Annushka

HI guys, I'm finishing the design for my labels and want to make sure that all the info is in compliance with the ftc rules. Please review and let me know if this is ok.

FRONT
logo
name of the clothing line (which is the company name, minus the Inc. ending)
Made in (country of origin)
Decorated in USA
100% cotton
size

BACK
RN #
care instructions

As long as I use RN# I don't have to put the company name with the Inc., correct? And the RN# must be mine and not the shirt manufacturer? Also is it ok to state that the garment was decorated in US as long as I have the country of origin listed as well? THanks a lot everyone

 

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Dave 2006

looks like your on the money to me

 

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Annushka

Quote: Originally Posted by Dave 2006 looks like your on the money to me

Thanks Dave

 

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Solmu

Quote: Originally Posted by Annushka I'm finishing the design for my labels and want to make sure that all the info is in compliance with the ftc rules.

It's been a while since I did my reading on this, but I can't think of anything you're overlooking.

Quote: Originally Posted by Annushka As long as I use RN# I don't have to put the company name with the Inc., correct?

Correct. In fact you don't have to put the company name at all (but you'd want to I imagine).

Quote: Originally Posted by Annushka And the RN# must be mine and not the shirt manufacturer?

It doesn't have to be.

Quote: Originally Posted by Annushka Also is it ok to state that the garment was decorated in US as long as I have the country of origin listed as well?

I'm pretty sure it is. You couldn't, for example, put "Decorated in the USA" in 16pt type and then "Made in {COO}" in 8pt type. But if it's accurate and not misleading you should be fine.

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Annushka

THank you Lewis. I used the same size and font for the entire label so nothing dominates. The only thing I am still unsure of is the RN#. THis is what I understood from the ftc's site - you have to use your company's name exactly as it is used to do business, unless you use an RN# in which case you can use the name of your brand or the clothing line instead. I think the purpose of all this is to make sure the consumer knows or has a way to track (with the RN#) the company selling the product. If I got this right than I have a feeling that if I want to use the name of the brand (and not the exact name of my company) than I have to get RN#. Because otherwise if I use the manufacturer's RN and only a brand name on the label than my company's name stays undisclosed. Do I have this right?

 

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Solmu

Quote: Originally Posted by Annushka The only thing I am still unsure of is the RN#. THis is what I understood from the ftc's site - you have to use your company's name exactly as it is used to do business, unless you use an RN# in which case you can use the name of your brand or the clothing line instead.

Yes.

Quote: Originally Posted by Annushka I think the purpose of all this is to make sure the consumer knows or has a way to track (with the RN#) the company selling the product.

I don't think it's the company selling the product that's important, but the company that made it (and therefore the conditions under which it was made). If you re-label goods with your RN you have to keep track of what you relabelled - ultimately the FTC want to be able to track it back to the source. That's my interpretation anyway.

Quote: Originally Posted by Annushka If I got this right than I have a feeling that if I want to use the name of the brand (and not the exact name of my company) than I have to get RN#. Because otherwise if I use the manufacturer's RN and only a brand name on the label than my company's name stays undisclosed. Do I have this right?

Honestly, I'm not 100% sure either. I always took this:

Quote: Originally Posted by FTC textile labels must identify either the company name or Registered Identification Number (RN) of the manufacturer, importer, or another firm marketing, distributing, or otherwise handling the product

...to mean that more or less anyone in the chain could be the company with the RN. So my interpretation (which may not be correct) is that you don't have to get an RN, but you certainly can if you want to. However I don't think it's completely unambiguous, and while I have done further reading in the past it's fading now

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monkeylantern

The only thing I can think of is make sure you put on *all* the washing instructions. There are many places where that means wash temp, drying guide, no dry cleaning etc.

Seeing as you're doing everything right, you may as well be right *everywhere* you might sell.

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Solmu

Quote: Originally Posted by monkeylantern The only thing I can think of is make sure you put on *all* the washing instructions. There are many places where that means wash temp, drying guide, no dry cleaning etc.

The US is one of those places - they have some of the stricter (if not strictest) labelling laws.

I suspect the only way you can be compliant with US labelling regulations, and not compatible with those of another country, is in cases where the two are mutually exclusive (e.g. "Use US care symbols" / "Use standard international care symbols").

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Annushka

Thanks a lot guys. I'll go over the requirements for care insturctions labels one more time. I also thought about sending ftc directly the final draft of the label to review. I dont' know if they'd respond and how fast, but it's worth a try to avoid headaches in the future.

Quote: I don't think it's the company selling the product that's important, but the company that made it (and therefore the conditions under which it was made). If you re-label goods with your RN you have to keep track of what you relabelled - ultimately the FTC want to be able to track it back to the source. That's my interpretation anyway.

- Lewis your comment makes sense. In which case I should ask ftc whos RN should I use.

 

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highstyleinc

If you have your own RN#, you can use your company logo or name or nothing, but like Lweis mentioned, you will most likely want to put your brand on the label.

If you want to use the manufacturer's RN#, then you have to use your legal name of the company.

Everything else looks good. The manufacturer will have the correct washing symbols if that's what you are using.

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Annushka

Quote: Originally Posted by highstyleinc If you have your own RN#, you can use your company logo or name or nothing, but like Lweis mentioned, you will most likely want to put your brand on the label. If you want to use the manufacturer's RN#, then you have to use your legal name of the company.

Cool, that's exactly what I thought. Thanks Kris.

 

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Solmu

Quote: Originally Posted by highstyleinc If you want to use the manufacturer's RN#, then you have to use your legal name of the company.

...in which case there's no point using the manufacturer's RN


How sure are you of this? I'm not saying you're wrong or anything (I definitely don't know), I'm just asking because it's important and I want to be 100% sure.

My understanding has always been that if you leave the back label, you can replace the front label with whatever you want. If the above is true however, that is incorrect: the extra label you add in would have to have your full legal company name on it (i.e. not "whatever you want").

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Annushka

I'll try callling ftc tomorrow. I'll post once I have an answer from them.

 

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