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:
- 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;
- the percentage of the total weight of the product that is made of non-fibrous matter;
- the name – or RN number – of the manufacturer or other responsible company; and
- 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.