Calling It Cotton: Labeling and Advertising Cotton Products

If you advertise or sell clothing or household items containing cotton, the product labels must reflect the fabric content accurately. So say the Textile Act and Rules, enforced by the Federal Trade Commission. The Textile Act and Rules cover fibers, yarns and fabrics, and household textile products made from them, like clothing and accessories, draperies, floor coverings, furnishings and beddings. If the item contains wool, the Wool Act and Rules apply instead of the Textile Act and Rules.

This article explains what information must be included on labels and in written advertisements if you mention the presence of specific kinds of cotton in textile products.

Fiber Content Statement

Any product covered by the Textile Act and Rules must include a fiber content statement that lists:

  • the generic name of each fiber that equals 5% or more of the product's weight, in order of predominance, and the percentage of the product's weight represented by each fiber.

For example: "85% Cotton, 15% Polyester."

Fibers that are less than 5% of the weight should be listed as "other fiber[s]". Fibers that have functional significance, even in small amounts, may be listed by name.

For example: "96% Cotton, 4% Spandex."

A product should not be labeled "100% Cotton" unless it contains only cotton (or only cotton with some non-cotton “trim”). For more information about textile labeling requirements, see Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts.

The fiber content statement may include the name of a type of cotton, the cotton trademark or a term that implies the presence of a type of cotton. The statement must be truthful and not deceptive. If you use a cotton name, trademark, or other term that implies the presence of a type of cotton, you must use the generic fiber name "cotton" with it.

For example, "100% Sea Island Cotton," "50% Pima Cotton, 50% Upland Cotton," "85% Egyptian Cotton, 15% Silk."

You must use type of the same size and conspicuousness for the required fiber content information. The type must be reasonably easy to read. For example, "50% EGYPTIAN COTTON, 50% OTHER COTTON" is permissible; "50% EGYPTIAN COTTON, 50% other cotton" is not. If your product contains more than one kind of cotton, the fiber content statement doesn't have to specify the name and percentage of each cotton type.

For example, the product may be labeled "All Cotton" or "100% Cotton."

If the label of a product made from various kinds of cotton names a cotton type, it must give the cotton's percentage by weight and make clear that other types of cotton also were used to make the product.

For example, a sheet that contains 65% Pima Cotton and 35% Upland Cotton may be labeled "100% Cotton," "100% Cotton (65% Pima Cotton)," "65% Pima Cotton, 35% Upland Cotton," or "65% Pima Cotton, 35% Other Cotton."

If your product contains more than one kind of cotton, a content statement that claims the product is made of only one type of cotton is not acceptable.

For example, when a sheet contains 50% Egyptian Cotton and 50% Upland Cotton, a fiber content label that reads, "100% Egyptian Cotton," is unacceptable.

Use of a Trademark

A fiber trademark or other term must not be used to imply the presence of a fiber that's not actually in the product.

For example, a trademark like "Pimalux" (a fictitious trademark) can’t be used if the textile product  doesn’t contain pima cotton.

A trademark or other term that implies that a product is wholly made of one kind of cotton may not be used when the product is made of more than one kind of cotton, or when it contains fibers other than cotton.

For example, "Pimalux Towel - 100% Cotton" would not be an acceptable disclosure for a product made of 50% Pima Cotton, 50% Upland Cotton because the statement falsely implies that all the cotton in the towel is pima cotton. An acceptable fiber content statement for this product would be "Pimalux Towel - 50% Pima Cotton, 50% Upland Cotton."

Towels

If both loops and ground of a towel are cotton, manufacturers may still want to distinguish between the fiber of the loops and the fiber of the ground, especially if the loops are made of a premium cotton like Pima.

For example, a label saying "100% Cotton, 100% Pima Cotton Loops" or "100% Cotton, Pima Cotton Loops" is acceptable, assuming the statement is truthful. A label saying "100% Pima Cotton" or simply "Pima Cotton" would not be acceptable if only the loops were Pima and the ground was another kind of cotton.

If the loops and the ground of a towel are not the same generic fiber, the label must take into account the fiber weight of each.

For example, if the loops are cotton and the ground is polyester and each comprises 50% of the weight, the label could say “50% Cotton, 50% Polyester."

If the manufacturer wants to show the fiber of the loops separately, the label should disclose: "100% Cotton loops, 100% Polyester ground (loops 50% of fabric, ground 50%)."

A label reflecting only the content of the pile or the back is not acceptable.

For example, when towel loops are 100% Pima Cotton, and the base fabric is 100% Upland Cotton, a label that says only "100% Pima Cotton" or "100% Pima Cotton Loops" is unacceptable.

Including non-required information

Some information is considered non-required. For example, any  reference to a type of cotton that isn't part of the required fiber content statement, but appears on the same label, is non-required information.  Non-required information must not:

  • interfere with, minimize, detract from or conflict with the required information and
  • be false or deceptive as to fiber content.

For example, if the required fiber content statement says "70% Pima Cotton, 30% Upland Cotton," the non-required phrase "Pimalux Towel" must not interfere or detract from it, or be false or deceptive by, for example, falsely implying that the towel is 100% Pima Cotton.

If an item has a label that includes the required fiber content statement, its hang-tag may identify and describe one or more fibers. The item’s hang-tag doesn’t have to include the full fiber content statement if it:

  • tells consumers to see the label for the full fiber content, or
  • states that it doesn’t disclose the product’s full fiber content.

The disclosures aren’t required on a hang-tag that identifies the only fiber in an item. However, the label disclosing the full fiber content for such an item must state that the product is “All” or “100%” of the fiber, as required by the Rules. The fiber content information on a hang-tag must not be false or deceptive.

Read more about hang-tag disclosures.

Items containing wool

If the item also contains wool, the same labeling requirements apply, with these exceptions:

  • the wool content must be identified even if the wool accounts for less than 5%
  • the fibers don’t need to be listed in descending order of predominance

Written Advertisements

An ad doesn't have to mention a product's fiber content or include the name of a particular kind of cotton, cotton trademark or other term implying the presence of a type of cotton. But if it does, it must include the required fiber content information with fibers listed in order of predominance by weight. The percentages of fibers don't have to be included.

For example, "Fine Pima Blend Fabric (Pima Cotton, Upland Cotton)" is permissible in an ad for a product whose label reads "90% Pima Cotton, 10% Upland Cotton." "Pimalux Towel (Pima Cotton, Upland Cotton)" is permissible in an ad for a towel whose label reads "70% Pima Cotton, 30% Upland Cotton."

All required fiber information must appear together in the ad in type of the same size and conspicuousness and that is reasonably easy to read.

Any reference in an ad to fiber content, including the name of a particular kind of cotton, a cotton trademark or other term implying the presence of a type of cotton, must not be false, deceptive or misleading as to fiber content.

If your ad uses the name of a particular type of cotton, a cotton trademark or other term implying the presence of a type of cotton, include that information on the product’s content label.

For more information

See Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts and Clothes Captioning for more about textile labeling requirements and care labels.

Your Opportunity to Comment

The National Small Business Ombudsman and 10 Regional Fairness Boards collect comments from small businesses about federal compliance and enforcement activities. Each year, the Ombudsman evaluates the conduct of these activities and rates each agency's responsiveness to small businesses. Small businesses can comment to the Ombudsman without fear of reprisal. To comment, go to www.sba.gov/ombudsman.

July 2014