You seem to be confusing the labeling requirements from 2 different government agencies. The FTC is the agency that has care and content labeling laws regarding fiber and fabric based items. This is to inform the consumer about possible allergy problems due to the type of materials include on the item and instructions on the proper care of the product that they get the longest lasting wear out of the product. Under their interpetation certain items are exempt from having the label based strictly on what the product category is. So as long as a hat is not made of wool it is exempt from from having that label permanently attached to it.
Now if the hat or cap is for a child under 13 the CPSIA comes into play, that law is governed and interpeted by the CPSC a seperate Federal government regulatory agency from the FTC. The CPSIA requires all children's items to have a permanent tracking on the product so that the current owner of the item can trace the product back to the maker of the item. There are no "set in stone " exemptions from having this label, even when your raw materials are exempt from testing and the finished product does not require additional testing like small parts this label is still require to be on the finished product. To be able to not have a tracking label the CPSC requires a manufacturer to prove that the label would significantly interfer with the primary function of the product, is as required to be worded to large to fit on the product, or would significantly detract from the product's apeeal when placed in a posisition that does not interfer with the primary function. Then once the maker of the child's item, under those circumstances, is able to logical prove that to the government upon demand then they can supply the tracking information on a remove label, tag or as part of the packaging.
The FTC care and content label needs at the very least:
- Your company, shop name, or RN#
- Fiber content by %
- Fiber country of origin
- Washing and care instructions
Other info may be required depending on the exact fabrics use like registered trademark info for fabrics that are followed by a ® or the international symbols for care instructions.
Interpeted from www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered www.ftc.gov/bcp/edu/pubs/business/textile/bus50.shtm#Complying
The CPSIA tracking label from a crafter needs at minimum:
* The manufactuer company's, artisan's shop name, or searchable RN# (not required to repeat if able to find it elsewhere permanantly on the product like on a FTC care and content label).
* The city, state/territory, & country where the item was completed.
(* Contact information- website, or registered business street address. - If different from where made address or unsearchable by the city & state info so a consumer can contact the manufacturer / designer if ther is a problem.)
* At least the season with year of manufacture or date of completion of the product, but the governmnet would prefer you to be more specific.
If designer make repeats of the designs then they may also need a batch number, but only if the pieces are mostly identical looking and made of the same looking raw materials as each other.
www.cpsc.gov/about/cpsia/sect103policy.pdf
