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Updated Wool Products Labeling Rules Include Hang Tag Flexibility

Monday, June 02, 2014
Sandler, Travis & Rosenberg Trade Report

The Federal Trade Commission has approved final changes to its Wool Products Labeling Rules that will clarify and update these rules, provide more flexibility to industry and align several provisions with recent amendments to the Textile Rules. The Wool Rules require that labels on wool products disclose the manufacturer’s or marketer’s name, the country where the product was processed or manufactured, and information about the fiber content.

Changes to be made as a result of this final rule, which will be effective July 7.

- 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

The FTC notes that it is not adopting a proposed requirement for continuing guaranties to be renewed annually due to insufficient evidence that it would increase the reliability of continuing guaranties.

The FTC recently amended the Textile Rules to replace the requirement that sellers sign guaranties under penalty of perjury with a requirement that they certify that they will actively monitor and ensure compliance with the applicable law, and the FTC states that this amendment effectively revised the Wool Rules as well. However, the Commission expressed concern about the reliability of continuing guaranties following this change and states that if it obtains evidence that continuing guaranties have become less reliable it will revisit this issue and consider amending the continuing guaranty provisions accordingly.

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