Factual review: 6 October 2026. The federal-rule versions checked were current through 1 October 2026.
AI-generated editorial illustration; not a production-approved label or placement diagram.
Before approving clothing labels for the United States, establish three declarations: fibre content, country of origin and a qualifying business identity. An RN number is one identity option. These disclosures are required for covered textile and wool products. Textile rule, section 303.16; wool rule, section 300.3.
This guide helps sourcing and production teams prepare ordinary new adult clothing for US sale. It covers federal labelling and imported-origin rules; care instructions remain a separate obligation.
Prepare the fibre-content declaration
Generic names and percentages
First establish which regime applies. Products required to be labelled under the Wool Products Labeling Act are excluded from the textile rules. Their declarations follow the wool rules. Section 303.2(c).
Use the prescribed generic fibre names and percentages by weight. Under the textile rule, named fibres appear in descending weight order, with “other fiber” or “other fibers” last. A fibre trademark cannot replace its generic name. Sections 303.6–303.7 and 303.17; section 303.16; wool equivalent, section 300.8.
For a verified simple blend, 60% cotton / 40% polyester illustrates the declaration. It is not a substitute for checking the actual garment’s composition.
Minor fibres and garment components
The 5% threshold does not give general permission to leave fibres out:
| Situation | Treatment |
|---|---|
| A fibre below 5% under the textile rule | Normally disclose its percentage as “other fiber”; aggregate multiple such fibres as “other fibers”. |
| A minor fibre with an established function | It may be named where it has a clearly established, definite functional significance at the amount present. |
| Wool or recycled wool in a covered wool product | State the relevant percentage even below 5%. |
These distinctions come from section 303.3 and section 300.3(b).
Review the whole construction. Under the textile rule, linings, interlinings, fillings and paddings need separate fibre disclosure when incorporated for warmth or when fibre-content claims are made about them. A shell-fabric declaration alone may therefore be insufficient. Section 303.22.
Wool garments have separate component rules, including a requirement to disclose interlining composition separately. Do not apply textile exceptions automatically to wool products. Section 300.23.
Establish origin from the manufacturing facts
For imported textile products, the Federal Trade Commission (FTC) accepts origin determined under the laws administered by US Customs and Border Protection (CBP). Section 303.33(d).
The textile-origin rule applies tests in sequence: wholly obtained or produced; specified changes in tariff classification and other requirements; then, where necessary, later knitting, assembly or manufacturing tests. Its scope and exceptions matter. Neither the dispatch country nor the last sewing operation is a universal answer. 19 CFR 102.21(a), (c) and (e).
Before artwork approval, ask the factory for the manufacturing stages and their countries, including fabric production, knitting to shape where relevant, cutting, assembly and finishing. Have the importer or customs adviser check the garment’s tariff classification and applicable origin rule against those facts.
This review concerns the label’s origin declaration. Preferential-duty eligibility and broader Made in USA advertising claims need their own assessment.
Choose a qualifying business name or RN
Is an RN compulsory?
No. An FTC Registered Identification Number (RN) can replace the qualifying business name. The textile rule also permits a US-registered word trademark used as a house mark identifying the business. An arbitrary brand logo is insufficient. Section 303.19.
The wool rule uses different wording: its name must be the name under which the qualifying business operates. Do not assume the textile house-mark option applies. Sections 300.4 and 300.13.
What can an overseas brand use?
FTC guidance allows imported products to identify the foreign manufacturer or distributor, or a qualifying US importer, wholesaler or consenting retailer. Agree whose identity represents a business actually involved in the product’s supply chain. FTC business-identification guidance.
RN issuance is restricted to qualifying US-resident applicants. Applications and registration updates normally use the FTC RN website. An RN cannot be transferred or assigned to another business. Section 303.20.
An IRS tax number or Canadian CA number cannot substitute for the required business name or RN. FTC RN FAQ, question 8; permitted textile identification, section 303.19.
Check the label arrangement
For covered garments with a neck, origin must appear at the inside centre neck, between the shoulder seams, or close to another label attached there. Origin belongs on the front of its label. Composition and identity may appear elsewhere on a conspicuous, readily accessible label. Section 303.15(b); wool equivalent, section 300.5(b).
Two illustrative arrangements for a conventional adult shirt are:
| Arrangement | Neck label at the required position | Accessible side-seam label |
|---|---|---|
| Combined declarations | Verified origin, composition and qualifying identity | Care information, if placed here |
| Split declarations | Verified origin | Verified composition and qualifying identity; care information may share this label |
These show information placement, not finished artwork. Each declaration and the care instructions need verification.
Required information must include English. For wool products, if any required information appears in another language, all required information must appear in both languages. Section 303.4; section 300.7.
Check attachment and packaging too:
- Textile and wool disclosures: labels must remain attached through distribution and delivery to the consumer. Section 303.15(a); section 300.5(a).
- Imported origin marking: subject to exceptions, marking must be conspicuous, legible, indelible and as permanent as the article permits. 19 CFR 134.11.
- Care information: the care label must stay attached and legible through the garment’s useful life. If it cannot be seen or easily found at sale, care information also belongs on the package exterior or an attached hang tag. Sections 423.1(a) and 423.6(a).
Retail packaging intended to remain intact until delivery generally needs the textile/wool information too, unless it can be clearly read through the packaging. Section 303.28; section 300.15.
Before sending artwork to the factory
Use this practical handover checklist:
- Confirm fibre names, percentages and component disclosures against supplier evidence.
- Record the manufacturing facts and reviewed origin declaration.
- Confirm the qualifying business name or RN with the relevant business.
- Check English wording, placement, readability, attachment and retail packaging.
- Send the approved artwork version and separately substantiated care instructions together.
Resolve any change in composition, manufacturing route or business identity before reusing an existing label specification.
Related guides
- US clothing labelling requirements
- US care-label requirements and ASTM symbols
- EU fibre composition and animal-origin disclosures
Topics: US Labelling · Fibre Composition