Worked Example: US Care and Content Label for an Imported Blouse
An illustrative US labeling record for a fictional imported cotton blouse, connecting fiber content, country of origin, responsible-business identity, and a substantiated care instruction under the FTC textile and care rules.
Current FTC guidance and eCFR 16 CFR Part 303 (Textile Fiber Products Identification Act) and Part 423 (Care Labeling Rule), plus US Customs country-of-origin marking under 19 U.S.C. 1304, reviewed for a fictional imported 100% cotton woven blouse sold in the United States; no product is labeled, tested, substantiated, marked, or declared compliant.
A compliant US label set for this fictional imported blouse carries four required disclosures: the fiber content ("100% Cotton"), the country of origin ("Made in India"), the identity of the responsible US business (its full business name or its FTC-issued RN number), and a care instruction. Two separate FTC rules apply, the Textile Fiber Products Identification Act for fiber, origin, and identity, and the Care Labeling Rule for care, and US Customs independently requires the origin marking. The care label must be permanent, and the business must hold a reasonable basis for the care instruction before the product is sold. This is an illustrative record, not legal advice or a compliance determination.
Freeze the labeling scenario before developing it
| PRODUCT | Women's woven short-sleeve blouse with a neck; no other market or category implied |
| FIBER | Illustrative 100% cotton woven shell; final article, trims, and any blend open |
| ORIGIN | Cut and sewn in India, imported for United States retail sale |
| SELLER | United States importer that can hold a business name or FTC RN; the Indian maker cannot hold an RN |
| DECISION | Build the label content, placement, permanence, and supporting evidence for qualified review |
Two FTC systems and one Customs requirement apply at once. Fiber content, country of origin, and responsible-business identity fall under the Textile Fiber Products Identification Act, 16 CFR Part 303, summarized in the FTC guide Threading Your Way Through the Labeling Requirements. Care falls under the Care Labeling Rule, 16 CFR Part 423, summarized in Clothes Captioning. Country of origin is also required independently by US Customs under 19 U.S.C. 1304, so the label must satisfy both the FTC and Customs.
This is general information for an illustrative product, not legal advice and not a compliance determination. A qualified product and legal owner must confirm the current eCFR text, the fiber-content basis, the care substantiation, the Customs origin determination, and any category or state rules such as apparel flammability under 16 CFR Part 1610, children's-product rules, or California Proposition 65. If any fact changes, for example a blend instead of 100 percent cotton, a children's size, an added trim, or a different market, the required label changes with it.
The four required disclosures
| Fiber content | Generic fiber names with percentage by weight in order of predominance. For a single fiber you may state "100% Cotton" or "All Cotton." A single-fiber claim has no tolerance, so an intentional 3% added fiber breaks it. Fibers under 5% are listed as "other fiber" unless functional, such as spandex, or wool. |
| Identity | The full name under which the responsible US business trades, or its FTC-issued RN used in place of the name. An RN is optional and is issued only to US businesses, so the Indian manufacturer cannot hold one. |
| Country of origin | The English name of the country of manufacture, here "Made in India." It must appear on the front of a label, and for a garment with a neck it goes at the inside center of the neck, midway between the shoulder seams. |
| Care instruction | One complete washing or drycleaning instruction plus any needed warnings, on a permanent label. The business must hold a reasonable basis for it before sale. Words or the ASTM care symbols the rule incorporates may be used. |
Four errors show up constantly. A "100%" or "All" claim has no tolerance, so a garment with any intentionally added fiber cannot use it. Country of origin must be on the front of a neck label at center back, a placement people miss. An imported garment cannot carry a foreign maker's RN, because RNs are US-only, so the US importer's name or RN is used. And the US care-symbol system is the ASTM set the rule references; the international ISO 3758 and GINETEX symbols are not accepted as a US substitute on their own.
Edit the worked label record
Care and content label decision record
Keep the product, fiber determination, origin determination, responsible-business identity, care instruction and its evidence, label artwork and placement, and release decision traceable to the same configuration.
Edits stay in this browser only and are not sent anywhere. This record does not label, substantiate, mark, or declare compliance for any product.
Product and responsible business
Name the exact product and the business that answers for the label.
Fiber content determination
State fiber by generic name and weight, with the basis for the numbers.
Country of origin determination
Satisfy both the FTC and US Customs, and place the mark correctly.
Care instruction and reasonable basis
The instruction is a substantiated claim, not a default copied from a similar product.
Label artwork, placement, and permanence
One label or several, but the required content, placement, and permanence must all hold.
Release and change control
Authorize a named configuration and define what reopens the label.
Keep the systems, and the agencies, separate
Passing on one axis is not compliance on another. The Textile Act content, the Care Labeling Rule instruction, and the Customs origin marking are three separate obligations, and the first two are enforced by the FTC while the third is enforced by US Customs. A correct fiber statement says nothing about whether the care instruction is substantiated. A care instruction that reads well is still a violation if the business does not hold reliable evidence for it before the product is sold. And a country name that satisfies the FTC label still has to meet the separate Customs marking rule. Treat each as its own decision with its own evidence, then reconcile them on one approved artwork.
For the live program, put the label fields into the tech pack, gather supplier facts with the Material Sourcing Request and Supplier Screening Brief, and record proofs with the Sample Review and Approval Record. For other regulated routes, see the children's sleepwear and EU high-visibility vest worked examples.
Sources and decision boundaries
The content prompts use the FTC's Threading Your Way Through the Labeling Requirements and 16 CFR Part 303. The care prompts use the FTC's Clothes Captioning and 16 CFR Part 423. The origin prompts use US Customs guidance on country-of-origin marking under 19 U.S.C. 1304. These sources support the record structure and dated questions only. Stitch Authority does not label a submitted product, determine fiber or origin, substantiate care, approve artwork, or declare compliance. Verified against these sources on 18 July 2026.
What has to be on a clothing label in the US?
For most apparel, four things: the fiber content by generic name and percentage, the identity of the responsible business as a name or an FTC RN, the country of origin, and a care instruction. Fiber, identity, and origin come under the Textile Fiber Products Identification Act, and care comes under the separate Care Labeling Rule. Imported garments also have to meet US Customs origin marking.
Do I need an RN number?
No. An RN is optional. You may use the full name your business trades under instead. An RN is issued by the FTC only to businesses located in the United States, so a foreign manufacturer cannot hold one; for an imported garment the US importer's name or RN is normally used.
Can I use care symbols instead of words?
Yes. The Care Labeling Rule lets you use the ASTM care-symbol system it incorporates in place of words, as long as the symbols convey the required instruction and warnings. Note that the international ISO 3758 and GINETEX symbols are not accepted as a US substitute on their own, so a product for the US market should use the ASTM set.
Where does the Made in label go on a garment?
The country of origin must appear on the front of a label, and for a garment with a neck it goes at the inside center of the neck, midway between the shoulder seams. It must be conspicuous and legible, and it has to satisfy both the FTC label rule and the separate US Customs marking requirement.
What is a reasonable basis for a care instruction?
It is reliable evidence that the care instruction and its warnings are accurate, which the business must possess before the product is sold. That can be wash or dryclean testing, tests of components tied to the finished garment, or technical literature and industry expertise. A Dryclean Only label, for instance, needs evidence that washing would harm the garment.
Work with a technical designer.
Label content review, care substantiation planning, and tech-pack callouts for teams that need one correct, defensible label set before production.