Here come the bride-to-be and bridesmaids, shopping for the perfect dresses for the big day. They may look first at a gown’s style and price, but they’ll also check the manufacturer, fiber content, country of origin and care instructions. This is required information that can help them make their choices.
If you manufacture, import or sell wedding gowns and other bridal attire, you must ensure that consumers have certain garment information. The Textile Act, its regulations and the FTC's Care Labeling Rule require that labels be attached to imported and domestic textile products like wedding gowns. These rules apply to sample garments and garments that are for sale. If the item contains wool, the Wool Act and its regulations apply instead of the Textile Act and its regulations.
Labels for wedding gowns and bridal attire must contain four key pieces of information:
1. The identity of any one of the businesses in the distribution channel:
- the manufacturer
- the manufacturer's Registered Identification Number (RN), which is issued to companies in the U.S. and registered by the FTC
- the retail store's name or RN or
- the RN or business name of any other company directly involved in the distribution of the gown.
The label showing the name or RN may be sewn in or attached to the garment as a hang-tag, and must be conspicuous.
2. The garment's fiber content
If the garment doesn’t contain wool, you must list the generic fiber names and percentages (by weight) of each fiber used, in descending order of predominance. The label also should identify fibers that make up less than 5% of the item’s weight as “other fiber,” unless the fiber has a clearly established functional significance. List the percentage of “other fiber” last.
The label may be sewn in or attached to the garment as a hang-tag, and must be conspicuous. It may appear with other information or it may be a separate label. To ensure proper care of the garment, it may be important — although not required — to have the fiber content on a label that is permanently attached. You may attach additional hang-tags that identify some, but not all, the fibers, if the tags tell shoppers:
- to check the label for full fiber content, or
- that the hang-tag does not disclose the product’s full fiber content.
If the garment contains wool, the same requirements apply, except that:
- the wool content must be identified even if the wool accounts for less than 5%;
- the fibers don't need to be listed in descending order of predominance.
3. The country of origin
Imported wedding attire must identify the country where it was processed or manufactured.
Garments made entirely in the U.S. of materials made in the U.S. must be labeled "Made in U.S.A." or an equivalent phrase. Garments made in the U.S. of imported materials must be labeled to show the processing or manufacturing done in the U.S. and the imported component. Garments manufactured partly in the U.S. and partly abroad must identify both aspects.
If a garment is imported, the country-of-origin label must be sewn in to comply with U.S. Customs requirements. If an item is made in the U.S. of imported or domestic fabric, the country of origin information can be sewn in or placed on a hang-tag. The country-of-origin disclosure must be placed as close as possible to the center back of the neck. The country of origin of imported garments should be determined according to U.S. Customs regulations.
4. Care instructions
The care label must identify at least one safe cleaning method — either washing or drycleaning — and any necessary warnings about the cleaning method. For example, if the care instruction is to dryclean, the label must specify one type of solvent that may be used, unless all commercially available types of solvents can be used safely on the garment. If the garment is labeled for washing, the label must say whether any step of the normal washing process (washing, bleaching, drying or ironing) could harm it or other items cleaned with it.
The care label must be sewn in. Imported garments should have care labels when they are sent to the U.S., or the importer should attach them.
Tag Omission, Removal and Substitution
Wedding gowns and attire must have all the required labeling information when they leave the manufacturer.
Under the Textile and Wool Acts, it is illegal to remove a label containing manufacturer, fiber content or country-of-origin information without substituting another label with the required information. A retailer that wants to remove a label identifying the manufacturer must substitute a label that lists the shop's own name or RN, or the name or RN of another business in the gown distribution chain. The substitute label must contain all the information that is required on the original label. All substitute labels must be properly attached to the garment, either sewn in or on a conspicuously placed hang-tag. Finally, a retailer must not remove the sewn-in care instructions.
Manufacturers of wedding gowns and attire must keep records for three years that show the required label information for every garment they produce. The records should show that the letter of the law has been met and establish a traceable line from the raw materials to the finished product.
In addition, any business that substitutes a label on a textile product also must keep records for three years that show what information on the label was removed and the name of the party from whom the product was received.
Any violation of the Textile or Wool Act regulations or the Care Labeling Rule is considered an unfair and deceptive act or practice under the FTC Act. As a remedy, the Commission may issue an administrative order prohibiting the unlawful behavior. Violations of an administrative order can result in a federal district court action for civil penalties up to $16,000 each. Businesses not subject to a previous administrative order also can be subject to monetary civil penalties, an injunction and other remedies — including consumer redress — in a federal district court action for knowingly engaging in practices —like mislabeling garments — that the Commission has determined to be unfair or deceptive in prior cases.
For violations of the Care Labeling Rule by a manufacturer or importer, the Commission may seek an injunction in federal district court and civil penalties of up to $16,000 per violation. A retailer that removes care labels from garments may be held liable for unfair and deceptive acts or practices under the FTC Act and may be the subject of an administrative order. Violations of such orders can result in an action for civil penalties in federal district court.
Each instance of mislabeling under the textile laws and the Care Labeling Rule may be considered a separate violation.
For More Information
See Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts and Clothes Captioning for more about textile labeling requirements and care labels.
Your Opportunity to Comment
The National Small Business Ombudsman and 10 Regional Fairness Boards collect comments from small businesses about federal compliance and enforcement activities. Each year, the Ombudsman evaluates the conduct of these activities and rates each agency's responsiveness to small businesses. Small businesses can comment to the Ombudsman without fear of reprisal. To comment, go to www.sba.gov/ombudsman.