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FTC Seeks Public Comments Regarding the Proposed Changes to the Fur Product Labeling and Advertising Rules

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FTC Seeks Public Comments Regarding the Proposed Changes to the Fur Product Labeling and Advertising Rules

On September 7, 2012 the Federal Trade Commission (FTC) announced the proposed changes to the Fur product labeling and advertising rules and is seeking public comments. The changes are intended to allow more flexibility on labeling and also incorporate the provisions of the Truth in Fur Labeling Act, passed by Congress in 2010.

Below are the specific changes that are being proposed by the FTC

Eliminating the disclosure on the label, invoice and advertisement that the product is made in whole or substantial part with fur obtained various parts of the animal. [16 CFR 301.20(a)]

Eliminating the label size requirement of 1.75 inches by 2.75 inches and following the Textile rules of the label being conspicuous and durable through the cycle of distribution, sale or resale and delivery to the ultimate consumer.

Replacing the 12 point type font size requirement for the label with the requirement to disclose the information in a manner that is readily accessible and legible to the ultimate consumer

Allowing the label to contain true and non-deceptive information on both sides of the label

Removing the requirement to list the information in a particular order (16 CFR 301.30)

Allowing the retailers to use a single label when items are sold as pairs or ensembles and each component contains the same fur, to be in line with the Textile labeling rules

Eliminating the exemption low value fur products ($150 and below) and adopting TFLA’s more limited exemption for (1) fur obtained from trapping or hunting and (2) transactions of the fur obtained from trapping or hunting at a non-traditional selling place such as a residence, craft fair etc by the person whose primary income is not based on the sale of apparel or fur products.

Eliminating the optional to disclose if the fur has been treated with iron or copper [(16 CFR 301.19(l)(1) through (7)], since the “color altered” or “color added” disclosure is a requirement on an invoice.

Deleting 16 CFR 301.28, since the proposed new § 301.27 clarifies the method for label attachment.

Eliminating the assignment of “item number or mark” to furs and disclose the same on invoices and labels (16 CFR 301.40). FTC experience has shown that this information is not needed to enforce the Fur Rules.

Updating the Name guide to correct typographical errors and species misidentifications

Note: Comments must be received by the FTC no later than November 16, 2012. For information on how to submit comments, visit http://www.ftc.gov/opa/2012/09/furproducts.shtm

Bureau Veritas Assistance

If you have any questions about care labeling or other textile or apparel issues, Bureau Veritas offers a full range of testing and softlines solutions. Please contact your customer service representative or email cps.info@us.bureauveritas.com.

Bureau Veritas Consumer Products Services, Inc. ("BVCPS") provides the information in this client bulletin as a resource of general information. It does not replace any applicable legal or regulatory requirements and is provided "as is." BVCPS will not be liable for any indirect, special, punitive, consequential or other damages (including without limitation lost profits) of any kind in connection with this client bulletin. BVCPS DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, IN CONNECTION WITH THIS CLIENT BULLETIN.