain its appearance. The rule requires the manufacturer to
recommend only one care method, although other methods may work as well. The care label must
clearly and thoroughly tell the customer how to care for the garment. It must specify washing,
bleaching, drying, ironing, and/or dry-cleaning procedures and warn against any part of the
prescribed care procedure that would harm the garment or others being cleaned with it. The rule

6
does not allow care labels that are promotional in nature; for example, Never Needs Ironing is
unacceptable.
Care or refurbishing plays an important role in maintaining the existing quality of a garment. Ideally,
the care label recommends a care method that minimizes shrinkage, color loss, and deterioration of
the garment. Manufacturers that impart an understanding of appropriate care procedures to
consumers through appropriate care labeling avoid returns of garments that did not perform well
because of improper care.
Some consumers use care labels in evaluating ready-to-wear for purchase. For example, one
consumer avoids buying garments that require ironing or dry-cleaning, while another expects such
care requirements. In either case, the care label affects the consumer's perception of the quality
and/or performance of the garment. Care labels allow the consumer to estimate the maintenance
costs for the garment, which influence the garment's ultimate cost and value.

1.8.4 Reasonable Basis for Care Labels.

The Care Labeling Rule requires apparel manufacturers to have a reasonable basis for the care
instructions they recommend. A reasonable basis includes evidence such as tests, current technical
literature, past experience, or industry experience. For example, the manufacturer should have proof
that washing will harm a garment that is labeled Dry Clean Only. However, if the label states Dry
Clean without the Only, proof is not necessary (although the FTC has proposed at the time of this
writing requiring proof that garments cannot be safely washed at home if they are labeled dry clean).
Only the apparel manufacturer possesses complete information about the garment and all its
components. Therefore, it makes sense that the apparel manufacturer is responsible for determining
a safe care method for the garment. Testing the ability of the garment to withstand the
recommended care procedure is important. Although testing increases costs, accurate care labeling
pays for itself in the form of fewer returns and more satisfied customers. Garments with inaccurate
labels that suggest damaging care methods lead to dissatisfied customers.
Some manufacturers use the care label instructions written for a particular fabric by its producer.
This is effective if the only raw material required to make the garment is the fabric. When other
fabrics or trim items are added to the mix, preparing care instructions becomes more complicated.
In these cases, the apparel manufacturer conducts research and makes a determination about the
most appropriate care label instructions according to how the components interact with each other.
For instance, do the interfacing and shoulder pads withstand the same care as the body fabric? Will
the findings and trim accept the same care as the fabric? For example, the thread used to sew the
sweater shrank when washed, distorting the armhole seams. Although the care method suggested on
the label did not harm the sweater fabric, it made the sweater unwearable because the thread did not
perform the same as the sweater.
Low labeling of care instructions is sometimes a problem, particularly for manufacturers and
retailers importing apparel. Low labeling involves recommending a more conservative care method
than the garment requires. Manufacturing personnel in other countries who do not have an extensive
knowledge of U.S. care label regulations or U.S. consumer laundering practices do their best to
write appropriate instructions, but this is difficult as they have little experience with U.S. laundering
practices. For example, in some Middle Eastern countries fabric is often dyed using manual
methods. Many of the dyestuffs will not retain color in warm- or hot-water laundering. For this
reason all care labels for garments made of these fabrics are written with Machine wash cold
instructions. This is low labeling as some of the fabric colors do not experience a color loss in
warm- or hot-water laundering when tested.

7
1.8.5 Consumer Responsibilities.
Many consumers do not read care labels. Other consumers read care labels but do not trust them.
They may have had an experience in which following the care labelled to garment failure. Or they
may have successfully used a care method other than the one suggested on the label. Although
consumer "guessing" about the appropriate care for garments may meet with occasional success, it
may also lead to ruining garments through inappropriate care. Consumers use information such as
the fiber content of the garment to decide how to care for a garment. But variations in fibers, yarns,
fabrications, and finishes that the consumer cannot see may cause the garment to require a different
care method than the fiber content might suggest. For instance, although it is true that most cotton
fabrics are washable, the dye in some cotton fabrics bleeds when washed at hot water temperatures
and thus requires cool or warm water temperature. Or, a garment that might otherwise be washable
may contain buttons, trim, or other components that are not washable. Consumers cannot tell these
things from the fiber content label or by looking at or feeling a garment.
Based on the wording of the federal regulation and the small amount of space available on a care
label, apparel manufacturers list only one possible set of care instructions. Other safe care methods
sometimes exist besides the one on the label. Consumers can use the one listed on the label or use
an alternative method at their own risk. Rather than taking care decisions into their own hands,
consumers should communicate with manufacturers and retailers regarding questions about or
dissatisfaction with suggested care methods.

2. REGULATIONS ON APPAREL SAFETY

Unsafe clothing, especially clothing for infants and children, may cause serious injury and even
death. The Consumer Product Safety Commission (CPSC), a division of the FTC, enforces the
Flammable Fabrics Act, which regulates clothing flammability, and other safety issues, including
those addressed in the Federal Hazardous Substance Act (FHSA). The CPSC's Regulations for Toys
and Children's Articles governs sharpness and choking hazards, and Guidelines for Drawstrings on
Children's Outerwear suggests ways for manufacturers to reduce strangling and entanglement risks
involving drawstrings. The FHSA also prohibits the use of dangerous substances, such as lead paint,
on clothing.

2.1 Flammable Fabrics Act

The Flammable Fabrics Act, established in 1953 (last amended in 1988), classifies fabrics
according to how fast they burn under controlled testing conditions (ASTM D-1230). The
regulations apply to clothing textiles, plastics, carpets and rugs, and mattresses and mattress pads.
Title 16 CFR 1610 of the Flammable Fabrics Act sets forth standards for rating wearing apparel
fabrics as follows:
Class 1: normal flammability (suitable for clothing). Flame spread is 3.5 seconds or more for
non-raised fiber fabrics and 7.0 seconds or more for raised fiber fabrics.
Class 2: intermediate flammability. Flame spread is from 4 to 7 seconds and the base fabric
ignites or fuses.
Class 3: rapid and intense burning (unsuitable for clothing). Flame spread is 3.5 seconds or
less for nonraised fiber fabrics and 4.0 seconds or less for raised fiber fabrics and the
intensity of flame is such as to ignite or fuse the base fabric.

The purpose of these standards is to discourage the use of any dangerously flammable fabrics to
make apparel. The manufacture, offering for sale, importation, or delivery of Class 3
(noncomplying) fabrics and articles of wearing apparel is prohibited by law. The CPSC has
identified certain textile products to be dangerously flammable, including sheer rayon skirts and

8
scarves, sheer silk scarves, rayon chenille sweaters, rayon/nylon chenille and long hair sweaters,
cotton and polyester/cotton fleece garments, and cotton terry cloth robes. Manufacturers,
distributors, importers, and retailers of these textile products should carefully evaluate the
flammability compliance of these products prior to sale.
The Flammable Fabrics Act, 16 CFR 1615 and 1616, establishes stringent requirements for infants'
and children's sleepwear. Infants' and children's sleepwear includes clothing sizes 0-6X and 7-14
worn primarily for sleeping and related activities. Included are nightgowns, pajamas, robes, and
other sleep-related accessories, excluding diapers and underwear.
The law requires that each garment be permanently labeled with a Garment Production Unit number
(GPU) or style number and a Fabric Production Unit number (FPU) or style number to identify its
producers in case of a fire-related incident. Manufacturers are required to retain records on each
piece of children's sleepwear produced to verify compliance with the law. The law does not require
labels on children's sleepwear to inform the consumer that the garment complies with federal
regulations, but many manufacturers indicate compliance as a service to the consumer and to
promote the garment.
In 1996, the CPSC voted to amend the children's sleepwear standard under the Flammable Fabrics
Act. The amendments permit the sale of tight-fitting children's sleepwear and sleepwear for infants
aged nine months or under, even if the garments do not meet the minimum standards for flame
resistance ordinarily applicable to such sleepwear. The new amendments became effective in 1998.
For some time, many parents have been circumventing the intent of the children's sleepwear
regulations by allowing their children to sleep in loose-fitting, 100% cotton T-shirts and other 100%
cotton nonsleepwear garments such as underwear or day-wear. The CPSC felt that parents should
be given the option to buy tight-fitting, 100% untreated cotton sleepwear as opposed to the
nonsleepwear garments, considering that the data show that no ignitions have resulted when
children wear tight-fitting sleepwear. Most deaths and injuries are occurring when children sleep in
loose-fitting, nonsleepwear garments, typically T-shirts. Tight fit appears to be a more important
factor than the flame resistance of the fabric because (1) sleepwear that is tight fitting is less likely
than loose-fitting sleepwear to come into contact with an ignition source; (2) even when ignited,
tight-fitting sleepwear is not apt to burn readily because less air is available to feed the fire, and the
proximity of the skin soaks up heat, retarding the spread of fire.
The changes will be accompanied by an information and education campaign to help consumers
understand why the untreated cotton sleepwear garments being allowed on the market must fit
children snugly; why certain types of sleepwear garments will remain flame retardant polyester or
treated cotton; and why loose-fitting, untreated cotton garments should not be used as sleepwear.
Proper labeling will remind consumers of the purpose of the regulations to protect children.
Retailers must understand why it is important to display complying sleepwear separately from
noncomplying underwear and daywear that could be used for sleepwear, so that consumers will not
inadvertently buy a product that is not deemed safe as sleepwear. The CPSC will continue to
monitor fire injury data to insure that the relaxation of the standard does not reduce children's safety.