The Federal Trade Commission recently terminated an investigation into allegations that a U.S. company’s marketing materials for textile products omitted required country-of-origin information and failed to disclose that the products were made from imported fabrics.

For more information, please contact trade attorney Elise Shibles at (415) 490-1403.

The Textile Products Identification Act (Textile Act) and its implementing regulations (Textile Rules) require a conspicuous and readily accessible country-of-origin label or labels on the inside or outside of textile products, regardless of whether the products originated in the U.S. or abroad. The Act also requires marketers to disclose product origin in mail-order advertising, including online materials.

According to the FTC, the company at issue performs processes in the U.S., including cut-and-sew and finishing of certain textile products, and makes a particular line of products in the U.S. The FTC states that while it is appropriate for the company to promote these facts, its marketing materials that cover imported products or products made from imported fabrics must make clear disclosures in compliance with the Textile Act and Textile Rules.

To come into compliance, the company implemented a remedial action plan that included (1) removing broad, unqualified advertisements stating that its products were made in the U.S., (2) updating trade show signage, (3) ensuring that all its products were labeled with an appropriate country of origin, (4) updating online marketing materials to include required country-of-origin information, (5) training company personnel on the requirements of the Textile Act and Textile Rules, and (6) making diligent efforts to ensure the accuracy of third-party retailer claims, including contacting all dealers and distributors to confirm the accuracy of their marketing materials.

Based on these actions and other factors, FTC staff has decided not to pursue this investigation further.

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