Textiles Labeling Requirements in the United States

Posted on Leave a comment

Textile Labeling Requirements in the United States

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.


FREE CONSULTATION CALL (US, EU & UK)

  • Request a free 30-minute call with Ivan Malloci to learn how we can help you with:
  • Find product requirements
  • Certification and labeling
  • Lab testing

REQUEST A CALL

16 CFR Part 303 – ​​Rules and Regulations Under the Textile Fiber Products Identification Act

16 CFR Part 303 sets requirements for textile products. This section explains its scope, exemptions, and labeling requirements.

General 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.

Covered products

Here we list several textile products covered by the act, the rest of which are listed in 16 CFR Part 303.45(a):

  • Articles of clothing intended for individuals to wear
  • Dishcloths and washcloths
  • Draperies
  • Furniture slip covers or coverlets
  • Handkerchiefs
  • Scarves for dressers and other furniture
  • Towels

Exempted products

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.

Labeling requirements

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:

  • “100 percent cross-linked rayon”
  • “100 percent solution dyed acetate”
  • “100 percent combed cotton”

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 Act

16 CFR Part 301 requires manufacturers to comply with the labeling rules and regulations under the Fur Products Labeling Act.

General requirements

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).

Covered products

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.

Exempted products

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.

Labeling requirements

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:

  • Alpaca
  • Caracal Cat
  • Grey Fox
  • Cape Jackal
  • Stone Marten

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

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 of 1939

Manufacturers of wool products must comply with the labeling rules in 16 CFR Part 300 under the Wool Products Labeling Act.

General requirements

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).

Covered products

This part covers products that are made from wool, as well as products that contain both wool and other constituent fibers.

Exempted products

According to Section 68j of the FTC’s Title 15, Chapter 2, products excepted from the wool products labeling requirements include items such as:

Labeling requirements

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:

  • Factually incorrect
  • Fallacious
  • Deceptive

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 Amended

16 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:

  • Machine washing – “Wash inside out”
  • Hand-washing – “Rinse thoroughly”
  • Drying – “Tumble dry”

You might also use care symbols to complement care terms. However, if you use the symbols established in ASTM Standard D5489–96c, it is not necessary to also use care terms.

Size

To 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 D5219-15 – Standard Terminology Relating to Body Dimensions for Apparel Sizing.

b. ASTM D6192/D6192M-19 – Standard Tables of Body Measurements for Girls, Sizes 2 to 20 (Reg & Slim) and Girls Plus.

c. ASTM D6458/D6458M-19 – Standard Tables of Body Measurements for Boys, Sizes 4 to 20 Slim and 2 to 20 Regular.

d. ASTM D6860/D6860M-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 Textiles

For some textile products, additional labeling requirements might apply.

CPSIA

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:

  • Manufacturer’s name
  • Date and location of manufacture
  • Batch number

Flammable Fabric Act

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 1610 – Standard for the Flammability of Clothing Textiles and 16 CFR Part 1611 – Standard for the Flammability of Vinyl Plastic Film set labeling requirements for fabrics not customarily washed or dry-cleaned.

b. 16 CFR Part 1615 – Standard for the Flammability of Children’s Sleepwear: Sizes 0 Through 6X and 16 CFR Part 1616 – 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 1630 – Standard for the Surface Flammability of Carpets and Rugs and 16 CFR Part 1631 – 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.

FAQ

Here are some answers to frequently asked questions regarding whether labeling and care instructions are required for different textile products.

Is labeling required for clothing textiles?

Manufacturers must provide labeling for clothing textiles, which should include the following information:

  • Fiber composition content
  • Traceability information
  • Country of origin
  • Claims (if any)
  • Care instructions

According to the product, e.g. children’s sleepwear, additional labeling requirements might apply.

Is care labeling mandatory for clothing textiles?

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 D5489–96 standard, or a combination of care terms and symbols.

Is size mandatory for clothing textiles?

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.

Is labeling required for children’s clothing?

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.

Is labeling required for home textiles?

According to 16 CFR Part 303.45, manufacturers must provide labeling for home textiles, such as:

  • Handkerchiefs
  • Towels
  • Sleeping bags

Other home textile products might also require labeling.

Is labeling required for textile accessories?

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.

  • (USA & EU)

    FREE CONSULTATION CALL (US, EU & UK)

    • Request a free 30-minute call with Ivan Malloci to learn how we can help you with:
    • Find product requirements
    • Certification and labeling
    • Lab testing

    REQUEST A CALL



    Disclaimer: The Site cannot and does not contain legal advice. The legal information is provided for general informational and educational purposes only and is not a substitute for professional advice. Accordingly, before taking any actions based upon such information, we encourage you to consult with the appropriate professionals. We do not provide any kind of legal advice. THE USE OR RELIANCE OF ANY INFORMATION CONTAINED ON THE SITE IS SOLELY AT YOUR OWN RISK.

    Full Disclaimer: Link

    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • ec.europa.eu
    • echa.europa.eu
    • ecfr.gov
    • cpsc.gov
    • ftc.gov
    • fcc.gov
  • Leave a Reply

    Your email address will not be published. Required fields are marked *

    Free Training Session

    Product Compliance in 2024

    1. United States, EU, and UK

    2. Product examples & case studies

    3. Ask your questions via Live Chat!