How do you know if it is really organic cotton or not? I recently had a commenter on my other blog who was upset after ordering an “organic cotton crib set” only to realize the bumper was filled with polyester fiber. Was this false advertising or labeling?
The Textile Products Identification Act, enforced by the Federal Trade Commission (FTC), governs the labeling of fibers, yarns, fabrics, and the clothes and household items made from them. It regulates what manufacturers must include on labels and written advertisements. But what is and what isn’t required may be misleading to some.
Knowing the requirements of the Textile Products Identification Act may help you as a consumer to better understand labels and the fiber content of the products you buy. Here we will focus on the rules for cotton.
Content Label Rules:
- Just because it says 100% Organic Cotton doesn’t mean the cute ribbon and lace trim are also organic or cotton. The content label must list each fiber that equals 5 percent or more of the products weight, for example 55% Hemp, 45% Cotton. Content labels do not have to disclose the fiber content of trim, decoration, or ornamentation. The label may or may not say “exclusive of the trim”, “exclusive of decoration”, or “exclusive of ornamentation”.
- Rest assured though that if it says 100% Organic Cotton, it is according to the labeling rules. Manufacturers are NOT allowed to label a 50% Organic Cotton, 50% Cotton blend as 100% Organic Cotton. If the product contains more than one kind of cotton, a claim the product is made of only one type of cotton is not acceptable. It could however say “All Cotton” or “100% Cotton”. But if the manufacturer wants to call out one specific type of cotton, like Organic or Pima, then they have to list all the types of cotton on the label.
Here is where my blog reader got tripped up. The rules are different for written advertisements, including hang tags and website descriptions. They only have to disclose the fiber content following the content label rules if they choose to. Ads don’t have to mention a product’s fiber content. However, if it does, it must follow the content label rules listing each fiber in order of predominance by weight. Also manufacturers are not intentionaly supposed to mislead customers. Mentions of fiber content in an ad must not be false, deceptive or misleading.
A requirement to include in written advertisements or fabric content labels the filling in a crib bumper would be excluded under an exemption clause. The exemption means the labeling and advertising rules don’t apply to filling or padding used primarily for structural purposes and not for warmth. For example the filling of a quilt would be required on a label because it is for warmth, but the filling of a crib bumper does not have to be disclosed on the content label because it is structural.
Law Labels are different then content labels. A Law Label is the one you see on your mattress that says “Do Not Remove Under Penalty of Law”. The purpose of the law label is to inform consumers what the hidden filling materials are in bedding and furniture products. The crib set customer only found out her crib bumper wasn’t 100% Organic Cotton as she thought when she saw the law label stating the filling was 100% polyester. Law Label requirements vary by product and vary state by state.
As for the advertising of the crib bumper, the website description stated it was “100% Cotton” and later described it as “High-quality supersoft woven organic cotton”. Apparently the description was only describing the cover of the bumper. It did not mention the type of fiber filling at all. It was not until the customer had it in her hands that she could read the law label to learn it was 100% polyester. The manufacturer followed the rules, but do you think they were right not to disclose the filling content in the product description?
Ultimately between the content labels and law labels the Federal Trade Commission covers all the bases when it comes to disclosing fiber content to consumers, except with the advent of internet shopping consumers often are not able to see the information in those labels until they order and receive the item. The bottom line is you can’t make a fully informed buy decision without knowing what the content and law labels say. If in doubt I recommend calling the retailer and asking what the labels say. Never assume that the fiber or filling content has been disclosed to you in a website product description or advertisement, because manufacturers are not required to do so.