Care Labels and Compliance for Textiles Entering the US Market
US textile labelling is not complicated, but it is exact, and the cost of getting it wrong lands entirely on the brand rather than on the factory. This post sets out what is required, what CPSIA adds if you make anything for children, and - the part most sourcing guides skip - a clear division of who does what.
| Status of this guidance - as at September 2026 |
|---|
| A practical summary written from a manufacturer’s perspective, not legal advice. Requirements are set out in FTC rules including 16 CFR 303 and 16 CFR 423, and in CPSC regulations for children’s product. Verify the current text against FTC and CPSC guidance, and take specialist advice for children’s product or protective apparel. |
The three things on every textile label
Under the Textile Fiber Products Identification Act and its rules, textile products offered for sale in the US must carry three pieces of information. Care instructions are a fourth requirement, under a separate rule.
1. Fiber content
Stated using the generic names of the fibers - cotton, linen, silk, polyester - not trade names, and by percentage of total fiber weight.
- A single-fiber product: "100% Linen".
- A blend: each fiber listed by generic name in descending order of weight. "55% Linen, 45% Cotton".
- Fibers under 5% of total fiber weight generally cannot be named and are designated "other fiber" or "other fibers" - unless the fiber has a clearly established functional significance at that level, elastane being the usual case.
Note that "linen" and "flax" refer to the same fiber; US labelling conventionally uses linen. Get the composition from your manufacturer in writing, because the same figure drives both your label and your HTS classification, and an inconsistency between the two is the kind of thing that turns a routine entry into a query.
2. Country of origin
Goods made in India are marked "Made in India". This has to be conspicuous - for apparel that normally means the front of a neck label or an equally prominent position, not buried in a side seam behind three other labels. Both Customs marking rules and FTC rules bear on this, and "assembled in", "designed in" and similar constructions are regulated rather than decorative.
3. The identity of the responsible company
Either the company name under which business is conducted, or a Registered Identification Number (RN) issued by the FTC.
The practical point here is one that catches new importers: RN numbers are issued to businesses residing in the United States. Your Indian manufacturer cannot hold one. In a private label arrangement the identity on the label is your brand, which is consistent with where the legal responsibility sits anyway. If you do not have an RN, you can apply to the FTC, or simply use your registered company name.
4. Care instructions
Under the Care Labeling Rule, manufacturers and importers must provide care instructions so a consumer knows how to clean the product. In practice:
- The label must be permanently attached and remain legible for the useful life of the product.
- It must give a full regular care procedure - washing or dry cleaning, and where relevant drying, bleaching and ironing.
- It must carry warnings where an otherwise reasonable action would harm the product or other items. Washing with other colours is the standard example, and it is a real one for deep-dyed linen.
- The label need not be attached at the time of importation - but it must be there before sale to the consumer.
That last point is technically permissive and practically a trap. Yes, you can import unlabelled and relabel domestically. The cost of doing so on a full container is substantially more than the labels, plus the warehouse time, plus the delay. Have them applied at manufacture.
Linen-specific care wording
Two things are worth specifying properly rather than copying from another brand's label.
Shrinkage. Untreated linen commonly shrinks 3-7% on first wash. If the fabric is pre-shrunk, your care instruction can be straightforward. If it is not, the instruction and the pattern allowance have to account for it. Confirm which you have - our GSM guide covers what to specify on the tech pack.
Colour bleeding. Deeply dyed linen, particularly indigo and strong naturals, can bleed on first wash. If that is a characteristic of your fabric, the warning is not optional - it is exactly the situation the rule contemplates.
Children's product: CPSIA
If any part of your range is intended for children aged 12 and under, a separate and considerably stricter regime applies. This is not a footnote to the labelling rules; it is a different compliance programme.
| Requirement | What it means |
|---|---|
| Lead limit | 100 ppm maximum in accessible substrate materials |
| Third-party testing | By a CPSC-accredited laboratory, on the actual item and all its components |
| Children’s Product Certificate | Issued on the basis of that testing, and filed as required |
| Tracking label | Permanent, identifying producer, location and date of production, and batch |
| Flammability | Textiles must meet CPSC flammability standards under the Flammable Fabrics Act |
| Test report currency | Reports are expected to be recent - typically within the past year for children’s product |
The sentence to internalise: the US importer of record carries the legal liability, even when the overseas factory arranged the testing. A test report from a supplier is evidence, not a transfer of responsibility. If children's product is a meaningful part of your plan, budget for a compliance consultant rather than working it out from blog posts.
Who does what
This table is the reason this post exists. Most compliance problems are not disagreements about the rules; they are gaps where each party assumed the other had it.
| Item | Manufacturer | Brand / importer |
|---|---|---|
| Fiber composition by weight | States it accurately, in writing | Verifies it and puts it on the artwork |
| Label artwork | Prints exactly what is supplied | Supplies compliant artwork - owns the wording |
| Country of origin marking | Applies it | Confirms placement is conspicuous |
| RN or company name | Cannot hold an RN | Provides its own identity |
| Care instructions | Advises based on the fabric; applies the label | Approves the wording and warnings |
| Permanent attachment | Attaches so it survives the product’s life | Checks on the PP sample |
| Fabric test reports | Provides to buyer requirements | Specifies which tests are needed |
| CPSIA testing and CPC | Facilitates; provides components | Legally responsible |
| HTS classification | Supplies an accurate goods description | Classifies, with a broker |
| Customs declaration accuracy | Accurate export documents | Legally responsible as importer of record |
The pattern is consistent: we print what you specify; you own what is specified. A manufacturer who offers to "handle compliance for you" is describing something that is not legally possible in the US market, and that should worry you rather than reassure you.
A pre-bulk checklist
- Fiber composition confirmed in writing by the manufacturer, matched against the artwork.
- Label artwork approved, including fiber content, "Made in India", your name or RN, and care instructions with any necessary warnings.
- Placement and permanence checked on the PP sample, not on a photograph.
- HTS code confirmed with your broker against that same composition.
- Any required test reports requested and received before bulk, not after.
- For children's product: CPSC-accredited testing, CPC and tracking label design all resolved before production starts.
All of that costs almost nothing at the artwork stage. All of it is expensive once the goods are in a warehouse in New Jersey.
We apply labels, tags and packaging to specification as standard, manufacture to OEKO-TEX standards, and supply testing and compliance documentation to buyer requirements. If you are working through the commercial side as well, our guide to private label for US brands covers Incoterms, minimums and transit times.
Frequently asked questions
Do care labels have to be attached before the goods are imported?
No. The FTC Care Labeling Rule requires that a permanent care label be attached before the product is sold to a consumer, not at the moment of importation. In practice you should still have them applied at manufacture, because relabelling a container of goods in a US warehouse costs far more than the labels do and introduces a delay you did not plan for.
Can our Indian manufacturer put their name on the label?
The label must identify the company name under which business is conducted, or a Registered Identification Number. RN numbers are issued by the FTC to businesses residing in the United States, so an Indian manufacturer cannot hold one. In almost all private label arrangements the identity on the label is the US brand or importer, which is also who carries the compliance responsibility.
How do we describe a fiber that is less than 5% of the garment?
Fibers present at less than 5% of the total fiber weight generally cannot be named and must be designated as "other fiber" or "other fibers", unless the fiber has a clearly established and definite functional significance at that amount - elastane for stretch being the usual example. Ask your manufacturer for the exact composition by weight in writing, because you need it for the label and for your customs classification.
What extra applies to children’s clothing?
CPSIA. Children’s products must meet a lead limit of 100 ppm in accessible substrate materials, be tested by a CPSC-accredited laboratory, be covered by a Children’s Product Certificate, and carry a permanent tracking label identifying the producer, location and date of production and batch. Textile flammability requirements under the Flammable Fabrics Act apply as well. The US importer of record carries the legal liability even where the overseas factory arranged the testing.
Who is legally responsible if the label is wrong?
The party whose name is on the product and the importer of record - in other words, you. A manufacturer prints what the artwork says. If the artwork is wrong, or the fiber composition it states does not match the goods, the exposure sits with the US brand. This is why the composition should be confirmed in writing by the manufacturer and matched against the artwork before bulk production begins.
Labels applied at manufacture cost a fraction of relabelling.
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