Western Washington University
16 CFR Part 301: Regulations Under the Fur Products Labeling Act, Matter No. P074201
I generally agree with this proposed rule. It is important for any fur products to be labeled for a number of reasons. First, the consumer should know what they are buying. They are expecting the item they bought to be the item they were notified it was. It would not be morally right to extort a customer for profit gains. Secondly, there is a potential safety hazard in not properly labeling fur products. If the fur has not been treated or cleaned properly, the animal had some contagion/infection, or the consumer is allergic to a specific fur or agent in the fur, then the individual could potentially sue the store or manufacturer of the product. This act also protects the fur industry from lawsuits because it forces companies to thoroughly label all of their products containing any amount of fur. One clarification to this proposed rule is an aspect behind the second amendment of the Fur Act. TFLA states that face to face transactions at a residence, craft fair, or location of a short term basis by the hunter/trapper would not apply. It also stipulates that the revenue or the sale of any fur product could not be the primary source of income for such person. Does this mean that a person who considers themselves a professional hunter must label their fur when selling at any of the locations mentioned above? Does it still apply if the selling of fur products is the only way said individual can provide for their family? I can potentially see this being a problem in very rural areas especially Alaska. For example, a Native Alaskan who lives in the tundra and could only support his family through hunting, trapping, and selling furs could potentially be prosecuted in violation of this rule? Other than this simple clarification this rule is important to establish and enforce for the safety of consumers and the public.