Federal Trade Commission

Bureau of Consumer Protection

Office of Consumer & Business Education

1-877-FTC-HELP www.ftc.gov

July 1999 1 2

Facts

for Business

Calling It Cotton:

Labeling &

Advertising Cotton

Products

I

f you advertise or sell clothing or household items containing cotton, the product

labels must accurately reflect the fabric

content. So say the Textile Act and Rules,

which are enforced by the Federal Trade

Commission. The Textile Act and Rules

cover fibers, yarns, and fabrics, and household textile products made from them, such

as clothing and accessories, draperies, floor

coverings, furnishings, and beddings.

The FTC has prepared this brochure to tell

you what information must be included on

labels and in written advertisements if you

want to mention the presence of specific

kinds of cotton in textile products.

Labels

Any product covered by the Textile Act and

Rules must include a fiber content statement.

● The fiber content statement must list the

generic name of each fiber that equals 5

percent or more of the products weight,

in order of predominance, and the

percentage of the products weight

represented by each fiber. For example,

85% Cotton, 15% Polyester. Fibers

that are less than 5% of the weight

should be listed as other fiber[s].

However, if the fiber has a functional

significance, even in small amounts, it

may be listed by name. For example:

96% Cotton, 4% Spandex. A product

should not be labeled 100% Cotton

unless it contains only cotton (exclusive

of trim). For more information about

textile labeling requirements, see the

FTC business guide, Threading Your

Way Through the Labeling Requirements Under the Textile and Wool

Acts.

● The fiber content statement may include

the name of a type of cotton, cotton

trademark, or a term that implies the

presence of a type of cotton, as long as

its not deceptive. If you use a cotton

name, trademark, or other term that

implies the presence of a type of cotton,

the generic fiber name cotton must be

used with it. For instance, 100% Sea

Island Cotton, 50% Pima Cotton,

50% Upland Cotton, 85% Egyptian

Cotton, 15% Silk.

● You must use type of the same size and

conspicuousness for the required fiber

content information. The type must be

reasonably easy to read. For example,

50% EGYPTIAN COTTON, 50%

OTHER COTTON is permissible;

50% EGYPTIAN COTTON, 50%

other cotton is not.

● If your product contains more than one

kind of cotton, the fiber content statement doesnt have to specify the name

and percentage of each cotton type. For

example, the product may be labeled

All Cotton or 100% Cotton. However, if the label of a product made

from various kinds of cotton names a

cotton type, it must also give the

cottons percentage by weight and must

make clear that other types of cotton

were also used to make the product. For
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instance, a sheet that contains 65% Pima

Cotton and 35% Upland Cotton may be

labeled 100% Cotton, 100% Cotton

(65% Pima Cotton), 65% Pima

Cotton, 35% Upland Cotton, or 65%

Pima Cotton, 35% Other Cotton.

● If your product contains more than one

kind of cotton, a content statement that

claims the product is made of only one

type of cotton is not acceptable. For

example, when a sheet contains 50%

Egyptian Cotton and 50% Upland

Cotton, a fiber content label that reads,

100% Egyptian Cotton, is unacceptable.

● A fiber trademark or other term must

not be used to imply the presence of a

fiber that is not actually present in the

product. For example, a trademark such

as Pimalux (a fictitious trademark)

couldnt be used if the textile product

didnt contain pima cotton.

● Also, a trademark or other term that

implies that a product is wholly made of

one kind of cotton may not be used

when the product is made of more than

one kind of cotton, or when it contains

fibers other than cotton. For example,

Pimalux Towel  100% Cotton

would not be an acceptable disclosure

for a product made of 50% Pima Cotton, 50% Upland Cotton because the

statement may falsely imply that all of

the cotton in the towel is pima cotton.

An acceptable fiber content statement

would be Pimalux Towel  50% Pima

Cotton, 50% Upland Cotton.

● Towel manufacturers may wish to

distinguish between the fiber of the

loops and the fiber of the ground, if the

loops are made of a premium cotton

such as Pima. A label saying 100%

Cotton, 100% Pima Cotton Loops or

100% Cotton, Pima Cotton Loops is

acceptable  assuming that the towel is

made of 100% cotton and the loops are

made entirely of Pima cotton. A label

saying 100% Pima Cotton or simply

Pima cotton would not be acceptable

if only the loops were Pima and the

ground consisted of another kind of

cotton.

If the loops and the ground of a towel

are not the same generic fiber, the label

must take into account the fiber weight

of each. For example, if the loops are

cotton and the ground is polyester and

each comprises 50% of the weight, the

label could say: 50% Cotton, 50%

Polyester. If the manufacturer wishes

to show the fiber of the loops separately, however, the label should disclose: 100% Cotton loops, 100%

Polyester ground (loops 50% of fabric,

ground 50%).

● A label reflecting only the content of the

pile or the back is not acceptable. For

example, when towel loops are 100%

Pima Cotton, and the base fabric is

100% Upland Cotton, a label that says

only 100% Pima Cotton or 100%

Pima Cotton Loops is unacceptable.

● Any reference to a type of cotton that

appears other than as a part of the

required fiber content statement, even if

it appears on the same label, is nonrequired information. Such information

must: (a) be separate from the required

information; (b) not interfere with,

minimize, detract from, or conflict with

the required information; and (c) not be

false or deceptive as to fiber content.

For example, if the required fiber

content statement says 70% Pima

Cotton, 30% Upland Cotton, the nonrequired phrase Pimalux Towel must

be separate from the fiber content

statement, and must not interfere or

detract from it, or be false or deceptive.

● If non-required information includes the

word cotton, the name of a type of

cotton, a cotton trademark, or other

term implying the presence of a type of

cotton, the required fiber content information must be repeated the first time

the word cotton, the name of a type

of cotton, the cotton trademark, or the

term implying the presence of a type of

cotton appears in the non-required

information. For example, if the required information says 70% Pima

Cotton, 30% Upland Cotton and you

want to attach a hangtag to the product

containing the non-required information

Pimalux Towel, then the hangtag

must read: Pimalux Towel (70% Pima

Cotton, 30% Upland Cotton) the first

time Pimalux appears on the hangtag.

Or if the required fiber content statement says 50% Pima Cotton, 50%
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Upland Cotton, and you want to attach

a hangtag to the product containing the

non-required information Fine Pima

Blend Fabric, then the hangtag must

read: Fine Pima Blend Fabric (50%

Pima Cotton, 50% Upland Cotton) the

first time Pima appears on the

hangtag.

Written Advertisements

● An ad doesnt have to mention a

products fiber content or include the

name of a particular kind of cotton,

cotton trademark, or other term implying the presence of a type of cotton.

However, if it does, it also must include

the required fiber content information

with fibers listed in order of predominance by weight. But the percentages of

fibers dont have to be included. For

example: Fine Pima Blend Fabric

(Pima Cotton, Upland Cotton) is

permissible in an ad for a product

whose label reads 90% Pima Cotton,

10% Upland Cotton, and Pimalux

Towel (Pima Cotton, Upland Cotton) is

permissible in an ad for a towel whose

label reads 70% Pima Cotton, 30%

Upland Cotton. All required fiber

information must appear together in the

ad in type of the same size and conspicuousness  one thats reasonably

easy to read.

● Any reference in an ad to fiber content,

including the name of a particular kind

of cotton, a cotton trademark, or other

term implying the presence of a type of

cotton, must not be false, deceptive, or

misleading as to fiber content.

● If your ad uses the name of a particular

type of cotton, a cotton trademark, or

other term implying the presence of a

type of cotton, the cotton name, trademark, or other term should also be

included on the products content label.

For More Information

For inquiries or to get a copy of the Textile

Act or Rules, and the FTC business guide

Threading Your Way Through the Labeling

Requirements Under the Textile and Wool

Acts, contact: Consumer Response Center,

Federal Trade Commission, Washington,

DC 20580; toll-free: 1-877-FTC-HELP

(382-4357); TDD: 202-326-2502. Or visit

the FTC at www.ftc.gov.

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