US Apparel Labelling and Import Requirements

The United States separates two things that buyers often merge: what the label must say, which the Federal Trade Commission enforces, and what happens when the goods arrive, which US Customs and Border Protection controls. They have different rules, different responsible parties and different consequences. This guide takes them in that order.

Part one: the label

Under the Textile Fiber Products Identification Act and the FTC's rules, most textile and wool products must carry a label with three pieces of information: the fibre content, the country of origin, and the identity of the manufacturer or the business responsible for marketing or handling the product. A separate rule requires care instructions.

Fibre content

• List the generic name of each fibre making up 5 percent or more of the product's weight, in order of predominance, with its percentage.
• Fibres below 5 percent are generally grouped as other fiber, unless the fibre has a definite functional significance, in which case it may be named with its function disclosed.
• Certain components are excluded from the calculation, including trim, linings that are not used for warmth, small amounts of ornamentation and the threads holding the garment together. The label may need to state that the fibre content is exclusive of decoration.
• Use the generic fibre names the rules recognise. Marketing names do not substitute for them, and the declared content must match the fabric actually used, which is worth verifying by laboratory test as described in the quality control guide.

Country of origin

Imported garments must be marked with the country where they were made. For a garment with a neck, the origin must appear on the inside centre of the neck, midway between the shoulder seams. Where a garment has no neck, it must appear in another conspicuous and readily accessible position. This is a placement rule as much as a content rule, and it is a common reason a first shipment is questioned.

Who is identified on the label

The label must carry either the full company name of the business responsible for the product, or a registered identification number issued by the FTC. Registered identification numbers, known as RN numbers, are issued only to businesses in the United States, so a Turkish or other non-US factory cannot hold one. In practice, the US importer or brand appears on the label, using its own name or its own RN.

Care instructions

The FTC's Care Labeling Rule requires manufacturers and importers to attach care instructions to garments. In outline, the label must be permanently attached and legible for the useful life of the garment, must provide regular care instructions covering the appropriate method, and must include warnings where a normal care procedure would harm the product. There must be a reasonable basis for the instructions given, meaning evidence rather than assumption. How that evidence is produced for a finished garment is covered in how care instructions are determined.

This is a clear difference from the European Union, where care labelling is voluntary at EU level. If you sell in both markets, design the label set for both from the start, as covered in the labels and packaging guide.

The FTC publishes plain-language guidance for businesses, including its guide to labelling under the Textile and Wool Acts, on the FTC apparel labelling pages.

Part two: the border

At import, responsibility sits with the importer of record. That party is accountable for correct classification, valuation, duty payment and for the legality of the goods, regardless of what the factory told them.

Low-value shipments no longer offer a shortcut. Duty-free de minimis treatment for shipments valued at or below 800 US dollars was suspended for all countries with effect from 29 August 2025, so low-value consignments are subject to applicable duties, taxes and fees. CBP publishes a fact sheet on the suspension.

Forced labour due diligence

Under the Uyghur Forced Labor Prevention Act, CBP applies a rebuttable presumption that goods mined, produced or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or by entities on the UFLPA Entity List, are prohibited from entry. Cotton is one of the sectors where enforcement is most active.

CBP states that it is the importer's responsibility to know its supply chain. In practice that means being able to trace the cotton or other inputs back through fabric, yarn and raw material with ordinary business records: purchase orders, invoices, production records, transport documents and proof of payment. This obligation applies wherever the garment was sewn, so it is not resolved simply by choosing a country of assembly outside China.

Ask any supplier, before the first order, where the yarn and fabric originate and what documentation can be provided. CBP's operational guidance for importers describes the documentation typically expected.

State-level and product-specific rules

Federal labelling rules are not the whole picture. Individual states impose additional requirements, for example California's Proposition 65 warning obligations for certain substances, and some product categories such as children's sleepwear carry their own safety requirements. Confirm what applies to your specific product and where you will sell it, rather than assuming a federal-only checklist is sufficient.

A practical checklist for a US private label programme

1. 1Confirm the exact fibre composition of the fabric used, and verify it by laboratory test where the programme justifies it.
2. 2Draft the fibre content statement using generic names and percentages in order of predominance, with the 5 percent rule applied.
3. 3Confirm the country of origin and specify its placement, including the inside centre of the neck for garments with a neck.
4. 4Decide whose name or RN number appears on the label, and register for an RN if you are the responsible US business and do not have one.
5. 5Develop care instructions with a reasonable basis, ideally supported by wash testing, and specify a permanent label.
6. 6Appoint a customs broker and confirm classification of every style before shipment.
7. 7Check the current duty rate for those classifications close to your shipping date.
8. 8Arrange a customs bond appropriate to your import volume.
9. 9Collect and retain supply-chain documentation for fibre origin.
10. 10Check state-level and category-specific requirements for your product.

Voyager Textile produces label sets to the customer's specification and prepares the export documentation international shipments require. Confirming that the label content and the import classification are correct for the United States remains the importer's or brand's responsibility, which is why the specification should be agreed before production rather than at packing.