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Discussion Starter · #1 ·
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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Re: My label contents - is everything correct?

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.

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).

And the RN# must be mine and not the shirt manufacturer?
It doesn't have to be.

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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Discussion Starter · #5 ·
Re: My label contents - is everything correct?

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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Re: My label contents - is everything correct?

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.

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.

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:

FTC said:
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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Re: My label contents - is everything correct?

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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Re: My label contents - is everything correct?

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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Discussion Starter · #9 ·
Re: My label contents - is everything correct?

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.
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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Re: My label contents - is everything correct?

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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Discussion Starter · #11 ·
Re: My label contents - is everything correct?

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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Re: My label contents - is everything correct?

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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Re: My label contents - is everything correct?

...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").
Sorry, I worded that wrong. You can use the manufacturer's RN# and put whatever you want. If there is no RN# at all, you have to use your company name. Obviously you don't want to do that. Best thing to do is just apply for an RN#. It's free and you can do it online. They email it to you within a day or two.

To be clear, here is what they FTC says:
You are required to label covered products to show the name or identifying number of a U.S. business responsible for manufacturing or marketing the product or the name of a foreign manufacturer. Therefore, you may use your company business name on the label instead of an RN. The business name is the full name that appears on business documents, such as purchase orders and invoices. It is not a trademark, brand, or designer name (unless that is also the name under which the company conducts business). Alternatively, the goods may be labeled with the RN or business name of the company that is buying the goods from you - such as a distributor or retailer. If you are acquiring the finished products from a U.S. manufacturer, importer, or distributor, they can remain labeled with the RN or business name of that company. RN numbers are available only to businesses residing in the U.S. However, imported goods can be labeled with the name of their foreign manufacturer.
 

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Re: My label contents - is everything correct?

Sorry, I worded that wrong. You can use the manufacturer's RN# and put whatever you want. If there is no RN# at all, you have to use your company name.
Excellent, sounds like we're on the same page.

Best thing to do is just apply for an RN#
That does pretty much make all the above moot. And in the unlikely event someone wants to know what blanks you're using, it means they'll need to ask :)
 

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Re: My label contents - is everything correct?

if i was an elementary school teacher teaching at a school that didn't believe in grades, i would give your label a check plus plus!
 

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Re: My label contents - is everything correct?

ok im a little confused about thisa whole RN subject.

ig: the American Apparel labels have...... Top label " front has just the american apparel logo. back has where it was amnufactured and the type of textile"
Back Label "front has the size of the shirt, again the type of textile. and the back has American Apparels RN#and all of the washing directions and hazzard symbols"

would i just be able to remove the front tag and replace it with my own saying w.e i want it to say? "it would be my legal company name"

is this fine? or do i need something else?

thankss
 

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Re: My label contents - is everything correct?

would i just be able to remove the front tag and replace it with my own saying w.e i want it to say?
Should be fine, if the back tag you're leaving takes care of the legal requirements (which it usually does).
 
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