American Apparel and Footwear Association

we wear intelligence

AAFA provides a clearing house of information for the U.S. apparel and footwear industry, as well as consumers.

tshirtsonhangers

frequently asked questions

 

Questions:
  1. What rules and which government agency regulate labeling requirements for apparel and footwear?

  2. What are the labeling requirements for apparel?

  3. What are the labeling requirements footwear?

  4. What are the labeling requirements for products with fur?

  5. What are the labeling requirements for products with faux fur?

  6. What kind of care instruction is required on apparel labels?

  7. What is covered under the Care Labeling Rule?

  8. Can care symbols be used in lieu of words on a label?

  9. Are there any exemptions to the Care Labeling Rule?

  10. Is there a standard for sizing in the United States?

  11. Are there any safety regulations in relation to apparel labeling?

 

Answers:

1) What rules and which government agency regulate labeling requirements for apparel and footwear?

The U.S. Customs and Border Protection (CBP) and the Federal Trade Commission (FTC) enforce labeling laws and acts in the United States.

The Textile Fiber Products Identification Act (15 U.S.C. § 70), the Wool Products Labeling Act (15 U.S.C. § 68), the Fur Products Labeling Act (15 U.S.C. § 69), and FTC implementing rules found at 16 C.F.R. parts 303, 300, and 301, require that most apparel products have a label with fiber content, country of origin, and manufacturer identification.

The Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, 16 CFR Part 423 defines the requirements for care instructions on apparel (the rule exempts shoes).

(back to top)

 

2) What are the labeling requirements for apparel?

Labels containing fiber content, country of origin, the identification of the manufacturer, importer, or other dealer, and care instructions must be present at the time the end user takes possession of the good. Labels containing care instructions must be attached permanently to the item.

Apparel products that contain wool, leather, or fur have additional requirements that can be found here on the FTC Web site.

For your benefit AAFA and the Federal Trade Commission have published a guide to help you understand labeling requirements under the textile rules that is on the FTC Web site here.

(back to top)

 

3) What are the labeling requirements footwear?

The only requirement for labels on footwear sold in the U.S. is to have the country of origin on imported products.  (However, most in the industry do include material content).

Footwear products that contain wool, leather, or fur have additional requirements that can be found here.

(back to top)

 

4) What are the labeling requirements for products with fur?

For any product containing fur (apparel, footwear, accessories, etc) the FTC requires a permanent label with the following information:
 

  1. Animal name, according to the fur name guide

  2. Name or Registered Identification Number (RN) of the manufacturer, importer, marketer or distributor

  3. Country of origin for imported fur written as “Fur Origin: Country”

  4. If the fur is pointed, dyed, bleached or artificially colored

  5. If the fur product is composed in whole or substantial part (more than 10% of surface area) of pieces, such as paws, tails, bellies, sides, flanks, ears, throats, heads, scraps, or waste fur

  6. If the fur is used or damaged

  7. The fiber content of any other materials used in the product

For more details visit the FTC Web site.

(back to top)

 

 
5) What are the labeling requirements for products with faux fur?
 

Faux fur is a little more complicated. 

For Apparel: Several states including New York, Massachusetts, Wisconsin, Delaware, and New Jersey have their own regulations that state if an item appears to be fur but is not the label should clearly state that it is “faux fur” and provide the actual material content. 

For Footwear: Footwear does not usually require material content on the label. However, several states including New York, Massachusetts, Wisconsin, Delaware, and New Jersey have their own regulations that state if an item appears to be fur but is not the label should clearly state that it is “faux fur” and provide the actual material content.  Most major retailers require the faux fur label in all products just to be safe and have a product that can be sold anywhere.

(back to top)

 

6) What kind of care instruction is required on apparel labels?

The Federal Trade Commission's (FTC) Care Labeling Rule requires manufacturers and importers to attach care instructions to garments.  Labels for clothing must have a washing instruction or a dry-cleaning instruction. If the item can be washed and dry-cleaned, the label needs only one of these instructions. However, you may want to consider that consumers like having washing instructions for items that can be washed. If you prefer, you can give instructions for both washing and dry-cleaning.

For more information on complying with the Care Labeling Rule, visit the Federal Trade Commission’s Clothes Captioning Guide.

(back to top)

 
7) What is covered under the Care Labeling Rule?
 
Textile apparel that is worn to cover or protect the body is subject to the Care Labeling Rule. 
 
Shoes, gloves, and hats are exempt from the rule.
 
Several items are excluded including handkerchiefs, belts, suspenders and neckties because they do not cover or protect the body.
 
8) Can care symbols be used in lieu of words on a label?
 
Yes.  The American Society for Testing and Materials (ASTM) designated as ASTM Standard D5489-07, Standard Guide for Care Symbols for Care Instructions on Textile Products, may be used in place of words, but the symbols must fulfill the requirements of the Rule.  Although there are several different sets of care symbol standards around the world, only the ASTM symbols have been approved for use in the United States. There is no requirement to use symbols, they are just an option.  AAFA is working to harmonize the ASTM symbols with other international standards to ease the burden on our members who sell products worldwide.
 

(back to top)

 
9) Are there any exemptions to the Care Labeling Rule?
 

Yes.

The following items do not need permanent care labels, but must have obvious temporary labels at the point of sale:

  • Totally reversible clothing without pockets.

  • Products that may be washed, bleached, dried, ironed, and dry-cleaned by the harshest procedures available, as long as the instruction, "Wash or dry-clean, any normal method," appears on a temporary label.

  • Products that have been granted exemptions on grounds that care labels will harm their appearance or usefulness. You must apply for this exemption in writing to the Secretary of the FTC. Your request must include a labeled sample of the product and a full statement explaining why the request should be granted.

The following items do not need any care instructions:

  • Products sold to institutional buyers for commercial use. For example, uniforms sold to employers for employee use in job-related activities, but not purchased by the employees.

  • Garments custom-made of material provided by the consumer.

  • Products granted exemptions under Section (c)(2) of the original rule because they were completely washable and sold at retail for $3 or less. If the product no longer meets this standard, the exemption is automatically revoked.

(back to top)

 
10) Is there a standard for sizing in the United States?
 

No. There is no standard for sizing.

(back to top)

 
11) Are there any safety regulations in relation to apparel labeling?
 

Yes. There are some regulations under the Consumer Product Safety Improvement Act (CPSIA) in response to the flammability of clothing textiles including:

  • 16 CFR §1610 – Standard for the Flammability of Clothing Textiles

  • 16 CFR§ 1615 and 1616 – Standards for the Flammability of Children’s Sleepwear

For more information please contact Marie D’Avignon or Michael McDonald

You may also contact the Consumer Product Safety Commission directly (Contact: Mary Toro, CPSC, Director- Division of Regulatory Enforcement, (301) 504-7586).

(back to top)

 

 
Below are questions about specific topics that have been submitted by users.
 

Labeling (user-submitted) Questions

Questions And Answers

Where is the mandated label placement for t-shirts?

All products sold in the U.S. that have a neck (shirts, jackets, vests, etc.), should have a label containing country of origin information attached on the inside center of the neck.  The fiber content, care, and manufacturer can appear on the same label (front or back) or on another conspicuous and readily accessible label(s) on the inside or outside of the garment.  Usually, if this second label is not on the neck, it is on the inside seam close to the bottom of the shirt.  

For pants, skirts, shorts, etc., the label must simply appear in a place that is easy to see and easily accessible.  Most often, these labels are found in the waste band of these types of products.

back to top

Under the new Truth in Fur Labeling Act, what are the labeling requirements for ladies footwear, such as pumps or mules, with fur trim? Is footwear included in the new act?

Yes, footwear is included under the Act.  All products containing fur must have a permanent label with information on the origin and details of the fur used.  Please see the above answer on labeling requirements for fur products for more details.  

back to top

Have there been studies identifying how many dry cleaning cycles represent the life a garment?

For determining lifecycle in relation to the length of time a permanent label must be able to remain on a garment, the standard of 30 washes is often used in the United States and Canada.

back to top

if i am producing a reversible inside out vest with no pockets, where must i put the name label and country of origin ?

In this instance, the information can be included on a hang-tag or non-permanent label. Under the Federal Trade Commission (FTC) Care Labeling Rule (16 CFR Part 423) – Section 423.8 (a) “Any item of textile wearing apparel, without pockets, that is totally reversible (i.e., the product is designed to be used with either side as the outer part or face) is exempt from the care label requirement.” (c) “If an item is exempt from care labeling under paragraph (a) or (b), of this section the consumers still must be given the required care information for the product. However, the care information can be put on a hang tag, on the package, or in some other conspicuous place, so that consumers will be able to see the care information before buying the product.”

http://www.ftc.gov/os/statutes/textile/carelbl.shtm

back to top

I am curious about country of origin placement requirements for backpacks. Where do the labels need to be sewn in and are there any restrictions.

The United States Department of Customs and Border Protection has below guidance on COO placement:

‘The marking should be located in a conspicuous place. It need not be in the most conspicuous place, but it must be where it can be seen with a casual handling of the article. Markings must be in a position where they will not be covered or concealed by subsequent attachments or additions. The marking must be visible without disassembling the item or removing or changing the position of any parts.’

back to top

In a 2pc set such as a suit, can the jacket have different care instructions from the bottom?

Yes.  If the suit pieces require different care instructions or are designed to be sold separately, like coordinates, then each item should have its own care instructions.

 

For more information please refer to this site: http://business.ftc.gov/documents/bus50-clothes-captioning-complying-care-labeling-rule

back to top

What is the CA # on a label and what does it stand for?

 

The CA# on a label is used in Canada as an identifier for the Canadian dealer (manufacturer, importer, or seller of the product) in place of the company name and address.  Businesses can register for a CA number through the Canadian Competition Bureau.  The CA# is similar to the RN# used in the United States to identify U.S. companies.
 
For frequently asked question regarding the CA# please visit this site:

http://www.competitionbureau.gc.ca/eic/site/cb-bc.nsf/eng/02576.html

back to top

If i have a complete reversible garment without pocket, how can I indicate COUNTRY OF ORIGIN, fiber content and care instructions? Is it possible to use an hang tag? Thanks and best regards

 

In this instance, the information can be included on a hang-tag or non-permanent label. Under the Federal Trade Commission (FTC) Care Labeling Rule (16 CFR Part 423) – Section 423.8 (a) “Any item of textile wearing apparel, without pockets, that is totally reversible (i.e., the product is designed to be used with either side as the outer part or face) is exempt from the care label requirement.” (c) “If an item is exempt from care labeling under paragraph (a) or (b), of this section the consumers still must be given the required care information for the product. However, the care information can be put on a hang tag, on the package, or in some other conspicuous place, so that consumers will be able to see the care information before buying the product.”

http://www.ftc.gov/os/statutes/textile/carelbl.shtm

back to top

What are the labeling mechanics for footwear? Must the durability of the label details for footwear (size,width,COO) be permanent or is point of sale sufficient?

The Country of Origin label must be permanent.  Size is not required to be labeled in the United States, so this information can be provided in any manner as long as it is not misleading to the consumer.

back to top

What are the labeling requirements for small leather goods?- leather wallets, leather card case etc

As wallets (and presumably card cases) are exempt from the general textile labeling requirements, the only label you are required to have is country of origin.  That being said, if you are advertising the wallets as leather, then you should have a label stating that.  Labels should be used to a) back up marketing claims and b) avoid anything that could be seen as deceptive.  For example: if you are advertising a product as leather, but it is really 50% leather and 50% vinyl and you do not have a label explaining that it would likley be seen as deceptive by the FTC. 

 

There are no set rules on how to label leather goods, however, there are many guidelines on how not to label them and they all relate back to the FTC’s stance that labels should be truthful and easy to understand.  Sections 24.1 and 24.2 of the Guides for Select Leather and Imitation Leather Products explain how to avoid deceptive labeling: http://www.ftc.gov/os/statutes/textile/gd-leath.shtm

back to top

I have a leather purse whose packaging stated 100% cowhide, but the inside label said 100% leather. Can a hang tag on the purse that states 100% cowhide to match the packaging satisfy requirements under 16 CFR 24 so as not to be misleading?

 

It must say the same thing on the hang tag and the permanent label, if not it is misleading.

back to top

Can care/content labels be removable by the consumer? In other words, could we simply tag an item with a tethered label?

No.  Except in special circumstances, care labels must be permanently attached to the product throughout the entire lifespan of the product.

For more information, please visit: http://business.ftc.gov/documents/bus50-clothes-captioning-complying-care-labeling-rule

back to top

I am shipping goods from China to USA, the care instructions are correct but 1 of the care symbols is wrong, will this be checked by customs?

It is always best to assume that all goods will be inspected thoroughly during the Customs Clearance Process.  

back to top

Dear Mr, Mrs,In the FTC/AAFA apparel guideluines for labelling i can't find information on the required languages on the content and care label.Could you let me know where i can find this information for a globally operating company? Kind regards

For products meant to be sold in the United States, the care and content information must be disclosed in English (however other languages are allowed to be present as well).  Most countries require this information to appear in the native language of the country/region.  The U.S. Office of Textiles and Apparel has a helpful list of which languages to use in which country available online at: http://web.ita.doc.gov/tacgi/overseasnew.nsf/d1c13cd06af5e3a9852576b20052d5d5/fad8900a6a29da2b8525789d0049ea04?OpenDocument

back to top

Can't find what you are looking for?

in the spotlight

Join us on April 7-9 in Washington, D.C., for the 12th Annual AAFA International Sourcing, Customs & Logistics Integration Conference > 

legislative action

The Affordable Footwear Act is a common sense duty reduction on low-cost and children's footwear. Learn more about stomping out the shoe tax >

 

ABOUT SSL CERTIFICATES