SGS Helps Companies Avoid Non-Compliant Labeling In USA

Correct labeling allows manufacturers and importers to legally sell their products in the USA and/or international markets. Correct labeling can speed up importation and reduce addition costs associated with re-labeling and re-shipment.
( | Press Release | 2017-05-08 11:51:47 )
Correct labeling allows manufacturers and importers to legally sell their products in the USA and/or internationally. For importers it can also avoid delays at the point of importation and the subsequent costs of re-labeling and re-shipment. Such issues can also attract consumer complaints and damage brand image. Compliance is particularly important in markets such as the US, where all textile and apparel products have to include the following information:

• Country of origin
• Manufacturer or dealer identity
• Fiber content
• Care instructions (mandatory only for apparel; must be permanently attached to the product)

Size labeling is optional in the US market, although most companies do include it.

Who Must Comply?
The US Federal Trade Commission (FTC) enforces The Care Labeling Rule requiring care instructions to be attached to garments by the following:

• Importers and manufacturers of textile wearing apparel
• Importers and manufacturers of piece goods sold to consumers who make wearing apparel
• Any person or organization that directs or controls the manufacturing or importing of textile wearing apparel or piece goods for making wearing apparel

These labels must also be conspicuous and exposed, to allow for easy access by consumers.

Country of Origin
Although FTC has no requirements for the location of Country of Origin labels, US Customs specifies the position for blouses and items with a waistline. This highlights the need for local knowledge, backed up by global experience.

Manufacturer or Dealer Identity
All product categories must be labeled with the company’s legal name. Textile products may use the Registered Identification Number (RN) of the manufacturer or importer instead of a name, although an RN is not required to do business in the US.

Fiber Content
Textile products - including apparel, accessory items and home textiles - are regulated by the FTC, and subject to the laws within the following acts:

• Textile Fiber Identification Act – 16 CFR 303
• Wool Products Labeling Act - 16 CFR 300
• Fur Products Labeling Act – 16 CFR 301
• The Leather Guide - 16 CFR 24

A few exemptions
The general labeling rules do not apply in a number of cases, including:

• Shoes
• Gloves
• Hats
• Belts
• Suspenders and neckties
• Non-reusable upholstery or mattress stuffing
• Outer coverings of upholstered furniture, mattresses and box springs
• Marked manufacturers’ remnants of up to 10 yards when the fiber content is unknown and not easily determined
• Trim up to 5 inches wide

While there are exclusions to certain products under the Textile Fiber Identification Act, there are other regulations for labelling wool, leather and leather-like materials, and fur. For example, the Guides for Select Leather and Imitation Leather Products - 16 CFR Part 24, helps manufacturers correctly label products made of synthetic leather to avoid misrepresentation to the consumer.

Special claims labeling
The FTC also regulates the functional claims - e.g. moisture management, water proof breathable, and antibacterial - of certain products. This aspect of the FTC’s work – known as Truth In Labeling – ensures that claims are true and substantiated by scientific evidence.

If a product label includes misleading or false information about the item’s contents, care instructions, country of origin, performance claims and so on, it is a case of mislabeling.

So, if a fabric contains 2% organic cotton and 98% non-organic cotton and the label states: “Fine Organic Cotton Blend” it would be misleading to the consumer. This would be considered deceptive advertising.

Manufacturers putting claims on labels or hangtags, such as one stating that a garment provides 50+ protection from UV radiation, must be able to substantiate their claims.

The consequence of mislabeling is a “civil charge” which can cost a company thousands of dollars, if not more. For example, companies that labeled their products as being made of bamboo (when they were actually made of rayon) paid $1.26 million to settle the FTC charges.

For more information contact your local SGS representative, or our global team, and visit Softlines and Accessories.

Louann Spirito
Director - Technical Support, Global Softlines
SGS North America Inc.


About SGS
SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 90,000 employees, SGS operates a network of over 2,000 offices and laboratories around the world.

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