FTC Seeks Comment on Possible Changes to Wool Labeling Rules

January 30, 2012 by Elizabeth Parker|CPSC and Textiles

The Federal Trade Commission systematically reviews all its rules and guides to ensure that they continue to achieve their intended purpose without unduly burdening commerce. As part of this review, the FTC is requesting public comment by March 26, 2012 on the overall costs, benefits, necessity, and regulatory and economic impact of, and possible modifications to, the Rules and Regulations under the Wool Products Labeling Act of 1939¹. The FTC also seeks comment on how it should modify the rules to implement the Wool Suit Fabric Labeling Fairness and International Standards Conforming Act.

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(The FTC completed its last comprehensive review of the Wool Rules in 1998 and modified the Rules in 1998 and 2000. As a result of the 1998 review, the FTC, among other things, streamlined the labeling requirements and incorporated the definition of "trimmings" set form in the Textile Fiber Products Identification Act. In 2000, it amended the Rules to clarify that the FTC will assign only one registered identification number to a qualified applicant, to clarify the country-of-origin disclosure requirement, and to amend certain provisions of the Textile Act that the Wool Rules incorporate.)

Interested in Improvements, Definition of "Trimmings," Wool Suit Int'l Standards

The FTC seeks comment on whether it should clarify or modify certain Rule provisions

and/or its business and consumer education materials to improve industry and consumer understanding of the Rules. Additionally, the FTC seeks comment on whether it could otherwise improve the Rules. Specifically, FTC states some of the definitions in the Rules may warrant modification, for example for "trimmings" in relation to required fiber content disclosures.

In 2006, the Wool Act was amended by the Wool Suit Fabric Labeling Fairness and International Standards Conforming Act, which declared that specified wool products manufactured on or after January 1, 2007, including cashmere, are misbranded if the average diameter of their fibers does not meet certain standards. The FTC also seeks comment on how it should modify the Wool Rules to implement the Conforming Act.

Seeks Comments on Extent of Industry Compliance, Conflict w/ Other Rules, Etc.

The FTC solicits comments on the following specific questions related to the Wool Rules (partial list, see notice for full list of questions):

What modifications, if any, should be made to the Rules to increase their benefits or reduce their costs to businesses, particularly small businesses? How would these modifications affect the costs and benefits of the Rules for consumers and businesses? Provide any evidence supporting your proposed modifications.

Provide any evidence concerning the degree of industry compliance with the Rules. Does this evidence indicate that the Rules should be modified? If so, why and how? If not, why not?

Provide any evidence concerning whether any of the Rules' provisions are no longer necessary. Explain why these provisions are unnecessary.

What potentially unfair or deceptive practices concerning wool labeling, not covered by the Rules, are occurring in the marketplace?

Do the Rules overlap or conflict with other federal, state, or local laws or rules, such as those enforced by U.S. Customs and Border Protection? Have the Rules assisted in promoting national consistency with respect to wool labeling and advertising? Provide any evidence supporting your position.

Are there foreign or international laws, regulations, or standards with respect to wool labeling or advertising that the FTC should consider as it reviews the Rules? Should the Rules be modified in order to harmonize with these international laws, regulations, or standards? How would such harmonization affect the costs and benefits of the Rules for consumers and businesses, particularly small businesses? Provide any evidence supporting your position.

¹The Wool Products Labeling Act of 1939 (15 USC 68-68j) requires marketers to attach a label to each wool product disclosing: (1) the percentages by weight of the wool, recycled wool, and other fibers accounting for 5% or more of the product, and the aggregate of all other fibers; (2) the maximum percentage of the total weight of the wool product of any nonfibrous matter; (3) the name under which the manufacturer or other responsible company does business or, in lieu thereof, the registered identification number (RN number) of such company; and (4) the name of the country where the wool product was processed or manufactured. It also contains advertising and record-keeping provisions.

(See ITT's Online Archives 11071548 for summary of the FTC's ten-year regulatory review schedule, which intended for the rules and regulations under the Wool Products Labeling Act to be reviewed in 2011.)

FTC Contact -- Robert Frisby (202) 326-2098