In this article, learn about:
the essential Federal Trade Commission labeling requirements
how to avoid common labeling compliance mistakes
best practices for building labeling compliance into your production process
Apparel labels may be small, but they carry significant weight. Beyond telling consumers what a garment is made of, they help products clear customs, meet retailer compliance requirements, and satisfy federal regulations. Getting them right can mean the difference between a smooth product launch and costly shipment delays, rejected orders, recalls, or enforcement actions.
In the United States, the Federal Trade Commission (FTC) regulates apparel labeling through the Textile Fiber Products Identification Act, the Wool Products Labeling Act, and the Care Labeling Rule. U.S. Customs and Border Protection (CBP) also enforces country-of-origin requirements for imported goods. Together, these agencies establish the standards suppliers must follow before products reach store shelves.
As retailers continue to strengthen their compliance programs, accurate labeling has become an important part of doing business. Suppliers that build compliance into their production process can reduce risk, move products through the supply chain more efficiently, and strengthen relationships with retail partners.
This guide explains the key labeling requirements for apparel suppliers, including fiber content, country-of-origin, manufacturer identification, care instructions, and recordkeeping.
Fiber Content Disclosure
Fiber content is one of the most closely regulated parts of an apparel label. The FTC requires suppliers to accurately identify the fibers in a garment using approved generic fiber names and list them in order of predominance by weight.
Accurate fiber content starts long before a label is printed. Suppliers should maintain documentation from mills, testing laboratories, and manufacturing partners to support every fiber claim, in case a legal defense is needed against mislabeling charges.
Follow the 5% Rule
Most fibers that make up less than 5% of a garment's total weight can be grouped under the term "Other Fiber." However, there are important exceptions.
A fiber that provides a functional benefit should still be identified, even if it represents less than 5% of the product. For example, a garment containing 4% spandex to provide stretch should identify spandex on the label.
Wool follows different requirements. Under the Wool Products Labeling Act, any amount of wool or recycled wool must be identified by both fiber name and percentage, regardless of how little is used.
Understand Specialty Wool Requirements
Certain specialty wool fibers have additional labeling standards. To label a product as cashmere, the fiber must come from the fine undercoat of a cashmere goat and meet FTC fineness requirements. Wool marketed using "Super" or "S" numbers, such as Super 100s or Super 150s, must also meet specific micron standards established by the FTC. These claims should always be supported by documentation from suppliers or testing laboratories.
Label Biconstituent Fibers Correctly
Some manufactured fibers combine two chemically distinct fiber-forming substances before extrusion. These are known as biconstituent fibers.
When labeling these fibers, suppliers should identify each component fiber in descending order by percentage.
For example:
100% Biconstituent Fiber (65% Nylon, 35% Polyester)
Keeping accurate manufacturing records is especially important when using specialty fibers, as retailers or regulators may request documentation to support fiber claims.
Use Approved Fiber Names
The FTC requires suppliers to use approved generic fiber names on apparel labels. Many suppliers serving multiple global markets also align labels with International Organization for Standardization (ISO) terminology when appropriate. Get the full list here.
Category | Examples / Approved Names | Notes |
Natural Fibers | Cotton, Wool | Cotton may be identified by specific varieties (Pima, Egyptian, Sea Island). Wool refers to fiber from sheep or lambs. |
Specialty Animal Fibers | Cashmere, Mohair, Alpaca, Camel, Llama, Vicuna | These specialty wool fibers may be identified by their common names. |
Other Animal Hair Fibers | Angora rabbit hair, Cashgora hair | Hair or fur from other animals should use the animal name (e.g., "Angora rabbit hair"). |
Manufactured Fibers | Polyester, Nylon, Acrylic, Rayon, Spandex, Acetate, Olefin | Must be labeled using FTC-recognized generic names. |
Permitted ISO Fiber Names | Viscose, Elastane, Modal, Polyamide, Cupro | These internationally recognized names are also permitted by the FTC for specific fiber types. |
Know What the 3% Tolerance Means
The FTC allows a 3% tolerance for unintended manufacturing variations in fiber content. This allowance accounts for normal production variability, and not intentional substitutions.
For example, if manufacturing variation causes a small difference between the tested fiber content and the labeled percentages, the tolerance may apply. It does not permit a supplier to label a garment containing 97% silk and 3% polyester as "100% silk."
Registered Identification Number (RN): Identifying Your Business
Most apparel labels also identify the responsible business. Suppliers can do this by listing their company name or by using a Registered Identification Number (RN) issued by the FTC.
What is an RN?
An RN is a unique number that identifies a business responsible for manufacturing, importing, distributing, or selling textile products in the United States, such as RN 00001 or RN 23004.
While an RN isn't required, many suppliers choose to use one because it:
Saves space on product labels.
Makes manufacturer information easier to verify.
Meets the administrative requirements of many retailers.
Keep Your Information Current
If you use an RN, make sure the information associated with it stays up to date.
Changes to your company name, address, or business status should be reported to the FTC. Keeping your registration current helps retailers verify your information and reduces potential compliance issues.
Care Labels: Helping Consumers Care for Products Correctly
Care labels do more than provide washing instructions. They're required under FTC regulations and help consumers care for garments without causing unnecessary damage.
Manufacturers and importers are responsible for ensuring care instructions are accurate and based on reliable testing or technical evidence.
Include Complete Care Instructions
Most apparel products must include instructions for:
Washing
Bleaching
Drying
Ironing
If a common cleaning method could damage the garment, the label should also include the appropriate warning. For example, if colors may bleed during washing, the label should state "Wash with like colors."
Make Labels Permanent and Easy to Read
Care labels should remain attached and legible throughout the useful life of the garment. The FTC also requires labels to be easy for consumers to find and read. Small, faded, or poorly attached labels may not satisfy these requirements.
Noncompliance Can Become Expensive
Violations of the Care Labeling Rule can result in significant civil penalties. Because regulators may treat each incorrectly labeled garment as a separate violation, even a single production run with inaccurate care labels can create substantial financial exposure.
Testing garments before production and reviewing care instructions during quality assurance can help suppliers avoid costly mistakes.
Related Reading: Retail-Ready Product Requirements for First-Time Suppliers
Label Placement: Make Required Information Easy to Find
Even accurate information can fall short if consumers can't easily find or read it. FTC regulations specify where certain information must appear and how labels should be attached.
Follow Placement Requirements
For garments with a neck, the country-of-origin label should appear at the inside center of the neck. Other important information, such as fiber content or the Registered Identification Number (RN), can appear on the reverse side of the same label or on a separate label, provided it's permanently attached and easy to access.
Before beginning production, confirm your retailer's labeling requirements as well. Many retailers have placement standards that go beyond federal regulations.
Use English for Required Disclosures
Required labeling information must appear in English for products sold in the United States. Suppliers may include additional languages on the same label for international distribution, but the English disclosures must remain complete and clearly legible.
Related Reading: Label, Pack, Ship: A Guide to Walmart Supplier Requirements
Build Compliance Into Your Production Process
Label compliance doesn't begin when artwork is approved. It starts with accurate product data and continues throughout sourcing, manufacturing, quality assurance, and packaging.
Developing a repeatable review process helps reduce errors before products reach retailers or customs officials.
Maintain Supporting Documentation
Suppliers should keep records that support every claim made on a garment label, including:
Fiber composition documentation
Laboratory testing results, when applicable
Country-of-origin records
Supplier certifications
Manufacturing and sourcing documentation
The FTC generally recommends maintaining these records for at least three years. Organized documentation can simplify retailer audits, customs reviews, and regulatory inquiries.
Review Labels Before Production
A final label review can prevent expensive corrections later in the production process.
Before approving a production run, verify that every label includes:
Accurate fiber content
Correct country of origin
Manufacturer identification or RN
Required care instructions
Proper label placement
Catching an error before garments are sewn or packaged is significantly less expensive than relabeling inventory after production.
Common Labeling Mistakes to Avoid
Many labeling issues result from routine production changes rather than intentional noncompliance. Building a quality control process around labels can help suppliers avoid unnecessary delays and rework.
Some of the most common mistakes include:
Listing fibers in the wrong order by weight.
Omitting functional fibers that make up less than 5% of the garment.
Using unapproved fiber names.
Making unsupported country-of-origin claims.
Providing incomplete care instructions.
Using outdated company information or RN records.
Placing required labels where consumers can't easily find them.
Reviewing labels alongside product specifications and retailer requirements before production can help identify these issues early.
Related Reading: The Supplier Maintenance Checklist
Compliance Starts With Accurate Product Data
Apparel labels are one of the last steps in the production process, but they rely on information collected throughout the supply chain. Every fiber claim, country-of-origin statement, care instruction, and manufacturer identifier should be supported by accurate product data.
As retailer compliance programs become more rigorous and regulatory expectations continue to evolve, suppliers that build labeling compliance into their product development process are better positioned to reduce delays, avoid costly corrections, and strengthen relationships with retail partners.
By treating labeling as part of your overall product data strategy, not just a packaging requirement, you can improve compliance, simplify operations, and move products to market with greater confidence.
Interested in more compliance articles for apparel? Check out these links at The Supply Chain Source.