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FIBER CONTENT US Regulations & Testing Presented by: Louann Spirito Director Technical Support Softlines

FIBER CONTENT - USFIA 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

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Page 1: FIBER CONTENT - USFIA 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

FIBER CONTENT

US Regulations & Testing

Presented by:

Louann Spirito

Director Technical Support Softlines

Page 2: FIBER CONTENT - USFIA 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

© SGS SA 2012 ALL RIGHTS RESERVED

FIBER CONTENT REGULATIONS

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© 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

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© 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

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© SGS SA 2012 ALL RIGHTS RESERVED

Regulation Citation

Textile Fiber Products Identification Act

16 CFR 303

Wool Products Labeling Act 16 CFR 300

Fur Products Labeling Act

16 CFR 301

The Endangered Species Act of 1973

Dog and Cat Protections Act 2000 US Public Law 106 –

476 Chapter 3, Sect

1441-1442

The Leather Guide 16 CFR 24

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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

APPAREL PRODUCTS

Clothing - except hats

and shoes

Handkerchiefs

Scarves

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© SGS SA 2012 ALL RIGHTS RESERVED

HOME FURNISHING PRODUCTS

Floor coverings - rugs,

carpets, mats

Towels, washcloths, and

dishcloths

Ironing board covers and

pads

Doilies, dresser scarves

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© SGS SA 2012 ALL RIGHTS RESERVED

HOME FURNISHING PRODUCTS

Tablecloths and

napkins

Bedding

Draperies

Cushions

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© SGS SA 2012 ALL RIGHTS RESERVED

HOME FURNISHING PRODUCTS

Curtains and

casements

Afghans and throws

Furniture slip covers

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© SGS SA 2012 ALL RIGHTS RESERVED

OTHER PRODUCTS

All fibers, yarns, and

fabrics (except sewing

& handicraft threads)

Umbrellas and parasols

Hammocks

Flags

Sleeping bags

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© 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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© SGS SA 2012 ALL RIGHTS RESERVED

WHAT IF YOUR PRODUCTS CONTAIN WOOL?

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© SGS SA 2012 ALL RIGHTS RESERVED

Most products that contain any amount of wool are covered

by the Wool Act and must be labeled accordingly.

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© SGS SA 2012 ALL RIGHTS RESERVED

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

WHAT IF YOUR PRODUCTS CONTAIN WOOL?

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© SGS SA 2012 ALL RIGHTS RESERVED

NOW, WE KNOW WHAT PRODUCTS MUST

HAVE FIBER CONTENT LABELS….

The next challenge is writing an accurate fiber

identification label

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© SGS SA 2012 ALL RIGHTS RESERVED

CONFIRM THE ACTUAL FIBER CONTENT

Obtain fiber content test results

Be knowledgeable about interpreting the results

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© SGS SA 2012 ALL RIGHTS RESERVED

FIBER IDENTIFICATION TESTING

Physical

Chemical

Microscopic

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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

CHEMICAL TESTING

Quantitative - used to determine percentages

Fibers/yarns/fabrics placed in chemical bath, agitated, filtered, dried, and weighed

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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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

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© 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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© SGS SA 2012 ALL RIGHTS RESERVED

FIBER NAMES

Specialty wool fibers

Specialty wool fiber names may be used

Mohair Cashmere

Camel Alpaca

Llama Vicuna

If the name of a specialty fiber is used, the percentage of

that fiber must also be used

50% Camel Hair

50% Wool

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© 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

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© 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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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

The label can say “All” or “100%” if the fabric is made all

from one fiber

ON A FIBER LABEL...

100% Cotton

All Cotton

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© 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

63.4% Rayon

29.2% Polyester

7.4% Spandex

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© 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

Label

65% Rayon

28% Polyester

7% Spandex

Report

63.4% Rayon

29.2% Polyester

7.4% Spandex

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© SGS SA 2012 ALL RIGHTS RESERVED

ON A FIBER LABEL….

Label printed before report! Can cause

problems.

Label

60% Rayon

33% Polyester

7% Spandex

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© SGS SA 2012 ALL RIGHTS RESERVED

ON A FIBER LABEL….

Label printed before report! Can cause

problems.

Label

60% Rayon

33% Polyester

7% Spandex

Report

63.4% Rayon

29.2% Polyester

7.4% Spandex

Page 38: FIBER CONTENT - USFIA 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

© SGS SA 2012 ALL RIGHTS RESERVED

ON A FIBER LABEL….

Label printed before report! Can cause

problems.

Label

60% Rayon

33% Polyester

7% Spandex

Report

63.4% Rayon

29.2% Polyester

7.4% Spandex

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© SGS SA 2012 ALL RIGHTS RESERVED

ON A FIBER LABEL….

Label printed before report! Can cause

problems.

Label

60% Rayon

33% Polyester

7% Spandex

Report

63.4% Rayon

29.2% Polyester

7.4% Spandex

New Label

64% Rayon

29% Polyester

7% Spandex

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© SGS SA 2012 ALL RIGHTS RESERVED

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”

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© SGS SA 2012 ALL RIGHTS RESERVED

FOR EXAMPLE:

Using heather colored fabric ---------

98% Cotton

2% Polyester

98% Cotton

2% Other

Wool in any amount must always be listed

98% Cotton

2% Wool

98% Cotton

2% Wool

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© 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

4% Nylon

98% Cotton

2% Spandex

Page 43: FIBER CONTENT - USFIA 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

© 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

10% Polyester

4% Nylon

4% Rayon

82% Cotton

10% Polyester

8% Other Fibers

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© 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

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© 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

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© SGS SA 2012 ALL RIGHTS RESERVED

EXEMPTION EXAMPLES

100% Cotton

exclusive of decoration

Body – 100% Cotton

Ornamentation – 100% Silk

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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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.

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© SGS SA 2012 ALL RIGHTS RESERVED

EXCLUSIVE OF DECORATION

Fibers used in logos

that vary from body

fiber must be called

out on label

100% Cotton

Exclusive of

Decoration

Rayon

Cotton

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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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

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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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© SGS SA 2012 ALL RIGHTS RESERVED

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.

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How about a leather garment or leather trim on a garment?

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© 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

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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 Vinyl

Imitation Leather Vinyl Coated Fabric

Simulated Leather Plastic

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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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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© SGS SA 2012 ALL RIGHTS RESERVED

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

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© 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

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© 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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© SGS SA 2012 ALL RIGHTS RESERVED

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

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© SGS SA 2012 ALL RIGHTS RESERVED

FTC Amended Textile Fiber Identification Act

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© 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”

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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

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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

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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

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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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