Labels, mostly FTC concerns

[Former_Member]

Okay. I started this business telling myself I was not going to panic about the CPSIA and I was not going to post a question in here without reading everything and getting my answer there. But its just a lot of information, I am feeling really overwhelmed.

Right now, I am making three items for this shop: aprons, hand towels, and children's aprons. I thought I was fine with just putting a CPSIA label inside my children's aprons that said:
SugarSeams
sugarseams.etsy.com
Santa Fe, TX 77517
DOM September 2009

But with the FTC labels, I don't know what to do. From what I have read, FTC labels will be required on all the items I make and include name, country, care instructions and fiber disclosure
So a label like:
Sugar Seams
Made in USA of Imported Fabric
100% Cotton
Wash in gentle cycle, line dry

My difficulties with the FTC labels are:
1) it makes it impossible to make reversible aprons, yes?
2) i have been sewing for over 35 years and my studio is filled to the brim with unknown fabric. they are all primarily cotton but could have some blend, im not really sure. the FTC website recommends writing: Made of unknown fibers or something similar but that just sounds really suspicious.
3) is the verdict out about needing lot and item numbers?
4) writing down the content and country of origin and then keeping it organized seems to require a whole new level of sophistication to my system
5) i was hoping to buy these labels in bulk but since i don't make my items in bulk and they all use separate fabric, the time to make these labels and have them produced seems burdensome.
6) has anyone requested an rn number? do you need a business license for one? i own a business license but in a different name, should i aquire one for all of my etsy shops and get an rn number for each one?
7) is the FTC label law already in effect? any chance of them saying oopsie, our bad, nevermind!?

[knitwit4ever]

First, I understand your concerns and your attempts to stay legal! It's tough to do so thee days.

The FTC labelling laws have been in effect for a long time, so yes, fabric products (except for the list of excluded items) need to be labelled. I'm sure those laws were written for manufacturers using large lots of materials from one source. As another crafter with a storage area full of various yarns, and projects that use small bits of many things, I appreciate your dismay.

I decided to use 2 labels, stitching them on nearly overlapping. The upper has the manufacturer info: my name/info, location, "Manufactured in the USA of __Domestic Fibers __Imported Fibers" (with boxes to check with ink); my Item ID#___ (I've always numbered products so that's easy for me); manuf. date___; size___.

The lower label is the Fiber and Care label. I had some printed for the 2 most common yarn content I use. Others are blank so the info can be hand-entered as needed.

It's not perfect but so far it is the best way I can think of to handle it. I keep track of materials and yarn labels do have content, so I can tell that for sure.

[knitwit4ever]

Also:
Lot/Item numbers are ot required but you should develop some way of keeping track of your product. they did not specify the system you should use.

Somewhere in that long bunch of info there is discussion of labelling for reversible garments (jackets, I think). If I remember correctly, some exception may be allowed but you'll have to find it. I don't remember where it was :-(

[Former_Member]

A lot of this is just my opinion, but before becoming disabled I worked for 15 years in the maternity / children's retail industries.
1) it makes it impossible to make reversible aprons, yes?
No, not impoosible, but tricky. I've seen buntings, coats, art smocks, ponchos, and aprons that were all reversible with the proper FTC labels they are either hidden in a pocket or part of the lower hem as a regular tag that sticks out of the seam.

2) i have been sewing for over 35 years and my studio is filled to the brim with unknown fabric. they are all primarily cotton but could have some blend, im not really sure. the FTC website recommends writing: Made of unknown fibers or something similar but that just sounds really suspicious.
Double check directly with the FTC certain product categories do not need exact fiber content or care labels, and on certain products that do it can be part of a hang tag instead of directly on the product.

3) is the verdict out about needing lot and item numbers?
For the CPSIA yes unless you are making several items identical for the same source of raw materials. For certain FTC product categories no, agian double check with them directly.

4) writing down the content and country of origin and then keeping it organized seems to require a whole new level of sophistication to my system
For the CPSIA the definition of country of origin is different that what most people are thinking - they want the country of origin with city and state/providence that the final item is assembled in ex. : Toms River, NJ, USA. For items that require the detailed FTC labels they want the fiber content by percentages and country of orgin for that specific fabric listed ex. : 90% Wool (New Zealand) 10% Organic Cotton (America) exclusive of trim. Old stock there is nothing you can do except for going with the unknown fiber content. For new fabric purchases just bring a notebook with you to the fabric store & ask for them to cut a small swatch off your order & staple it to a notebook page the the info from the bolt. If you order online make sure you printout the product description & again take a small sample of the fabric when you receive it and attach it to the printout
.
5) i was hoping to buy these labels in bulk but since i don't make my items in bulk and they all use separate fabric, the time to make these labels and have them produced seems burdensome.
Can help you with this one, but you migjt consider checking out what the local fabric or craft store has in the way of ink jet printer fabrics. There was another thread going on that subject.

6) has anyone requested an rn number? do you need a business license for one? i own a business license but in a different name, should i aquire one for all of my etsy shops and get an rn number for each one?
Not sure abiout the RN # and if the business needs to be under the same name as the label, again another question for the FTC directly.

7) is the FTC label law already in effect? any chance of them saying oopsie, our bad, nevermind!?
The FTC has been in effect since at least the 1970s not sure exactly when, but that when it became a federal law for clothing to have precise fabric content and laundering instructions. Before that it was only done as a customer curtesy.


Most of all get the facts straight from the agencies that control these 2 different laws whenever possible
CPSIA Tracking labels
http://www.cpsc.gov/about/cpsia/sect103policy.pdf
FTC Labeling requirements
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered

[Former_Member]

thank you so much jewelrydesignsbyME. i have read those two links as much as possible but i think you are right, i need to email them with the details of my shop and ask them what is required with my specific products.
i think i have the cpsia requirements down, i just never realized the ftc labels applied to crafters for so many items! i have bought plenty of things off of etsy without tags that seem to require them by this law.

[Former_Member]

marking this one too

[FayeMaloneDesigns]

Fabric content labels, washing instruction, and size labels are easily obtainable off the internet at very resonable prices. These are woven with black threads into white satin ribbons. I buy mine from North West tag. They are all FTC compliant. I have my designer tags woven back east, they are not cheap, sigh!. Now I am making my own CPSIA tags on my printer with printer fabric. It's not really that big of a deal to label your products correctly.

As to your fabrics, if you buy mostly cottons, then crush them in your hand, if they wrinkle, then they are most likely cotton, if they don't crush with wrinkles then they are probably cotton poly, which was popular in the 70's and 80's. Now most is 100% cotton.

[Former_Member]

marking

[Former_Member]

I'm putting the care instructions on a separate tag. I have the same type of problem for content though: lots of mystery fabric pieces and one of my loveys uses at least 15 different fabrics and the tag to list them all would be HUGE. So for the content, I came up with "Made of natural and synthetic fibers and materials." I figure that covers everything that I could possibly use while keeping me compliant.

[Former_Member]

marking

[Former_Member]

I have an RN number and it was very fast and painless to get. I can't remember for sure, but I don't remember needing my business license information.

[Former_Member]

btw - jewelrydesignsbyME - The pocket is an excellent suggestion for the tag on a reversable item.

[Former_Member]

stitching

[Former_Member]

FYI for those concerned:

Here is a link to FTC labeling requirements.
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered

After going there, I found out that I was not required to label my handbags. So, its worth the read!

[GiggleRainbow]

marking

[Former_Member]

buttonpom says:
"...After going there, I found out that I was not required to label my handbags. So, its worth the read! "

Yes, I was happy to read that as well. But, be aware that it comes with an exception...
If you make a mention of fiber in your item's description, you then must follow the labeling requirements. (or at least that's how I understand it)

I think using linen along with my other fabrics for my bags is a selling point, but since sewn items are not the mainstay of my business, I'm don't think its worth the added time and expense for labels. SO, I just keep my item descriptions a little less detailed.

[happywhosits]

Good info. Thanks!

Eileen...

[Former_Member]

bewhiskered says:
I came up with "Made of natural and synthetic fibers and materials." I figure that covers everything that I could possibly use while keeping me compliant.
--------------------------------------------------

LOL, i love it! its such a silly law for crafters who don't mass produce, its great that you found a compliant way to say "made of stuff" haha

do you think writing "made from cotton blend" would work? im enivisioning a much larger tag for "made from cotton and other natural and synthetic fibers"
thoughts?

[fairiewings]

This link is the final ruling

http://www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-draft.pdf

I went ahead and printed it out so I can keep a copy for reference. Lots of pages to read but will answer a lot of your questions.

[happywhosits]

In reading the FTC docs linked to in this thread, it seemed to say that you must include the percentage of each fiber in the content label, so that "made of natural and synthetic fibers" would not suffice. Just my 2 cents.

Eileen...

[Former_Member]

from the FTC page:
Products containing unknown fibers30

If a textile product is made — in whole or in part — from scraps, clippings, rags, secondhand fibers or fabrics, or other textile waste materials of unknown and, for practical purposes, undeterminable fiber content, the disclosure may indicate that this is the case. For example:

Made of clippings of unknown fiber content

100% unknown fibers — rags

All undetermined fibers — textile by-products

100% miscellaneous pieces of undetermined fiber content

Secondhand materials — fiber content unknown

45% Rayon
30% Acetate
25% Unknown fiber content

75% Recycled Wool
25% Unknown Reclaimed Fibers

60% Cotton
40% Unknown fibers — scraps

If on the other hand, the fiber content is known or can be readily determined, the full content disclosure must be given.
Sale of remnants and products made of remnants31

Remnants for sale in a retail store do not have to be labeled individually if a display sign indicates that they are “remnants of unknown fiber content and origin.” Similarly, remnants of known fiber do not have to be labeled individually if a sign indicates the content. For example: “remnants, 100% cotton,” “remnants, 50% rayon, 50% acetate.”

If a finished product is made of remnants of undetermined content, the label would read: “Made of remnants of undetermined fiber content and origin,” or some equivalent statement.

[Former_Member]

After reading that, I still think I'm going to stick with my wording. I think you adding "cotton" to it works great. I might say acrylic. I just don't like using the word "unknown". I think it sounds skeevie. Remnants doesn't sound much better.

If I follow the letter of what you've posted, I could just throw a 100% in there. LOL! Like, "100% natural and synthetic fibers and materials."

[Former_Member]

yeah, the whole unknown or remnants phrasing reminds me of sausage making... you only use those words if it is made out of something you really dont want to label

[BikiniSandi]

I found I had to just print out the guidelines for Fiber Content label requirements and also Use & Care labeling and then force myself to sit down and read them. It took me two days and nights to get the nerve up to attempt my first label.

Once I printed out the first one, decided why it wasn't correct based on what I had read....I was back in business.

This whole thing has had me feeling a bit wacky for a year now. I decided to either do it, or look for a job. Now that I did it, the orders are coming in from all over. Wow! I should have done the label thing a year ago.

[HouseOfLittleTomato]

marking