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Wool Products Labeling Rules Would Get Update under FTC Proposal

Wednesday, September 18, 2013
Sandler, Travis & Rosenberg Trade Report

The Federal Trade Commission is seeking public comments by Nov. 25 on a proposed rule that would conform the Wool Products Labeling Rules to the requirements of the Wool Suit Fabric Labeling Fairness and International Standards Conforming Act and align them with proposed amendments to the Textile Rules.

Proposed Changes. The Wool Rules require labels on wool products to disclose the manufacturer’s or marketer’s name, the country where the product was processed or manufactured, and specified information about the fiber content. The proposed changes include the following.

- incorporating new definitions for cashmere and very fine wools

- clarifying existing descriptions of products containing virgin or new wool

- allowing certain hang-tags disclosing fiber trademarks and performance even if they do not disclose the product’s full fiber content

- stating that an imported product’s country of origin as determined under the laws and regulations enforced by U.S. Customs and Border Protection will be the country where the product was processed or manufactured

- requiring guarantors to acknowledge that providing a false guaranty is unlawful and to certify that they will actively monitor and ensure compliance with the applicable law

- requiring continuing guaranties to be renewed annually by providing that they will continue in effect for one year unless revoked earlier

Amendments Not Being Proposed. The FTC is declining to propose the following amendments that had been requested by several textile organizations.

- including fiber from animals such as yak and guanaco in the definition of wool

- specifying test methods for identifying or measuring fibers or creating a label certification program; e.g., a user fee-funded program that would allow an importer or distributor of a wool product to establish the accuracy of its product labels by the submission of fiber testing or other means, such as through the submission of supply chain documentation, sufficient to establish the fiber contents of the wool products and the accuracy of the label

- creating a de minimis wool content exception

- changing the Wool Rules’ treatment of language requirements  

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