16 CFR Part 303: Rules and Regulations Under the Textile Fiber Products Identification Act, Project No. P948404 #00003 

Submission Number:
Adam Varley
Vartest Laboratories, Inc.
New York
Initiative Name:
16 CFR Part 303: Rules and Regulations Under the Textile Fiber Products Identification Act, Project No. P948404

It is my understanding that the Act provides for cashmere to be classified as wool (obviously not for wool to be classified as cashmere) for labeling purposes whereas yak may not be treated in the same manner but must be explicitly called out if present. This seeming double standard creates difficulties for both microscopists responsible for explaining fiber content tests, and entities such as retailer quality control departments responsible for developing nominal or labeled values for fiber, yarn, fabric, apparel and other end use items using test reports and other resources as basis. Particularly in lower quality woven and knitted fabrics composed of cashmere and wool, a group of animal fibers can sometimes exist which are difficult to classify with respect to the type of animal from which they came due to indistinct appearance attributes in the fibers encountered. The presence of yak fibers in these blends can render classification even more difficult. These difficult to classify fibers can be broken out as a percentage by weight of the blend being analyzed by the microscopist and reported as such along with the percentage by weight of fibers which were readily classifiable. When the test report containing this information is used by the person requesting the test to develop a fiber content label the above mentioned difficulties occur: If a small amount of yak fiber is identified in a wool cashmere blend then currently it must be explicitly broken out rather than being able to be included as wool for labeling purposes. If the microscopist finds that fibers in the indistinct appearance attribute group may be yak then these fibers also may not be allocated to wool by the entity responsible for developing the fiber content label. The term wool is defined under 303.1 (s) as: “The term wool means the fiber from the fleece of the sheep or lamb or hair of the Angora or Cashmere goat (and may include the so-called specialty fibers from the hair of the camel, alpaca, llama, and vicuna) which has never been reclaimed from any woven or felted wool product.” By adding “yak,” after “llama,” the Act would be more readily able to accommodate a fiber of commerce which is at times found masquerading as cashmere but is also at times used in its own right.