A Cut Ahead: Trending Textiles & Labeling Regulations In May 2024

The textiles regulatory environment is ever-changing, especially considering chemical, labeling, and extended producer responsibility (EPR) issues that the industry faces today. With a 26% growth in textile regulations since 2020, its more important than ever to stay ahead of changing regulatory requirements.

To help you stay a cut ahead, we gather some of the most interesting recent inquiries from Compliance & Risks customers around trending textile labeling regulations across the world.

Q1) Care Instructions in Mexico

Regarding the labeling requirement for care instructions on clothing in Mexico, can the care instructions be in symbols or written?

Kim Plassche, Senior Regulatory Consultant, answers:

Per Section 4.5 of NOM-004-SE-2021 on care instructions, garments, their accessories and household linens must bear information regarding the proper treatment and care and conservation instructions, including, where appropriate, the following data:

Washing;
Bleaching;
Drying;
Ironing;
Particular recommendations, making specific mention of tendencies towards shrinkage or deformation when they are specific, indicating instructions to address them.

Per Section 4.5.6, these instructions must be indicated by means of brief and clear legends or symbols, in accordance with the provisions of the Mexican standard NMX-A-3758-INNTEX-2014.

Symbols other than those provided for in this regulation may be used, only when the legend relating to the appropriate treatment and care and conservation instructions also appears in Spanish.

Q2) Penalties for Non-Compliance for Fiber Names

If a textile product with a label displaying fiber names different from those on the FTC recognized lists imported to the US, what are the possible sanctions and/or ranges of monetary penalties for such non-compliance?

Maria Marecki, Market Access Manager, answers:

Regarding enforcement, the FTC states:

“A violation of the Textile, Wool and Fur Acts, or the Commission’s Rules under those Acts, is considered an unfair method of competition and an unfair and deceptive act or practice under the Federal Trade Commission Act.

The FTC Act provides various remedies for these violations, including issuing an administrative order prohibiting the act or practice that violates the FTC Act. Violators of an administrative order are subject to monetary civil penalties of up to $51,744 per violation. Each instance of mislabeling under the Textile, Wool and Fur Acts is considered a separate violation.

Businesses not subject to a previous administrative order also can be subject to monetary civil penalties, an injunction and other remedies, including consumer redress, in a federal district court action. The Commission can bring a civil penalty case against a company that knowingly engages in practices like mislabeling of textile products that the Commission has determined to be unfair or deceptive in prior cases. In this kind of case, “knowledge” refers to knowledge of the law. Because copies of the statutes, rules, and prior decisions in the textile, wool and fur areas have been distributed widely by the Commission, many manufacturers and sellers know the labeling requirements.

Improperly labeled imported items can be held up by Customs and possibly subject to liquidated damages.”

The FTC has a list of penalty offenses concerning textiles here.

Q3) Down Labeling in South Korea

Has there been an update to Korean Standard KS K 2620 on down labeling requirements?

Maria Marecki, Market Access Manager, answers:

The last change to KS K 2620 appears to have been in December 2022.

There was a recent amendment to down labeling requirements made by Notice No. 2024-27. The Notice made changes to Annex 1 (Household textile products) of the Safety standards for household products subject to safety standards compliance. The change requires the indication that the product is made of recycled down/feathers, if they are used.

Meet Our Experts

Maria Marecki, Market Access Manager, Compliance & Risks

Maria Marecki is the Market Access Manager at Compliance & Risks.

She has over a decade of experience as a research consultant compiling customized products to address strategic business needs for retailers and manufacturers, including entering new geographic markets and development of global best practices around regulatory compliance.

Her experience in product safety and labeling spans a wide range of products including children’s products, apparel, footwear, electronics, and cosmetics.

Kim Plassche, Senior Regulatory Consultant, Compliance & Risks

Kim Plassche is a Senior Regulatory Consultant on the Global Market Access team at Compliance & Risks, where she researches and monitors international product safety legislation for custom client reports.

Kim is a librarian, with 18 years of experience and a Master of Library Science from the State University of New York at Buffalo, Buffalo, NY. Prior to taking on her role at Compliance & Risks, she served as Map Librarian at her alma mater.

Kim has also worked in public and private libraries, including at a consumer products testing company, where she researched regulations and standards for internal and external clients.