Labeling laws that govern every hangtag and sewn-in tag

The FTC publishes a plain-language guide worth bookmarking: Threading Your Way Through the Labeling Requirements.

The four things a compliant U.S. label must show

1. Fiber content

You must list every fiber that makes up 5% or more of the garment, by percentage, in descending order, using the generic fiber name (for example "cotton," "polyester," "elastane"), not a brand name.

Example: a legga listed as "95% cotton, 5% spandex" is fine. "Spandex" and "elastane" are both accepted generic terms.

Fibers under 5% are grouped as "other fiber" unless they serve a functional purpose (a small percentage of elastane for stretch can be named because it affects fit).

The percentages must be accurate. "100% cashmere" means 100% cashmere. This is exactly where the FTC catches brands: a "cashmere" sweater that lab-tests as a blend is a false claim under the Wool Act.

2. The RN or WPL number

An RN (Registered Identification Number) is a number the FTC issues to a U.S. business, which can appear on the label instead of the company name. It is free to obtain through the FTC website. A WPL number is an older wool-specific version you may still see on legacy stock.

You do not have to use an RN. You can print the full company name instead. But most brands use the RN because it is compact and does not reveal the manufacturer to competitors.

Key point for buyers and sourcing teams: an RN identifies a U.S. business responsible for the product. It is not a mark of quality and it is not a factory code.

3. Country of origin

The label must state where the product was made, for example "Made in Vietnam" or "Made in Italy." For a garment, origin is generally determined by where it was assembled (where the fabric was cut and sewn), not where the fiber was grown.

Imported goods must show the foreign country of origin. "Made in USA" claims are held to a high bar: the FTC requires that a product be "all or virtually all" made domestically to carry an unqualified "Made in USA" label. Getting this wrong is a frequent enforcement target.

4. Care instructions

Under the Care Labeling Rule, the manufacturer must provide at least one safe method of care (washing, drying, ironing, bleaching, dry cleaning), and must warn if a normal care procedure would harm the garment.

Example: a rayon dress that shrinks in water needs a "Dry Clean Only" instruction. If you only test washing and it survives, you can label it washable, but you must have a reasonable basis for the instruction. You cannot guess.

Europe: similar goals, different rules

The EU governs fiber content through Regulation (EU) No 1007/2011 on textile fibre names and labelling. Core differences from the U.S.:

• Fiber content labeling is mandatory and harmonized across all EU member states, using EU-approved fiber names.
• The label must be in the language(s) of the member state where the product is sold. A shirt sold in France needs French; sold in Germany, German.
• The EU does not have a mandatory care-labeling law equivalent to the U.S. Care Labeling Rule. Care symbols are widely used but are generally voluntary and standardized through industry bodies (the "Ginetex" care symbols).

Country-of-origin marking in the EU is more limited than in the U.S. for textiles: "Made in" labeling is not uniformly mandatory for all garments, though customs origin rules still apply for import purposes.

Practical takeaway for a brand shipping to both markets: you often need multi-market labels. A single sewn-in tag might carry fiber content in several languages plus U.S.-style percentages and an RN, so it can ship anywhere without re-labeling.

🎬 [VIDEO: "How to Read a Clothing Care Label" - youtube.com - a short, practical walkthrough of care symbols and what each one means for washing, drying, and dry cleaning]

Where compliance actually breaks

Most labeling failures are not fraud. They are operational gaps.

Mislabeled blends. A factory substitutes a cheaper fiber to hit a cost target and the label is not updated. The brand ships "100% silk" that is actually a silk-polyester blend. Solution: lab-test production samples, not just pre-production samples.

Missing RN on private-label goods. A retailer sells a product under its own brand but forgets the RN or company name. Every unit is technically non-compliant.

Wrong country of origin after a sourcing shift. Production moves from China to Bangladesh mid-season, but the pre-printed labels still say China. This is a customs problem as well as an FTC problem.

Care instructions copied across styles. A team reuses "machine wash cold" from a cotton tee on a wool blend that felts in the wash. If a customer's garment is ruined and the instruction was unreasonable, the brand is exposed.

Who is responsible

Responsibility runs to whoever puts the product on the market. For a brand selling its own label, that is the brand, even if a third-party factory made the error. "The factory did it" is not a defense. This is why sourcing contracts should require the supplier to warrant label accuracy and to indemnify the brand for labeling violations.

A quick worked example

Suppose you are launching a sweater to sell in both the U.S. and France. Lab testing on the production run returns: 70% merino wool, 28% nylon, 2% elastane.

Your compliant label needs:

• Fiber content: "70% Wool, 28% Nylon, 2% Elastane." The 2% elastane can be named because it affects stretch and fit. All three exceed or qualify under the thresholds, so all are listed. Note: because this contains wool, the Wool Act applies, so the wool percentage must be exact.
• Identity: your company name or RN.
• Country of origin: "Made in [assembly country]."
• Care: at least one safe method, for example "Hand wash cold, lay flat to dry, do not tumble dry," assuming you tested and confirmed it.
• France requirement: fiber content also in French ("70% Laine, 28% Polyamide, 2% Elasthanne").

Notice the sweater cannot legally be called "cashmere" or even "wool" without qualification if the wool content were lower. The generic name and the percentage must match what is in the garment.

Key Takeaways

• The sewn-in tag is a legal disclosure. It must show accurate fiber content (every fiber at 5% or more, descending order, generic names), the company name or FTC-issued RN, country of origin, and at least one reasonable care instruction.
• "100% cashmere" and "Made in USA" are the two claims regulators police hardest. Only make them if you can prove them.
• Responsibility sits with the brand that markets the product, not the factory. Put label-accuracy warranties in supplier contracts.
• The EU mandates multilingual fiber labeling and does not require care labels the way the U.S. does. Selling in both markets usually means a combined multi-market label.
• Most violations come from operational drift (sourcing moves, fiber substitutions, copied care instructions), so test production samples and re-check labels whenever anything changes.