Keep it under your hat

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Usually when someone says “keep it under your hat,” they’re asking you to keep information confidential.  But when the FTC staff says “keep it under your hat” – and the hat in question is made of wool – we mean the exact opposite.  To us, it’s a reminder to marketers that hats containing wool must have labels that clearly disclose what the product is made of.

Maybe the cold weather has us all focusing on headgear, but we were recently asked if the Wool Products Labeling Act and the FTC’s Wool Rules apply to hats containing wool.  Here’s the short answer:  Yes.  But if you’re in the fashion or textiles business, you might be looking for more detail – so here goes.

The Wool Act and the FTC Rules require marketers to attach to every covered wool product a label that gives consumers four key pieces of information:

  1. the percentage by weight of wool, recycled wool, or other fibers accounting for 5% or more of the product, and the aggregate of all other fibers;
  2. the percentage of the total weight of the product that is made of non-fibrous matter;
  3. the name – or RN number – of the manufacturer or other responsible company; and
  4. the country where the wool product was processed or manufactured.

The Wool Act defines “wool” pretty specifically as the fiber from the fleece of sheep or lambs or hair of the Angora or Cashmere goat, as well as the hair of the camel, alpaca, llama, and vicuna.  With a few exceptions spelled out in the law, the Wool Act and the FTC Rules cover any product containing wool – and that includes hats.  And whether it’s a top hat, a Trilby, or a Tam o’ Shanter, if it’s made of wool, Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts offers guidance on labeling wool products accurately.

But those aren’t the only looming questions about textiles.  The FTC will host a public roundtable on March 28, 2014, in Washington, D.C., to consider proposed changes to the Care Labeling Rule.  (The event was originally scheduled for last fall, but had to be postponed due to the government shutdown.)  Interested in volunteering as a panelist?  Nominate yourself by February 28, 2014.  The deadline for comments is April 11, 2014.



Thanks for another great blog post. In #1 above you say you must label wool accounting accounting for 5% or more of the product, and the aggregate of all other fibers. "Threading Your Way..." states: "Exceptions to the five percent rule:(1) Wool or recycled wool must always be disclosed by name and percentage weight, even if it is less than five percent of the product." Can you please clarify?
Apologies, Marie. Let me take another crack at that. The label needs to disclose wool content even if under 5% and recycled wool content even if under 5%. It has to disclose other types of fiber by name if they account for 5% or more. The Wool Act says that labels must disclose: “the percentage of the total fiber weight of the wool product, exclusive of ornamentation not exceeding 5 per centum of said total fiber weight, of (1) wool; (2) recycled wool; (3) each fiber other than wool if said percentage by weight of such fiber is 5 per centum or more; and (4) the aggregate of all other fibers.”
The U.S. market for Western style hats is rife with mislabeled products that defraud consumers, are a source of unfair competition for honest manufacturers and retailers, and are in violation of the Wool Products Labeling Act of 1939. Wool felt hats, which lack the performance characteristics of fur felt hats, are being labeled in such a way as to cause consumers to believe they are buying fur felt hats worth four or five times what an appropriately labeled wool hat typically sells for. Such mislabeling has been confirmed by independent laboratories, is pervasive, and does not involve trace inadvertent contamination. The reputation of an iconic America product -- one that enjoys a large and growing domestic market as well as exports -- is threatened by mislabeled products. I thank the FTC for acting to educate the trade and consumers on this topic.
The FTC does a great job with regulating industries.
I purchased a wool AND cashmere coat on line for $556 (50% reduction from the original cost). I inferred that the wool AND cashmere represented 50% each. There was no sleeve lable, nor a hang tag. It wasn't until I wore the coat the first and only time that I notice the content label sewn into the inside of the garment toward the lower quarter of the coat. There the label listed 60% wool 50% cashmere; and 205 of a made made product/fiber. wHEN I read the coat description as wool AND cashmere...I simply selected my size and purchased the coat. Upon discovering the cashmere content was only 20% I returned the garment to the seller and notified American Express that because I felt the content and quality were misrepresented I was disputing the charge. The seller is disputing my dispute. Questions: 1. Is there a requirement that when the cashmere content is merely 20% can it be advertised as wool AND cashmere IMPLYING 50/50% COMPOSITION? 2) CONTENT LABEL ON THE GARMENT WAS NOT OBVIOUSLY APPARENT ON THE GARMENT. 3) What obligations in this scenario rest with the seller? 4) I have returned the garment, which is in the seller's possession; and I do not want the garment any longer because I believe the advertisement and description of the coat as woo AND cashmere was deceptive and misleading. What do/can I do? Please respond by to me by E-mail as follows: Thank you for you time and a speedy response.

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