fiber content - United States Fashion Industry Association

Transcription

fiber content - United States Fashion Industry Association
FIBER CONTENT
US Regulations & Testing
Presented by:
Louann Spirito
Director Technical Support Softlines
FIBER CONTENT REGULATIONS
© SGS SA 2012 ALL RIGHTS RESERVED
OBJECTIVES
 Gain an understanding of fiber content labeling
regulations
 Gain a general understanding of fiber content testing
procedures and reporting
 Update on recent changes to Textile Fiber
Identification Act
© SGS SA 2012 ALL RIGHTS RESERVED
FEDERAL TRADE COMMISSION
 Fiber labels for wearing apparel and other textile
products are required under FTC rule
 Textile Fiber Products Identification Act
 Wool Products Labeling Act
 Fur Products Labeling Act
Note: information can be obtained at www.ftc.gov
© SGS SA 2012 ALL RIGHTS RESERVED
Regulation
Textile Fiber Products Identification
Act
Wool Products Labeling Act
Fur Products Labeling Act
Citation
16 CFR 303
16 CFR 300
16 CFR 301
The Endangered Species Act of 1973
Dog and Cat Protections Act 2000
The Leather Guide
© SGS SA 2012 ALL RIGHTS RESERVED
US Public Law 106 –
476 Chapter 3, Sect
1441-1442
16 CFR 24
FIBER CONTENT LABELING APPLIES TO:
 Manufacturers, importers, retailers, distributors,
advertisers of products covered by the Textile,
Wool, and Fur Labeling Acts
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APPAREL PRODUCTS
 Clothing - except hats
and shoes
 Handkerchiefs
 Scarves
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HOME FURNISHING PRODUCTS
 Floor coverings - rugs,
carpets, mats
 Towels, washcloths, and
dishcloths
 Ironing board covers and
pads
 Doilies, dresser scarves
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HOME FURNISHING PRODUCTS
 Tablecloths and
napkins
 Bedding
 Draperies
 Cushions
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HOME FURNISHING PRODUCTS
 Curtains and
casements
 Afghans and throws
 Furniture slip covers
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OTHER PRODUCTS
 All fibers, yarns, and
fabrics (except sewing
& handicraft threads)
 Umbrellas and parasols
 Hammocks
 Flags
 Sleeping bags
© SGS SA 2012 ALL RIGHTS RESERVED
PRODUCTS NOT INCLUDED
 Many products excluded - textiles used in: handbags or
luggage
 Some products included if any fiber name is mentioned in
advertising
 See Threading Your Way Through the Labeling
Requirements Under the Textile and Wool Acts, Federal
Trade Commission, Washington, DC (www.ftc.gov)
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WHAT IF YOUR PRODUCTS CONTAIN WOOL?
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 Most products that contain any amount of wool are covered
by the Wool Act and must be labeled accordingly.
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WHAT IF YOUR PRODUCTS CONTAIN WOOL?
 A wool product is defined as any
product or portion of a product that
contains any wool
 Products exempt from the Textiles Act,
such as hats and slippers, are covered
by the Wool Act if they contain any wool
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NOW, WE KNOW WHAT PRODUCTS MUST
HAVE FIBER CONTENT LABELS….
 The next challenge is writing an accurate fiber
identification label
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CONFIRM THE ACTUAL FIBER CONTENT
 Obtain fiber content test results
 Be knowledgeable about interpreting the results
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FIBER IDENTIFICATION TESTING
Physical
Chemical
Microscopic
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PHYSICAL TESTING
 Usually used as a
screening procedure
 Yarns/fabrics burned,
residue and odor
observed
 AATCC chart for
reaction to flame
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MICROSCOPIC ANALYSIS
 Used to determine fibers
present in the fabric
 Qualitative
 For hair, wool, and cellulose
fibers that can’t be separated
chemically
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MICROSCOPIC ANALYSIS
 Fibers separated from yarns,
mounted on slides, viewed
under microscope, and
compared to known
photomicrographs of hair and
fibers
AATCC Technical Manual
references many fibers
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CHEMICAL TESTING
 Quantitative - used to
determine percentages
 Fibers/yarns/fabrics
placed in chemical bath,
agitated, filtered, dried,
and weighed
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FIBER NAMES
 Must use generic names for both natural and
manufactured fibers
Cotton
Silk
Ramie
Linen
Wool
Polyester
Nylon
Modacrylic
Spandex
Acrylic
 The most updated ISO generic fiber names have been
updated in the Textile Fiber Identification Act
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GENERIC FIBERS
Bamboo is not a generic
fiber name and is not
recognized by FTC
Regenerated cellulose
100% Rayon
Made of Bamboo Fiber
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FIBER NAMES
 Premium cotton names (Pima, Egyptian, Sea Island,
etc.) may be named as long as they are accurate
 Quantities of fiber types must be accurate
100% Pima
Cotton
100% Combed
Cotton
50% Pima Cotton
50% Other Cotton
© SGS SA 2012 ALL RIGHTS RESERVED
FIBER NAMES
 Wool fiber names
 The term wool may be used for fiber from the fleece of
sheep or lamb, and the hair of the Angora goat,
Cashmere goat, camel, alpaca, llama or vicuna.
 Reclaimed or recycled wool fibers must be identified
as “recycled wool”
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FIBER NAMES
 Specialty wool fibers
 Specialty wool fiber names may be used
Mohair
Camel
Llama
Cashmere
Alpaca
Vicuna
 If the name of a specialty fiber is used, the percentage of
that fiber must also be used
50% Camel Hair
50% Wool
© SGS SA 2012 ALL RIGHTS RESERVED
FIBER NAMES
 Other hair and fur fibers
 The term fur fiber may be used to describe
the hair or fur fiber of any animals other than
the sheep, lamb, Angora goat, Cashmere
goat, camel, alpaca, llama, and vicuna
© SGS SA 2012 ALL RIGHTS RESERVED
FIBER NAMES
 The name of another animal may be used if its hair or fur
fiber comprises more than 5% of the fiber weight
60% Wool
30% Fur Fiber
10% Angora Rabbit
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COATED FABRICS
 Coated fabrics are those that are coated, filled,
impregnated, or laminated with a continuous film
 Polyurethane (PU)
 Polyvinyl Chloride (PVC)
 Acrylic Resin
 To be considered a coating, the film must add a minimum
of 35% weight to the base fabric
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COATED FABRICS
 Coating films are not fibers
 Should not be identified as a fiber
 Can be identified for other purposes
100% Cotton
Polyurethane
Coated
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TOLERANCES FOR FIBER CONTENT
 There is a ±3% tolerance for fiber content claims on
labels
 40% could actually range from 37% to 43%
 Deviations larger than ±3% constitute mislabeling
 The tolerance does not apply to 100% fabrics
 The Wool Act does not allow a tolerance; however, for
practical purposes, the FTC applies the 3% rule to wool
products
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ON A FIBER LABEL...
 The label can say “All” or “100%” if the fabric is made all
from one fiber
100% Cotton
All Cotton
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ON A FIBER LABEL….
 Fiber blends must be reported by percentage of weight and
listed in order of predominance
Report
63.4% Rayon
29.2% Polyester
7.4% Spandex
© SGS SA 2012 ALL RIGHTS RESERVED
ON A FIBER LABEL….
 Fiber blends must be reported by percentage of weight
and listed in order of predominance
Report
Label
63.4% Rayon
65% Rayon
29.2% Polyester
28% Polyester
7.4% Spandex
7% Spandex
© SGS SA 2012 ALL RIGHTS RESERVED
ON A FIBER LABEL….
 Label printed before report! Can cause
problems.
Label
60% Rayon
33% Polyester
7% Spandex
© SGS SA 2012 ALL RIGHTS RESERVED
ON A FIBER LABEL….
 Label printed before report! Can cause
problems.
Label
Report
60% Rayon
63.4% Rayon
33% Polyester
29.2% Polyester
7% Spandex
7.4% Spandex
© SGS SA 2012 ALL RIGHTS RESERVED
ON A FIBER LABEL….
 Label printed before report! Can cause
problems.
Label
Report
60% Rayon
63.4% Rayon
33% Polyester
29.2% Polyester
7% Spandex
7.4% Spandex
© SGS SA 2012 ALL RIGHTS RESERVED
ON A FIBER LABEL….
 Label printed before report! Can cause
problems.
Label
Report
60% Rayon
63.4% Rayon
64% Rayon
33% Polyester
29.2% Polyester
29% Polyester
7% Spandex
7.4% Spandex
7% Spandex
© SGS SA 2012 ALL RIGHTS RESERVED
New Label
ON A FIBER LABEL...
 List only fibers that compromise 5% or more of
fiber weight
 Fibers less than 5% must be listed as “other
fiber” or “other fibers”
© SGS SA 2012 ALL RIGHTS RESERVED
FOR EXAMPLE:
 Using heather colored fabric ---------
98% Cotton
98% Cotton
2% Polyester
2% Other
 Wool in any amount must always be listed
98% Cotton
98% Cotton
2% Wool
2% Wool
© SGS SA 2012 ALL RIGHTS RESERVED
ON A FIBER LABEL...
 There are exceptions to the 5% other fiber rule
 Fibers less than 5% may be listed if the fiber has a definite
functional significance at that amount
96% Wool
98% Cotton
4% Nylon
2% Spandex
© SGS SA 2012 ALL RIGHTS RESERVED
ON A FIBER LABEL...
Multiple non-functional fibers
present in less than 5% each may
be combined
82% Cotton
82% Cotton
10% Polyester
10% Polyester
4% Nylon
8% Other Fibers
4% Rayon
© SGS SA 2012 ALL RIGHTS RESERVED
EXEMPTIONS TO FIBER DISCLOSURE
 Trim – Collars, Cuffs, Binding….
 Findings – Elastic, Thread, structural elements
 Decorative Trim
<15% of surface area
the fiber content is not disclosed
statement “exclusive of decoration” is used
 Ornamentation
 If ornamentation exceeds:
15% of the surface area AND 5% of fabric weight,
the fiber MUST be disclosed
© SGS SA 2012 ALL RIGHTS RESERVED
TRIM & FINDINGS
 Trims in clothing and other
textiles are excluded from the
labeling requirements.
 Trim includes: collars, cuffs,
braiding, waist or wrist bands,
rick-rack, tape, belting, binding,
labels, leg bands, gussets,
gores, welts, findings
© SGS SA 2012 ALL RIGHTS RESERVED
EXEMPTION EXAMPLES
100% Cotton
exclusive of decoration
Body – 100% Cotton
Ornamentation – 100% Silk
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METALLIC
Metallic Yarns are found in various forms
 Metal
 Plastic coated metal (normally polyester)
 Metal coated plastic (normally polyester)
 Plastic core completely covered by metal
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METALLIC
 Fibers that are coated are considered metallic and would
be labeled as % metallic. For example Polyester coated
w/ aluminum would be labeled metallic since metallic is a
generic name on the FTC fiber list.
 Core fibers that are wrapped, i.e., poly core fibers, must
be treated as 2 separate fibers and reported as a
biconstituent
 The rule is the same whether the fiber is used as
ornamentation or the body fabric.
 Fibers that are all polyester and shiny, should be
identified as polyester.
© SGS SA 2012 ALL RIGHTS RESERVED
EXCLUSIVE OF DECORATION
 Fibers used in logos
that vary from body
fiber must be called
out on label
Rayon
100% Cotton
Exclusive of
Decoration
© SGS SA 2012 ALL RIGHTS RESERVED
Cotton
TRADEMARKS
 A fiber trademark name may be used as long as
it appears immediately next to the generic fiber
name in the same size type and the same style
font
80% Cotton
20% Lycra® Spandex
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FAUX FUR REQUIREMENTS
 New York and other States
All apparel items containing real or faux fur must be have the
terms “real fur” or “faux fur” listed on a label attached to the
garment.
THEREFORE:
 All apparel items containing or made from fur need to have
the indication of “real fur” or “faux fur” on the label
© SGS SA 2012 ALL RIGHTS RESERVED
FUR
 Fur Products Labeling Act does not apply to fur from dogs or
cats.
 Cat and Dog Protection Act 2000
 No article containing dog or cat fur may be imported into or exported
from the United States.
 Dog Fur
Gae-wolf, Sobaki, Loup d’Asie (Wolf of Asia), Goupee, China Wolf,
Pommern Wolf, Asiatic Raccoon Dog, Corsac Fox, Dogues du Chine,
Asian Jackal
 Cat Fur
Wildcat, Goyangi, Mountain Cat, Housecat, Katzenfelle
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FUR
 Fur Products Labeling Act does not apply to endangered
species
 The Endangered Species Act of 1973
 Fur from animals on the endangered species list must not be imported
into or exported from the USA.
© SGS SA 2012 ALL RIGHTS RESERVED
How about a leather garment or leather trim on a garment?
© SGS SA 2012 ALL RIGHTS RESERVED
LEATHER
The Leather Guide covers all types of leather or simulated
leather products. It is commonly applied to footwear but
also applies to apparel, accessories, belts sold separately,
purses and handbags, wallets and billfolds, etc.
Guides for Leather and Imitation Leather Products
© SGS SA 2012 ALL RIGHTS RESERVED
LEATHER/LEATHER TYPE PRODUCTS
 If all or part or a product is made of non-leather material
that appears to be leather, the fact that the material is not
leather must be disclosed
 Acceptable terms include
Not Leather
Imitation Leather
Simulated Leather
© SGS SA 2012 ALL RIGHTS RESERVED
Vinyl
Vinyl Coated Fabric
Plastic
LEATHER/LEATHER TYPE PRODUCTS
 The kind and type of leather must be disclosed when all or
part of the product has been embossed, dyed or otherwise
processed to simulate a different type of leather
Example:
Top Grain Cowhide with Simulated Pigskin Grain
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LEATHER/LEATHER TYPE PRODUCTS
 The backing material behind another kind of upper material
must be disclosed
Example:
Top Grain Cowhide Backed with Vinyl
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LEATHER/LEATHER TYPE PRODUCTS
 A product made of ground, pulverized, shredded,
reconstituted or bonded leather must not be represented
as leather
 The label must include the type of leather (ground,
shredded, etc.), the percentage of leather and the
percentage of non-leather substance
Example:
Bonded leather containing 60% Leather Fibers and 40%
Non-leather Substances
© SGS SA 2012 ALL RIGHTS RESERVED
LEATHER/LEATHER TYPE PRODUCTS
 Trade names, trademarks or other words must
not be used if they misrepresent that a product
is made in whole or in part from an animal skin
or hide
 Labels, tags, cards, stamps, etc. in the shape of
a hide or animal skin must not be used unless
the product is made in whole or in part from an
animal skin or hide
© SGS SA 2012 ALL RIGHTS RESERVED
ENFORCEMENT
 Fiber identification labeling is enforced by the U.S. Federal
Government - Federal Trade Commission - for the benefit
of the consumer and manufacturers
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ENFORCEMENT
 Major USA home furnishing
company fined $360,000 for
misrepresenting fiber content of
sheets and towels
 A USA carpet and rug
manufacturer fined
$100,000 for falsely
labeling fiber content
and weight of carpets
© SGS SA 2012 ALL RIGHTS RESERVED
FTC Amended Textile Fiber Identification Act
© SGS SA 2012 ALL RIGHTS RESERVED
AMENDMENTS TO THE ACT
 § 303.1 Terms Defined
 Amended definition of terms “invoice” and “invoice or
other paper” to “invoice or other document” to better
address electronic commerce
 §303.7 – Generic names for manufactured fibers
 Now updated ISO generic fiber names are included in
the regulation
 § 303.12 – Trimmings of household textile
articles
 Wording has been simplified to make rule more
clear. Trims, findings and elastic , decorative and
ornamentation and can be considered a “Trim” or a
“Decoration”
© SGS SA 2012 ALL RIGHTS RESERVED
AMENDMENTS TO THE ACT
 § 303.17 – Use of fiber trademarks and generic
names on labels
 Full fiber content must be disclosed once on a garment
 Where fiber content is referred to on a hang tag, names
of fibers can be stated without reference to
percentages unless not all fibers are listed on the label
 In which case the words “This tag does not disclose the
products full fiber content” must appear on the hangtag.
Or “See label for full fiber content”
 For example, if the garment is
– 75% cotton/20% polyester/5%spandex,
 but the hang tag just mentions cotton/poly, then the
statement must be included on the label
© SGS SA 2012 ALL RIGHTS RESERVED
AMENDMENTS TO THE ACT
 § 303.33 – Country where textile fiber products
are processed or manufactured
 This has been changed to state the rules of US
Customs must be followed. Previously, FTC had some
COO rules which conflicted with US Customs
 § 303.35 – Use of terms “virgin” or “new”
 “Fiber” is added in this paragraph to clarify if the
product, any fiber or part are not wholly composed of
new or virgin fiber, the terms may not be used
 Previously, “fiber” is not quoted in this regulation and it
may be misinterpreted that it is applicable only when
the product or part is new or virgin
© SGS SA 2012 ALL RIGHTS RESERVED
AMENDMENTS TO THE ACT
 §303.37 Form of continuing guaranty
 Revised by replacing the requirement that suppliers
provide a guaranty signed under penalty of perjury with
a certification
 Revising the form used to file continuing guaranties
 §303.41 Use of fiber trademarks and generic
names in advertising
 The words “generic fiber name” was added to
paragraph a. The use of a fiber trademark or a generic
fiber name requires full disclosure of the fiber content in
at least one instance in an advertisement
© SGS SA 2012 ALL RIGHTS RESERVED
AMENDMENTS TO THE ACT
 § 303.42 Arrangement of information in
advertising textile fiber products
 Fiber trade name or a generic fiber name used in
advertising is required to have a full disclosure of the
fiber content information in at least one instance in the
advertisement.
 The rule has been amended to clarify that fibers
present less than 5% may be designated at other fibers
and no need to state the percentage of each fiber
 § 303.45 Coverage and exclusions from the Act
 This paragraph has been reworded for clearer
understanding
 No significant changes
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