Wool, ribbon, elastic questions

Beyond the CPSIA many products that are made from fiber or fabrics, regardless of the age of the user, have needed since the early 1970s a FTC care and content label. The FTC is a seprerate govenment agency from the CPSC (the agency that administers the CPSIA) so there are products that will have to follows the laws and regulations from both government offices. There are no exemptions in the FTC based on what an item is made from but there are certain types of finished product like socks that are exempt from having the care & content on the product. Wool based products do have their own special labeling requirements under the FTC even if wool is only a small part of the overall piece. In some cases the "wool law" can overide the labeling exempt status of a product category, example 100% cotton hat is exempt from labeling but a wool & cotton blend hat is not.
FTC main
www.ftc.gov
Clothing, accessories and home furnishings care and content labeling
www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#covered
www.ftc.gov/bcp/edu/pubs/business/textile/bus50.shtm#Complying

For the most part the FTC label must include:
- Your company, shop name, or RN# (an absolute requirement for the FTC labels, but if a FTC label is already on a child's product then no repeat name or RN# is needed for the CPSIA label)
- Fiber content by % (as measured by weight)
- Fiber country of origin for each fiber or fabric used
- Washing and care instructions
Other info may be required depending on the exact fabrics use like registered trademark info for fabrics that are followed by a ® or the internation symbols for care instructions.


There are no exemptions from the CPSIA tracking labels. The exemption list is only about having your components or the final product tested for lead and keeping copies of those test results. If all of your raw components are on the exemption list then you can skip having to get lead testing information to keep on file, but it might be a good idea to keep any packaging from the supplies to help you prove that the item was described and sold as something that falls into the exempt category.
For the current full list of raw materials offically exempt from CPSIA lead testing please read www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-dra...
Currently it has been interpetted that elastic and plain fabric ribbon (no screen printing, no add-ins like glitter or rhinestones, and no metal edging) are exempt from lead testing but depending on the type of final product and the age of the targeted user it still may need phthalate testing.

You still need to add a permanant tracking label to the finished products that are tied back to the self-issued GCCs that you keep on file. The government can request to see your GCCs at anytime even if there is never a report to investigate about a product of yours. Additionally if you decide to wholesell or send items to consignment the retailer will need copies of the GCCs for each product or production run of items to keep in their files.
Tracking labels required on every product for children under 13
www.cpsc.gov/about/cpsia/sect103policy.pdf

For a crafter the CPSIA tracking label must include at minimum :
* Your company' brand, shop name, or RN# (not required on the label if able to find it elsewhere permanantly on the product like on a FTC care and content label)
* The city, state/territory, & country where the item was completed
* If different from where made an address or website so a consumer can contact the manufacturer / designer (DO NOT include a phone number unless you want anyone that sees your label to call you at anytime)
* At least the month with year of manufacture or date of completion of the product (still waiting to hear if the CPSIA committee will allow micro businesses that can otherwise easily identify when their products were made to just include season & year)
* If you make repeats of the designs then you may also need a batch number, but only if the pieces are mostly identical looking and made of the same looking raw materials as each other.

Posted at 1:22pm Aug 14, 2010 EDT

Wow really complicated.....

Posted at 1:38pm Aug 14, 2010 EDT

Yes it is, when you say "Fiber country of origin for each fiber or fabric used" for the FTC label, what does that mean? The yarn manufacturer location or the location of wherever their raw materials come from or my country?

Posted at 1:56pm Aug 14, 2010 EDT

I'm pretty sure it means where the fibers for the yarn were manufactured, harvested, or sheared in. It's not uncommon for the base materials used in the yarn to be gather or made in 1 country then be spun into the yarn in another. Fiber arts are not one of my strong points you may want to check with your supplier to see what info they may have. If it's national chain the average salesperson may have no clue so you could also check with your local SCORE or SBA office to see if they have a definative answer.
Regardless of if I'm right or wrong that information should be right on the band for skein of yarn.

Posted at 3:27pm Aug 14, 2010 EDT

Re: the country of origin. My understanding is as follows...
There is a "once removed" rule applied, meaning that the yarn maker must identify the source country of origin for the fiber used in making the yarn. The user of the yarn is only required to state the source country of the yarn manufacture, not of the fiber used to make the yarn.

I'm not on my home computer, so can't quote the source but I think it is in the FTC documents somewhere.

Posted at 9:07pm Aug 15, 2010 EDT

Found it!
"One step removed rule

In deciding whether to mark a product as made, in whole or in part, in the U.S., a manufacturer must consider only the origin of materials that are one step removed from the particular manufacturing process. For example, a yarn manufacturer must identify imported fiber. A manufacturer of knitted garments must identify imported yarn. A manufacturer of apparel made from cloth must identify imported fabric."

Source: www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm#removed (See table of contents for
"Country of Origin", then next to last sub-section.)

Posted at 9:12pm Aug 15, 2010 EDT

Kisses, kisses knitwit.. I knew someone would find it.

So you don't have to run down the sheep that your yarn came from and followed it thru the chain.Good lordy, many people can't follow the chain of birth of their own ancestry, much less a sheep, llama and and alpaca.!!!!Next you kniow we will have to have DNA registry on our sweaters from Walmart!!!!

Posted at 10:30pm Aug 15, 2010 EDT

Yes, Faye, I was pleased when I found that reference originally, as I had been asking the same question. Much yarn is "made in U.S.A. from imported fibers", so I was trying to decide what I needed to call it when I created something.

Guess my memory still works...

Posted at 7:13am Aug 16, 2010 EDT

That is great info! Thank you. So in my situation, since I live in Canada, I'm a little confused as how to label. How would I label the following finished products (hats):

1. Hat made with yarn that is labelled Made in Canada?

2. Hat made with yarn that is labelled Made in USA?

3. Hat made with yarn that is labelled Made in Turkey but is sold and labelled by Lion Brand (New York, USA)?

Posted at 8:29am Aug 16, 2010 EDT