How to design a tagless neck label print that is FTC compliant

We’ve all seen it done... You are looking for a new shirt and finally you find one that is just your style. So with great joy, you open up the neck area of the shirt to see if it’s your size and with a sigh of relief it is! Not only that, but the label you are looking at is not the itchy kind that you always rip out, but it is a printed one the brand logo on it too.

As part of the laws that rule how we do business, the FTC or FEDERAL TRADE COMMISSION have requirements to help both the general public and manufacturers protect themselves physically and financially.  

1 | BRANDING

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Well.. Did you know, most clothing brands buy their T-Shirts for only a handful of source manufacturers? Because of that, and to advertise their own brand, apparel companies replace the manufacturer's label for one of their own. But you might ask, how is this legal? Well, the FEDERAL TRADE COMMISSION or FTC states, an importer, distributor, or retailer may want to replace the original label on a textile product with a label showing its company or RN. This is legal as long as the new label lists the name or RN of the person or company making the change. If there is no record of the number, it does not apply.

2 | PRINT SIZE & LOCATION

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When designing your private labeled custom apparel, being creative and having your own unique style is key. So why always see the branded neck label in the yoke of the shirt? Does the law require a specific placement in regards to the care and content of this information?

Label(s) with required information must be securely attached to the product until it is delivered to the consumer, but they don’t need to be permanently attached.

When a garment has a neck, you must attach a label that discloses the country of origin on its front to the inside center of the neck. Attach the label either midway between the shoulder seams or close to another label attached to the inside center of the neck. The fiber content and manufacturer or dealer identity can appear on the front or back of the same label, or on another conspicuous and accessible label(s) on the inside or outside of the garment.

So does the print size really matter? Yes. Especially when producing T-Shirts and needing to relabel your garments, since the garment is already finished or sewn together, the screen printer needs to have an easy way to print on your garments in the inside neck area without the extra time it would take to turn your shirt inside out or without stretching the neck area. Due to this, size does matter and below is helpful guide on how  all of your artwork should be contained within it.

Most Screen Printers have sleeve pallets they use which are 4” wide X 18+” long. Even though the length is there, the less you should use. Not all Screen Printers print the label in. Some create forms of neck labels they can apply by heat transfer. The overall idea is the provide the maximum amount of space to place your branding with the least amount stretching out your product and cause damage. 

3 Layout Style

REGRADING LETTERING SIZE
“All required information must be clearly legible, conspicuous, readily accessible to the prospective purchaser and in letters of equal size and conspicuousness. All of the required information must appear on one side of the label.”

3 | CARE AND CONTENT

Labels for clothing must have a washing or drycleaning instruction. If an item can be washed and drycleaned, the label needs only one of these instructions. Sometimes, because of the particular combination of components, a garment can’t be safely washed or drycleaned. The label on such a garment must say "Do not wash — Do not dryclean."

NOTE: You may use the care symbols from the American Society for Testing and Materials (ASTM). ASTM Standard D5489-96c Standard Guide for Care Symbols for Care Instructions on Textile Products, in place of words, but the symbols must fulfill the requirements of the Rule.

Washing Instructions:  5 Elements

1  | washing

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The label must say whether the product should be washed by hand or machine, and give a water temperature setting if regular use of hot water will harm the product.

Two | Bleaching

If all commercially available bleaches can be used on a regular basis without harming the product, the label doesn’t have to mention bleach.

If using chlorine bleach on a regular basis will harm the product, but using non-chlorine bleach on a regular basis won’t, the label must say, "Only non-chlorine bleach, when needed."

If all commercially available bleaches would harm the product when used on a regular basis, the label must say, "No bleach" or "Do not bleach."

Three | Drying

The label must say whether the product should be dried by machine or another method. Unless regular use of high temperature will harm the product when machine dried, it’s not necessary to indicate a temperature setting.

Four | Ironing

If a product needs repeated ironing, the care label must give ironing information. If regular use of a hot iron won’t harm a product, it’s not necessary to indicate a temperature setting.

Five | Warnings

If you have a reasonable expectation that a consumer could use a care procedure that will harm the product, the label must contain a warning like "Do not," "No," or "Only," to warn against the harmful procedure. For example, if a garment will be harmed by ironing, and you expect a consumer could occasionally “touch up” the garment, the label should state, "Do not iron."

If a care procedure on one product could harm another product that is washed with it, the label must include a warning. For example, if an item is not colorfast, the label must say "Wash with like colors" or "Wash separately."

Warnings aren’t necessary for alternative procedures that could be harmful. For example, if the instructions state "Dry flat," it's not necessary to state "Do not tumble dry."

4 | COUNTRY OF ORIGIN

Imported products made entirely abroad
A textile product made entirely abroad must be labeled with the name of the country where it was processed or manufactured. Importers and other marketers should check Customs regulations to determine the appropriate country of origin for products made entirely abroad. The determination depends on the type of product and the country or countries where processing or manufacturing occurs. The Textile and Wool Acts don’t define the terms “processing” and “manufacturing.” The terms refer to the steps in the production process relevant to determining an imported product’s country of origin. The Textile and Wool Acts require disclosure of the country where an imported product was processed or manufactured. So it is not sufficient to disclose that a product was made in the European Union, for example, instead of the specific country where it was made.

Unqualified “Made in U.S.A.” labels
A label may say, “Made in U.S.A.” only if the product is made completely in the U.S. of materials that were made in the U.S. If a U.S. manufacturer uses imported greige goods that are dyed, printed and finished in the U.S., for example, they may not be labeled “Made in U.S.A.” without qualification.

NOTE: In determining a product’s country of origin, you don’t have to consider the origin of parts of the product exempt from content disclosure, like such as zippers or buttons.

Products made in the U.S.A. with imported materials
The label must indicate that the product contains imported materials. The label may identify the country of origin of the imported materials, but it doesn’t have to. It can say, “Made in U.S.A. of imported fabric” or “Knitted in U.S.A. of imported yarn.” This disclosure must appear as a single statement, without separating the “Made in U.S.A.” and “imported” references.

Manufacturers should be aware that for certain products. Customs requires identification of the country where the fabric was made. To comply with Customs and FTC requirements for this group of products, the label must identify both the U.S. and the country of origin of the fabric. 

For example: “Made in U.S.A. of fabric made in China” or “Fabric made in China, cut and sewn in U.S.A.”

5 | MATERIAL CONTENT

If your product is covered by the Textile or Wool Act and Rules, it must be labeled to show the fiber content. For products covered by the Textile Act and Rules, the generic fiber names and percentages by weight of each constituent fiber must be listed in descending order of predominance

The disclosure requirement applies only to fibers in yarns, fabrics, clothing and other household items. If part of the product is made from a non-fibrous material — such as plastic, glass, wood, paint, metal or leather — you don’t have to include that on your label. That includes the contents of zippers, buttons, beads, sequins, leather patches, painted designs, or any other parts that are not made from fiber, yarn, or fabric.

5% rule:
In general, you may name only the fibers that comprise 5% or more of the fiber weight. Fibers of less than 5% should be disclosed as “other fiber” or “other fibers” and not by their generic name or fiber trademark.15

Exceptions to the 5% rule:
You must disclose wool or recycled wool by name and percentage weight, even if it is less than 5% of the product.
You may state the name and percentage of a fiber that is less than 5% of the product, if the fiber has a definite functional significance at that amount. For example, if a small amount of spandex is used for elasticity, the label could say:

Exemption Example:
         96% Acetate | 4% Spandex

Exceptions to the fiber disclosure requirement
Some parts of a textile or wool product don’t have to be counted for labeling purposes even if they are made of a fibrous material. These include trim, linings (unless used for warmth), small amounts of ornamentation and the threads that hold the garment together, although the label may need to disclose that the stated fiber content is exclusive of decoration or ornamentation.

Trimmings
Various forms of trim incorporated into 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 and superimposed hosiery garters.

6 | GARMENT SIZING

Although sizing is not mentioned as being a requirement, for the consumers, it is a good practice to include when creating your design. Some manufacturers use a small sized  woaven label sewn with the side seam to help private label brands keep their inventory stay better managed when sending out for decoration or even wash.

Below are 2 ways to set up your sizing style.

One size per set up cost -  Large Quantities
When setting up your print production as a Screen printer, the best way to keep your presses going it to set up each print without a need for additional changes. This method allows printers the opportunity set up each size on it’s own print head. Once the print is done, the screen can be pulled and set up for the next size in less than 60 seconds. 

All sizes per 1 set up cost -  Low Quantities
Unlike (A), all of the sizes are added to the art work and during production, the size label is changed using top and bottom tape applications which can also be finished in a fast manner, however, finger tips get ink on them and the margin of damages may increase.

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7 | COLOR GUIDE TIPS

When producing printed neck labels, creating a standard ink color will help during productions that have many colored garment. Because of this, by default, PMS 428C is the color of choice for most screen printers when producing your neck label prints. 

Review these options to consider a more colorful contrast for your printed neck label production.