Dry clean

50% Cashmere

50% Wool

FTC FACTSfor Business

BUSINESS

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FEDERAL TRADE COMMISSION FOR THE CONwww.ftc.gov

The Cachet of Cashmere: 

Cashmere.

The word evokes images of luxury, warmth and softness. The ultra-fine wool, 

from the undercoat of the Cashmere (or Kashmir) goat, is indeed a premium 

fiber — one that generally commands a much higher price than sheep’s wool.

If you manufacture or sell clothing or household items that contain any wool, 

including specialty wools like cashmere, camel hair, mohair, alpaca, llama, or 

vicuna, you must comply with the Wool Products Labeling Act. That means 

your product labels must accurately reflect the items’ fiber content, the country 

of origin, and the name of the man u fac tur er or marketer. Ap par el items also 

must be labeled to show a safe cleaning method.

Complying with the Wool 

Products Labeling Act

70% Cashmere

30% Silk
Facts for Business

Fiber Content Disclosure

Product labels must reflect 

the true fiber content of the 

item. For example, if 

a sweater is made 

of wool, it can be 

labeled as 100% 

Wool, assuming 

it contains only 

wool. Likewise, 

if a sweater is 

made only of cashmere, it can be labeled as 

100% Cashmere. Cashmere is a type of wool 

and also can be labeled as wool. If a sweater 

contains cashmere mixed with sheep’s wool, 

and the label refers to cashmere, the label must 

accurately disclose the content, e.g., 80% 

Wool, 20% Cashmere. It would be illegal to 

say simply Cashmere or Cashmere blend; the 

percentages must be stated. There is only one 

exception to the requirement that percentages 

be stated: the word All can be used in place of 

100% if the product is made of only one fiber, 

e.g., All Wool or All Cashmere.

If a claim about the fiber content appears 

elsewhere on the garment, such as on a hangtag 

or a sleeve label, it must mirror the garment’s 

fiber content label. For example, a coat labeled 

50% Cashmere, 

50% Wool cannot 

have a hangtag 

or a sleeve label 

stating merely 

FINE CASHMERE 

GARMENT or FINE CASH MERE BLEND. In 

this instance, the hangtag or sleeve label also 

must say 50% Cashmere, 50% Wool — in 

equally conspicuous lettering.

The Textile Act allows a three percent tolerance 

for fiber content claims, but the Wool Products 

Labeling Act doesn’t. However, the Wool Act 

says that deviation from the stated fiber content 

is not considered mislabeling if it results from 

“unavoidable variations” in the man u fac tur ing 

process that occur despite the exercise of 

due care. For this reason, the FTC generally 

will apply the three percent tolerance to wool 

prod ucts. The three percent tolerance does not 

allow for in ten tion al mislabeling. No tol er ance 

is allowed for a 100% claim, as the addition of 

another fiber would always be intentional.

Testing is Important

You’re responsible for label accuracy, even 

if you import, distribute or sell wool products 

man u fac tured by another company. You cannot 

necessarily rely on an invoice statement that the 

goods contain a specified amount of cashmere. 

Routine testing of fiber contents by a qualified, 

in de pen dent testing lab is the best assurance of 

accurate labels.

A trained expert, using an optical or electron 

microscope, can distinguish between cashmere 

fibers and sheep’s wool fibers, fol low ing 

pro ce dures established by the American 

Association of Textile Chemists and Colorists 

(AATCC) or the American Society for Testing 

and Materials (ASTM). The basic distinction is 

not only one of diameter, as some sheep have 

now been bred to produce ultra fine fibers — 

with a diameter comparable to that of cashmere 

fibers. There are significant differences in 

the scale structure of the two fibers, and that 

is what the test expert looks for under the 

microscope.

Guaranty of Compliance

If you buy and resell wool or cashmere 

products, you can ask your U.S. supplier for 

a “guaranty of compliance.” The guaranty is a 

written statement on a product invoice or other 

dated document that states: “We guarantee 

that the wool prod ucts specified herein are not 

misbranded under the provisions of the Wool 

Products Labeling Act and rules and regulations 

thereunder.”

50% Cashmere

50% Wool
Facts for Business

In other words, the supplier guarantees that the 

wool and cashmere products sold to you are 

correctly labeled under the Wool Labeling Act. 

The guaranty must have the name and address 

of the guarantor. A “continuing guaranty,” 

which covers all wool products sold by the 

guarantor, also can be filed with the FTC. 

Filing such a guaranty is an assurance by the 

guarantor that all of its products covered by the 

Wool Act are correctly labeled. A buyer who 

in good faith relies upon a properly executed 

guaranty will not be found in violation of the 

law if the goods are later determined to be 

mislabeled. Note, that good faith means acting 

prudently and not ig nor ing an indication (such 

as price or ap pear ance) that an item may not be 

accurately labeled.

A special note about guaranties and foreign 

companies: A foreign company cannot file a 

continuing guaranty with the FTC. In addition, 

a guaranty from a foreign company is not a 

legal defense if the importer is charged with 

mislabeling products. A U.S. importer is 

legally responsible for the proper labeling of 

imported textile and wool products. Importers 

should test the fiber content of imported goods 

periodically to verify the accuracy of the label.

How Posh is Pashmina?

The popularity of products marketed as 

pashmina — an Indian word for 

cashmere — has skyrocketed 

in recent years; yet 

most consumers 

aren’t sure what 

pashmina is. That’s 

not sur pris ing, as 

pashmina is not a labeling 

term rec og nized by the Wool Act 

and rules. Experts tell the FTC there is no 

pashmina fiber that is separate and distinct from 

the cashmere fiber.

Some manufacturers use the term pashmina to 

describe an ultra fine cashmere fiber; others 

use the term to describe a blend of cash mere 

and silk. The FTC encourages man u fac tur ers 

and sellers of products described as pashmina

to explain to consumers, on a hangtag, for 

ex am ple, what they mean by the term.

As with all other wool products, the fiber 

content of a shawl, scarf or other item marketed 

as pashmina must be accurately disclosed. For 

example, a blend of cashmere and silk might 

be labeled 50% Cashmere, 50% Silk or 70% 

Cash mere, 30% Silk, depending upon the actual 

cashmere and silk content. If the item contains 

only cashmere, it 

should be labeled 

100% Cash mere or 

All Cashmere. The 

label cannot say 

100% Pashmina, 

as pashmina is 

not a fiber recognized by the Wool Act or 

regulations.

Other Requirements

The label must state the country of origin and 

the identity (name or Registered Identification 

Num ber – RN) of the manufacturer or another 

busi ness responsible for marketing the item, 

in ad di tion to the fiber content. For further 

in for ma tion about the labeling of textile and 

wool products, see the FTC booklet Threading 

Your Way Through the Labeling Requirements 

Under the Textile and Wool Acts.

Care Labels

Apparel care labels are required under the 

FTC’s Care Labeling Rule. For information on 

com ply ing with this rule, see Writing a Care 

Label: How to Comply with the Amended Care 

La bel ing Rule.

100% Pashmina
Federal Trade Commission

Bureau of Consumer Protection

Offi ce of Consumer and Business Education

November 2003

Facts for Business

Dry clean only? Many cashmere items are 

labeled Dry Clean Only. If your label says Dry 

Clean Only, you are telling consumers that the 

item can’t be washed safely. To be accurate, 

you must have proof that the garment will be 

harmed by washing.

The truth is that 

many cashmere 

items can be washed 

safely at home. 

A label that says Dry Clean does not warn 

against washing and does not require proof that 

washing would harm the item.

For clothing that may be washed or dry 

cleaned, you must give instructions for at 

least one cleaning method. Of course, you 

may pro vide information about both cleaning 

methods. Con sum ers are telling the FTC that’s 

what they want. Many consumers prefer to 

wash items that can be laun dered at home.

For More Information

If you have further questions about the Textile 

or Wool Acts, visit the FTC website at 

www.ftc.gov on the Web — click on Business 

Guidance, then Textile, Wool, Fur, & 

Apparel Matters.

Or call the Textile Information Line: 

202-326-3553 (contains recorded information 

about textile, wool and RN matters)

For copies of this and other publications, 

con tact: Consumer Response Center, Federal 

Trade Com mis sion, Washington, DC 20580; 

toll-free 1-877-FTC-HELP (382-4357).

For more information about cashmere and 

other specialty wool products, contact:

Cashmere & Camel Hair Manufacturers 

Institute, 230 Congress Street, Boston, MA 

02110-2409; www.cashmere.org

Your Opportunity To Comment

The Small Business and Agriculture Regulatory 

Enforcement Ombudsman and 10 Regional 

Fairness Boards collect comments from 

small business about federal enforcement 

actions. Each year, the Ombudsman evaluates 

enforcement activities and rates each agency’s 

responsiveness to small business. To comment 

on FTC actions, call 1-888-734-3247.

Dry clean only?