Wool, ribbon, elastic questions

[nico6196]

1. I am playing around with some acrylic/wool blend yarns for some winter hats. My understanding is that because the yarn has wool in it, I need to abide by the FTC labelling requirements. Am I correct? What information is required on the label (FTC portion)?

2. Is ribbon and/or elastic (clothing elastic) exempt from CPSIA and FTC labelling requirements?

Thanks

[Former_Member]

Beyond the CPSIA many products that are made from fiber or fabrics, regardless of the age of the user, have needed since the early 1970s a FTC care and content label. The FTC is a seprerate govenment agency from the CPSC (the agency that administers the CPSIA) so there are products that will have to follows the laws and regulations from both government offices. There are no exemptions in the FTC based on what an item is made from but there are certain types of finished product like socks that are exempt from having the care & content on the product. Wool based products do have their own special labeling requirements under the FTC even if wool is only a small part of the overall piece. In some cases the "wool law" can overide the labeling exempt status of a product category, example 100% cotton hat is exempt from labeling but a wool & cotton blend hat is not.
FTC main
http://www.ftc.gov
Clothing, accessories and home furnishings care and content labeling
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered
http://www.ftc.gov/bcp/edu/pubs/business/textile/bus50.shtm#Complying

For the most part the FTC label must include:
- Your company, shop name, or RN# (an absolute requirement for the FTC labels, but if a FTC label is already on a child's product then no repeat name or RN# is needed for the CPSIA label)
- Fiber content by % (as measured by weight)
- Fiber country of origin for each fiber or fabric used
- 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 internation symbols for care instructions.


There are no exemptions from the CPSIA tracking labels. The exemption list is only about having your components or the final product tested for lead and keeping copies of those test results. If all of your raw components are on the exemption list then you can skip having to get lead testing information to keep on file, but it might be a good idea to keep any packaging from the supplies to help you prove that the item was described and sold as something that falls into the exempt category.
For the current full list of raw materials offically exempt from CPSIA lead testing please read http://www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-draft.pdf
Currently it has been interpetted that elastic and plain fabric ribbon (no screen printing, no add-ins like glitter or rhinestones, and no metal edging) are exempt from lead testing but depending on the type of final product and the age of the targeted user it still may need phthalate testing.

You still need to add a permanant tracking label to the finished products that are tied back to the self-issued GCCs that you keep on file. The government can request to see your GCCs at anytime even if there is never a report to investigate about a product of yours. Additionally if you decide to wholesell or send items to consignment the retailer will need copies of the GCCs for each product or production run of items to keep in their files.
Tracking labels required on every product for children under 13
http://www.cpsc.gov/about/cpsia/sect103policy.pdf

For a crafter the CPSIA tracking label must include at minimum :
* Your company' brand, shop name, or RN# (not required on the label 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
* If different from where made an address or website so a consumer can contact the manufacturer / designer (DO NOT include a phone number unless you want anyone that sees your label to call you at anytime)
* At least the month with year of manufacture or date of completion of the product (still waiting to hear if the CPSIA committee will allow micro businesses that can otherwise easily identify when their products were made to just include season & year)
* If you make repeats of the designs then you 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.

[Former_Member]

Wow really complicated.....

[nico6196]

Yes it is, when you say "Fiber country of origin for each fiber or fabric used" for the FTC label, what does that mean? The yarn manufacturer location or the location of wherever their raw materials come from or my country?

[Former_Member]

I'm pretty sure it means where the fibers for the yarn were manufactured, harvested, or sheared in. It's not uncommon for the base materials used in the yarn to be gather or made in 1 country then be spun into the yarn in another. Fiber arts are not one of my strong points you may want to check with your supplier to see what info they may have. If it's national chain the average salesperson may have no clue so you could also check with your local SCORE or SBA office to see if they have a definative answer.
Regardless of if I'm right or wrong that information should be right on the band for skein of yarn.

[knitwit4ever]

Re: the country of origin. My understanding is as follows...
There is a "once removed" rule applied, meaning that the yarn maker must identify the source country of origin for the fiber used in making the yarn. The user of the yarn is only required to state the source country of the yarn manufacture, not of the fiber used to make the yarn.

I'm not on my home computer, so can't quote the source but I think it is in the FTC documents somewhere.

[knitwit4ever]

Found it!
"One step removed rule

In deciding whether to mark a product as made, in whole or in part, in the U.S., a manufacturer must consider only the origin of materials that are one step removed from the particular manufacturing process. For example, a yarn manufacturer must identify imported fiber. A manufacturer of knitted garments must identify imported yarn. A manufacturer of apparel made from cloth must identify imported fabric."

Source: http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#removed (See table of contents for
"Country of Origin", then next to last sub-section.)

[FayeMaloneDesigns]

Kisses, kisses knitwit.. I knew someone would find it.

So you don't have to run down the sheep that your yarn came from and followed it thru the chain.Good lordy, many people can't follow the chain of birth of their own ancestry, much less a sheep, llama and and alpaca.!!!!Next you kniow we will have to have DNA registry on our sweaters from Walmart!!!!

[knitwit4ever]

Yes, Faye, I was pleased when I found that reference originally, as I had been asking the same question. Much yarn is "made in U.S.A. from imported fibers", so I was trying to decide what I needed to call it when I created something.

Guess my memory still works...

[nico6196]

That is great info! Thank you. So in my situation, since I live in Canada, I'm a little confused as how to label. How would I label the following finished products (hats):

1. Hat made with yarn that is labelled Made in Canada?

2. Hat made with yarn that is labelled Made in USA?

3. Hat made with yarn that is labelled Made in Turkey but is sold and labelled by Lion Brand (New York, USA)?

[Former_Member]

Marking, thank you!

[happywhosits]

breadcrumbs...

[KittyCatsCupboard]

Marking for later ^..^

[knitwit4ever]

nico, for "source" of your 3 examples:

Your items are all "Made in Canada" with:
Item 1: Yarn "Made in Canada"
Item 2: Yarn "Made in USA"
Item 3: Yarn "Made in Turkey"

Note that there are some yarns that say "Made in USA with fibers made in Turkey". Those would. I believe, be "Made in USA" for your purposes, as the "once removed" rule asks only where the yarn is made, not the original fiber. Packaging/labeling alone doesn't fall under the "once removed", as I understand it.

Better a late answer than none, I hope?

[Former_Member]

Thanks for the intepretations and the links

[Former_Member]

Do you think "Made in USA from imported materials" ok?

[knitwit4ever]

bluecuddly, for CPSIA that "Made in USA" should be enough, but the FTC rules specify country of origin is required for materials.

[FayeMaloneDesigns]

Correction, you can in fact say made in the USA of imported materials.

From the FTC site.

Products made in the U.S.A. with imported materials
The label must indicate that the product contains imported materials. The label may identify the country of origin of the imported materials, but it doesn’t have to. It can say simply: “Made in U.S.A. of imported fabric” or “Knitted in U.S.A. of imported yarn.” This disclosure must appear as a single statement, without separating the “Made in U.S.A.” and “imported” references.

[Former_Member]

thanks. I thought I read somewhere in the all the literature that it was ok to word it that way. But you know how it is, the more I read the more confused I get somedays.

[knitwit4ever]

True, FayeMalone, but the wool rules say "country of origin" so if any wool is included you'll need the country name.

[knitwit4ever]

Now I'm confused, too. When I get time, I'll have to go re-read. It may be that it says different things in different places.

[knitwit4ever]

Here's some text direct from the FTC source:
"Country Of Origin36

Products covered by the Textile and Wool Acts must be labeled to show the country of origin.

* Imported products must identify the country where they were processed or manufactured.
* Products made entirely in the U.S. of materials also made in the U.S. must be labeled “Made in U.S.A.” or with an equivalent phrase.
* Products made in the U.S. of imported materials must be labeled to show the processing or manufacturing that takes place in the United States, as well as the imported component.
* Products manufactured in part in the U.S. and in part abroad must identify both aspects."

>>>I believe that means that "Made in USA of Imported Materials" is sufficient.
~~~~~~~~~

"Products made in the U.S.A. with imported materials

The label must indicate that the product contains imported materials. The label may identify the country of origin of the imported materials, but it doesn’t have to. It can say simply: “Made in U.S.A. of imported fabric” or “Knitted in U.S.A. of imported yarn.” This disclosure must appear as a single statement, without separating the “Made in U.S.A.” and “imported” references.

Manufacturers should be aware that for certain products — including sheets, towels, comforters, handkerchiefs, scarfs, napkins, and other “flat” goods — Customs requires identification of the country where the fabric was made.37 To comply with Customs and FTC requirements for this group of products, the label must identify both the U.S. and the country of origin of the fabric. For example: “Made in U.S.A. of fabric made in China” or “Fabric made in China, cut and sewn in U.S.A.”

>>>So if you plan to sell internationally, some items/types of products may also need the country name.

Both texts copied from http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#origin

I guess I just decided that the only safe thing to do was to add the country name!