Members of the fur industry: Today’s the day

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If you manufacture, import or sell garments containing fur, November 19th should be circled on your calendar. That’s because today’s the day amendments to the FTC’s Fur Rule take effect. Looking for help with compliance? The FTC has published How to Comply with the Fur Products Labeling Act, updated guidance on keeping your practices within the law.

The FTC announced the amendments in May 2014, streamlining the Fur Rules to eliminate unnecessary requirements. Specifically, the FTC amended the Rules to revise the Fur Products Name Guide, provide businesses with more flexibility in labeling and invoicing, incorporate provisions of the Truth in Fur Labeling Act of 2010 (TFLA), and modify the Rules’ separate guaranty provisions to match the procedure for textile products. (Industry members should already know about an update to the continuing guaranty form for fur products that took effect earlier this year.)

Here are a few key changes:

Label and Invoice Content and Format.  The amended Rules:

  • eliminate specific label and font size requirements;
  • no longer require disclosures that fur comes from “sides” or “flanks”;
  • allow items sold in pairs or groups to have one label, even if the items are not physically attached; and
  • no longer require an item number on labels and invoices.

E-Commerce.  The FTC clarified the Rules to reflect that business paperwork often is in electronic form. The FTC amended the definitions of the terms “invoice” and “invoice or other paper” to:

  • replace the word “paper” with “document”;
  • state explicitly that those documents can be issued electronically; and
  • allow records to be preserved in forms other than paper.

Guaranties.  The FTC updated the Rules’ separate guaranty provisions by adding a statement that the guarantor’s printed name and address will satisfy the signature requirement.  The amendment eliminates the requirement that the guaranty show the shipment date. The FTC also revised the continuing guaranty form. Suppliers who choose to file a continuing guaranty no longer have to sign it under penalty of perjury. Under the updated Rules, a certification will suffice. (The FTC made this change in April 2014 – effective May 5, 2014 – when it amended the Textile Rules to revise the continuing guaranty form used for textiles, wool, and fur.)

Looking for more information? Read How to Comply with the Fur Products Labeling Act.

 

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