Guide to Meeting the US Care Labelling 16 CFR 423 Requirements
Care label regulation requires manufacturers and importers of textile apparel and certain goods to provide regular care instructions through care labels at the time such products are sold. Care labelling is a benchmark of quality. It is also an integral step in the total manufacturing process and must be considered as a part of the overall value of the finished product. Proper care instruction will extend the useful life of a product, thereby assuring better overall customer satisfaction.
A care label is a permanent label or tag detailing the product’s regular care information and instructions. The care label is attached or affixed in such a manner that it will not become separated from the product and will remain legible during the useful life of the product. Care instruction refers to a series of directions that describe practices which should refurbish a product without adverse effects and warn against any part of the directions, which one could reasonably be expected to use, that may harm the item.
Products Requiring a Care Label
- Textile Apparel – finished textile garment or clothing customarily used to cover or protect any part of the body, including hosiery, excluding footwear, gloves, hats or other articles used exclusively to cover or protect the head or hands
- Certain piece goods
Excluded:
- Handkerchiefs, belts, suspenders, and neckties because they do not cover or protect the body
- Non-woven garments made for one-time use because they do not require ordinary care
- Piece goods: items less than 5 inches wide and manufacturer remnants up to 10 yards with unknown fibre content
- Products sold to institutional buyers for commercial use. Example, uniforms sold to employers for employee use in job-related activities but not purchased by the employees.
- Garments custom-made of material provided by the consumer
Care Label Requirements
Businesses must:
- Provide instructions for regular care for the garment
- Ensure that care labelling instructions, if followed, will cause no substantial harm to the product
- Warn consumers about certain procedures that they may assume to be consistent with the instructions on the label but that would harm the product. Example, if a pair of pants is labelled for washing, consumers may assume they can iron them. If the pants would be harmed by ironing, the label should read, “Do not iron.”
Labelling mechanics:
The care label must be permanently attached for the useful life of the garment, except following cases where a temporary label is allowed:
- Totally reversible clothing without pockets
- Products that may be washed, bleached, dried, ironed, and drycleaned by the harshest procedures available, as long as the instruction, “Wash or dry-clean, any normal method,” appears on a temporary label.
Legible during useful life of garment
- Regulation does not specify font height or type, or label material conspicuous at point of sale
- If a product is packaged, displayed, or folded so that customers cannot see or easily find the label, the care information must also appear on the outside of the package or on a hang tag fastened to the product.
Care instructions must be in English, or care symbols per ASTM D5489-96c.
Care Instructions:
The care label must have washing or dry cleaning instructions.
- Exception garments that cannot be cleaned without being harmed ‘‘Do not wash—do not dry-clean,’’ or ‘‘Cannot be successfully cleaned.’’
- FTC recommends providing washing instructions due to consumer preference
Washing instructions: at a minimum, a care label should include a method of washing and a method of drying
Order of care instructions: not specified in the care labelling rule, but provided in ASTM D5489-96c for care symbols.
- Washing
- Bleaching
- Drying
- Ironing
- Dry-cleaning
Care Label Verification & Care Label Development
- When a garment contains several components, reliable evidence is required that the garment as a whole will not be damaged when cleaned as directed.
- Care instructions must include all components of the product, including non -detachable linings, trim and other details. Any special considerations for such components should be contained in the instruction as a warning, for example, “Remove trim,” or “Close zipper.”
- A detachable component, such as a slip out liner, must be separately labelled when it requires a different care procedure than the main product.
Lab Practice: Tests- Washing & Drycleaning
1. Procedures/Methods
- Colourfastness to washing – AATCC TM 61
- Colourfastness to chlorine and non-chlorine bleach – AATCC TS 001
- Dimensional stability to washing – AATCC TM 135 or TM150 Appearance after laundering – AATCC TM 88B, TM88C and TM124
- Colourfastness to drycleaning – AATCC TM132
- Dimensional stability: Perchloroethylene (PERC) – AATCC TM158
- Skewing – AATCC TM179
- Ironing – AATCC TM133
- Hand laundering – AATCC TS006
- Iron temperature guidance – AATCC TM133
2. Evaluations
- Fabric surface – fuzzing, pilling
- Wrinkles / wrinkle recovery
- Colour change and bleeding
- Staining and cross-staining
- Seam puckering
Frequently Asked Questions
- Is it mandatory to perform testing to confirm the care instruction on the label?
- No, it is not required but the manufacturer should have a reasonable basis, which can be industry expertise or experience for providing the care instructions on the label and it should comply with the lab testing as per the instructions which consumer will follow for cleaning after wearing.
- Is the use of ISO (Ginetex) symbols allowed?
- No. Only the care symbols specified in ASTM D5489-96c standard can be used.
- Is there a specific order for care instructions?
- The care labelling rule does not specify an order for providing care instructions. However, it would be recommended to have them organized logically based on consumer use. Care symbols on the other hand are required in specific order, which is specified in the ASTM standard D5489-96c. The order is: Washing, bleaching, drying, and ironing. Additional warnings and information shall be placed after or below the four laundering symbols or in the logical refurbishing sequence of the written instructions.
- When may “Dry-clean only” be used?
- “Dry-clean only” may be used when the garment can be safely dry cleaned by the normal process, using any dry cleaning solvent. The instruction indicates that the garment can’t be safely washed. When “Dry clean only” is used, there must be a reasonable basis for both the dry cleaning instruction and the warning against washing.
- Home textiles like bed sheets and towels are not covered by 16 CFR 423. However, if the manufacturer provides care instructions what is the requirement for such cases?
- Evaluation: claim or per 16 CFR 423 (client required)
- If evaluated as claimed: The Care Labelling Rule is not triggered merely because the company volunteers care instructions on sheets, towels, blankets, or other non-clothing products. The instructions must not be deceptive, and the company should have a reasonable basis.
Cotecna Care Label Testing and Verification (Consumer Products-Softlines Testing)
Cotecna Inspection can provide care label testing services according to the requirements of various countries. Our services guide apparel companies in various countries to properly label care labels and ensure that consumers and clothing caregivers can better understand the care instructions.
To learn more about care label testing and verification or to get a free quote, please contact us.