US Care Labeling FAQ

What rule or regulation governs care labeling? Is it mandatory?
The Care Labeling Rule was issued by the Federal Trade Commission under 16 CFR 423. It is mandatory to label textile wearing apparel and “certain piece goods.” The term “certain piece goods” refers to textile products sold by the piece from bolts or rolls for the purpose of making home-sewn textile wearing apparel. The rule exempts shoes, gloves and hats.
Who is responsible for labeling under this rule?

Manufacturers and importers of textile wearing apparel, or piece goods for making wearing apparel, are responsible for labeling. Parties that direct or control the manufacture or import of textile wearing apparel, or piece goods for making wearing apparel, must also comply with the rule.
Is there a standardized format for care symbols that manufacturer should use?
Only the symbols presented in standard ASTM D5489-96c, Standard Guide for Care Symbols for Care Instructions on Textile Products, have been approved for use in the United States.
Is it mandatory to perform testing to confirm the care instruction on the label?
The rule states that “care instructions shall not cause substantial harm to the product if followed.” It also requires that responsible parties possess reliable evidence to document any instructions or warnings placed on a care label. The key elements of reliable evidence include: it is acceptable to the industry, it is documented in writing, and it is in your possession. Thus, it is recommended that testing be performed to ensure that the care instructions are accurate.
What information is required on a care label?

Care labels must state what regular care is necessary for the ordinary use of the product. If the garment cannot be cleaned without harm, a warning should be provided. “Care instructions shall not cause substantial harm to the product if followed.”
Can care instructions be on the fiber content label?
It is acceptable to include care instructions on the fiber content label as long as it is attached or affixed in such a manner that it will not become separated from the product, and will remain legible during the useful life of the product.
Does the care label have to be permanent?
Other than an exemption under the regulation, care labels must be permanently attached to the product.
What is the minimum care instruction?
At a minimum, care instructions should contain either dry cleaning instructions or washing and drying instructions. However, all elements of a proper washing instruction have to be considered, i.e. washing, drying, ironing, bleaching and warnings. For example: “Machine wash. Tumble dry." Without specifying a temperature, this would mean the product can be machine washed and tumble dried at any temperature. Absence of ironing, bleaching and warnings imply that ironing is unnecessary (or it is safe to iron at a hot setting), and that any type of bleach can be used and that warnings are not required.
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Bureau Veritas Consumer Products Services, Inc. ("BVCPS") provides the information in these frequently asked questions "as is." In no event will BVCPS be liable for any loss in profits, business, use or data or for indirect, special, incidental, consequential or other damages of any kind in connection with these frequently asked questions. These frequently asked questions are a resource of general information and do not constitute the legal or other professional advice of BVCPS. Readers of these frequently asked questions should seek legal counsel regarding statutory or regulatory requirements discussed in these frequently asked questions. BVCPS DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, IN CONNECTION WITH THESE FREQUENTLY ASKED QUESTIONS.

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