In-FUR-mation Alert: How to Comply with the Fur
Products Labeling Act
Whether its a coat, cape, jacket, stole or
parka...if you manufacture, import or sell fur garments, you must comply with the labeling
requirements under the Fur Products Labeling Act (FPLA). Garment labels give consumers
important purchasing information. Consumers assume this information is accurate and
truthful. When its not either through an innocent or deliberate act
their trust in your business is damaged. The likely result for you? A tarnished reputation
The Federal Trade Commission wants to help you comply with the FPLA and its rules and
regulations. You can find these rules at www.ftc.gov.
Fur Labeling Requirements
Fur products garments made either entirely or partly with fur must have a
- The animal name, according to the Fur Products Name Guide.
The Guide at Section 301.0 of the rules lists the animals whose fur could
be used in a garment. However, simply because a name is on the list does not
necessarily make it legal to sell that fur in the U.S. For example, some animals on the
list may be endangered species and the sale of their fur prohibited. In addition, the
Dog and Cat Protection Act of 2000 prohibits importing, exporting, selling, trading,
advertising, transporting, or distributing any products made with dog or cat fur. California
criminal law also prohibits selling dog and cat fur in that state.
It is illegal to label a fur with the name of any animal other than the animal that
produced the fur, and to use coined or fictitious animal names.
The adjective form of the country of origin of the fur may but doesnt have
to precede the animal name (for example, "Russian Mink").
The name or Registered Identification Number (RN) of the
manufacturer, importer or other seller, marketer or distributor of the fur.
The country of origin for imported fur products (including the
country of origin for imported furs made into fur products in the U.S.).
Even if the adjective form of the country name is used with the animal name, the origin
must be stated separately, preceded by the words "Fur Origin" (for example,
"Fur Origin: Russia").
The country of origin of the garment made from fur may be different than the country of
origin of the fur itself. Imported garments must be marked in accordance with the marking
statute, 19 U.S.C. § 1304, enforced by the U.S. Customs Service. For details, see
the Customs web site at www.customs.treas.gov.
You may label domestic fur products to show origin, but the law doesnt require
it. Domestic furs also may be labeled to show the particular state or part of the country
they came from. A name that connotes a false geographic origin cannot be used, and
domestic furs cannot be labeled or advertised in a way that implies they are imported. If
the name of the animal, as listed in the Fur Products Name Guide, includes a geographic
designation, but the animal was raised or taken in the U.S., the origin should be stated
to prevent possible deception (for example, "Mexican Raccoon; Fur Origin: U.S.")
- If the fur is pointed, dyed, bleached, or artificially colored.
If these treatments dont apply, the fur should be labeled "natural."
If the fur product is composed in whole or substantial part (more
than 10 percent of surface area) of pieces, such as paws, tails, bellies, sides,
flanks, gills, ears, throats, heads, scraps, or waste fur.
If the fur is used or damaged.
The textile or wool content of the product, as well as the country of
origin and manufacturer or dealer identity of the textile or wool component.
of LabelingSize. Labels must be a minimum of 1¾ by 2¾ inches (4.5 x
For example, on a wool coat with fur trim, the label must disclose the wool content as
required by the Wool Act and Rules. You can find the text of these rules and the
publication, Threading Your Way Through the Labeling Requirements Under the Textile and
Wool Acts, on the Commissions web site at www.ftc.gov.
The content of a fur coat lining must be disclosed if the lining provides added warmth.
If the lining serves only a structural purpose, its fiber does not have to be disclosed.
If the lining contains any wool, the fiber content must be disclosed.
Durability. The label must be durable enough to remain on the fur
until it is delivered to the consumer.
Lettering. The required information must be no smaller than pica
or 12 point type, with all parts of the information in letters of equal size and
Order. The required order of information on the label is:
- whether the fur is natural or pointed, bleached, or dyed
- if the product contains fur that has been sheared, plucked, or let-out (optional)
- the adjective form of the name of the country from which the animal originated
- name of the animal
- if the fur product is composed of pieces
- country of origin
- any other information that is required or permitted.
and AdvertisingThe required information also must appear on
invoices and in advertising for fur products.
The name or RN of the manufacturer or dealer may precede or follow the above.
Ads for a group of furs with various countries of origin may use the
following statement, instead of separately listing the countries: "Fur products
labeled to show country of origin of imported furs." This does not apply to catalog
advertising where the customer does not have a chance to examine the product and its label
Advertising of a general or institutional nature not intended to
promote the sale of any particular product(s) need not have the required
information. However, if the ad makes any reference to a color, you must disclose whether
the color is caused by artificial coloring.
If the cost to a manufacturer of fur trim used on a garment (not including the cost of
adding the trim to the product) or a manufacturers selling price of a fur
product is $150 or less, the product is exempt from the statute and rules.
The exemption does not apply if:
- the product contains dog or cat fur;
- the product contains used fur;
- the product is the whole skin of an animal, with head, ears, paws, and tail;
- any false, deceptive, or misleading statements are made about the fur.
In addition, if any representations about the fur are made in labeling,
invoicing, or advertising, you must disclose the name of the animal, whether the fur is
artificially colored and whether the fur is composed of pieces.
Therefore, a product that meets the $150 exemption criteria cannot be called fur,
animal fur or genuine fur without disclosures about the animal name, any
artificial coloring process, and the use of fur pieces or waste. The exemption still would
apply to the other Fur Rule requirements, such as the label size, and the disclosure of
fur origin. Compliance with the Textile or Wool Rules labeling requirements would be
necessary for other parts of the garment.
The manufacturer of an exempt fur product must keep records showing the cost of the
fur. If the manufacturers selling price of the product is more than $150, and the
exemption applies because the original cost of the fur to the manufacturer was $150 or
less, the invoice must state that the fur is exempt from the Fur Act and Rules (for
example, "FPL EXEMPT").
Manufacturers and dealers must keep records showing the required information for at
least three years.
Enforcement of the Fur Act
Manufacturers, importers, distributors, and retail sellers are responsible for
complying with fur labeling requirements and may be subject to civil or criminal penalties
for selling mislabeled products. A violation of the FPLA, or the Commissions rules
under the Act, is considered an unfair method of competition and an unfair and deceptive
act or practice under the Federal Trade Commission Act. The Commission may issue an
administrative order prohibiting the conduct that violates the Act. Violators of an
administrative order are subject to monetary civil penalties of up to $11,000 for each
violation. Each instance of mislabeling is considered a separate violation. Criminal
proceedings can be brought against willful violators of the FPLA. Violations of the Dog
and Cat Protection Act of 2000 can result in penalties ranging from $3,000 to $10,000 per
violation, forfeiture of the product, and disbarment from importing, exporting,
transporting, distributing, manufacturing, or selling any fur product in the U.S.
The U.S. Customs Service also can impose marking duties, liquidated damages, or seize
improperly labeled imported items.
Sellers may protect themselves by asking their U.S. supplier of fur products for a
guaranty of compliance with the FPLA and Fur Rules. Continuing guaranties of compliance
also can be filed with the FTC. See sections 301.47-.48 of the Fur Rules for more
information about guaranties.
For More Information
If you have questions about the Textile, Wool and Fur Acts and Rules, contact:
Division of Enforcement
Federal Trade Commission
Washington, DC 20580
You also may visit us at www.ftc.gov on the Web. Click
on Business Guidance for information about complying with the Textile, Wool and Fur
Acts and Rules. Or contact the FTCs Consumer Response Center, Federal Trade
Commission, Washington, DC 20580; toll-free 1-877-FTC-HELP (382-4357); TDD: 1-866-653-4261.
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