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  Labeling

So now we need a way to track our products after they've left for recall purposes; we need a way to remember exactly what went into each product that we've sent off; we need a way for customers to remember where they got their product if an issue arises; we need a way for customers to remember where they got their product to share with others. How the heck do we do this?

Labeling.

Now, depending on the product you make, you may be required to have more information than other products. Labeling is dictated by numerous agencies, both federal and state. Let's start with the basics.

 

Federal Trade Commission (FTC)

The FTC has jurisdiction over basic trade laws mostly in regards to deceptive advertising, marketing, and selling in general. They have a fantastic webpage called Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts that goes through various products. They've formatted the page to easily pick out the types of products and what labeling they may or may not need. The first box contains products that require the information to be securely attached (we'll come back to this). The second box are items that are not covered by the Textile Act. The third box contains items that are only covered if you make a mention of fiber content anywhere in your business. The fourth box is another list of items not covered by the Textile Act.


The FTC requires a non-permanent, secure tag attached to the product. "Secure" means that it lasts until the final consumer receives the product (think like a price tag that you clip off before use).


Identification of Manufacturer, Importer or Other Dealer

For most of us, this will simply be our chosen business name.

The Identification may be replaced by a Registered Number obtained from the FTC. This is most often used for private labeling of others' goods.


Fiber Content

Use the information provided to you from the fabrics you've purchased. If on a bolt, the bolt-end will have this information. When using multiple materials, use sectional disclosure (bodice, sleeve, skirt, front, back, toe, etc.).


There is a 3% leeway permitted for fiber content exempt for items that contain wool. Wool must be listed in exact percentages.


One area that trips many up is the potential use of Lycra® spandex. "Lycra®" is a brand of spandex so be certain that your material is, in fact, made with the branded spandex. If it is, list it as 'Lycra® spandex'. If it is not or you are unsure, simply leave it as 'spandex'. Elastane is another word for spandex used mostly in European countries.


Country of Origin


The FTC requires country of origin to be fully accurate with including the origin of where the fabric was made. So if you use materials made outside of the USA, you need to add that clarification "Made in USA of Imported Material" or "Made in USA of Material from Indonesia". Customs may require this information to be permanently attached so that it lasts the useful life of the product. Things like wipes, towels, napkins, sheets, pillow cases, and other flat goods do require this information to be permanent. 

Federal Trade Commission (FTC)

Next, the FTC has jurisdiction over the labeling of all clothing. Again, they have a great webpage called Clothes Captioning: Complying with the Care Labeling Rule (they are quite witty in their article naming).


Here, you will be required to have a label that is permanently attached in some way so that it lasts the useful life of the product under the provided care instructions. While there is no government definition of how long "permanent" is, it is fairly safe to say that the useful life of clothing tends to be about 3 months considering the seasons and the growth of children (in fact, most children's clothing is sized in 3 month increments).

There are 5 main parts to the care information

  1. Washing by hand or by machine (include temp if hot water will harm the garment)
  2. Bleaching (this may be no bleach, chlorine only, etc.)
  3. Drying by air, blocking, machine, etc. (include temp if heat will harm the garment)
  4. Ironing (include temp or no iron)
  5. Warnings (such things as 'no softener' or 'like colors only')

Base your care instructions off of the information provided on the bolted fabric and your actual garment. For example, cloth diapers need a different wash routine than most clothing. 

Consumer Product Safety Commission (CPSC)

The CPSC has jurisdiction over all products. Yes, all products. This doesn't mean that all products have specific regulations to follow though, this simply means that if there is a safety issue with a product, they are the agency that enforces the process of remedy.


As far as labeling goes, we'll focus on children's products. While the CPSC does require other products to have labeling, those are products not typically made by at-home artisans like yourself.


The CPSC requires the following information on all children's products that are intended, sized, and used by ages 12 years old and under.


  • Manufacturer or private labeler name
  • City & State of manufacturing
  • Information to ascertain the specific source of the product (typically a website)
  • Date of Manufacture (Month & year at minimum)
  • Unique Code/Batch/Run Number (helps in the event of a recall)

Other children's items like toys may require additional labeling due to small parts or other dangers. Much of this information can be found in the ASTM Publication for the specific item being made. 

Please note that there are additional agencies and requirements that may come into play depending on what your product is. For example, blankets, pillows, and other similar items may require what is called a "Law Label". This is a state requirement through the bedding and stuffing agencies and not a federal requirement. Search "bedding requirements" for your state.


One last note. If you use pre-made items, you do not necessarily have to remove the existing tag. Just add to it any information that is missing. If any information is to change (such as care information), then you will need to remove the incorrect information and replace it with the new correct information.