January 27, 2010 

 

VIA EXPRESS MAIL

[COMPANY NAME] 

ATTN: [NAME], CEO 

[ADDRESS] 

 Re: Unlawful practices relating to textile fiber products 

 

Dear [NAME]: 

 Your company sells or recently has sold textile products that are labeled or advertised as 

“bamboo.” The Federal Trade Commission, which enforces the Textile Act and Rules, recently 

took action against several businesses that sold textiles labeled or advertised as bamboo even 

though the products were made of rayon. Commission staff is concerned that textile products 

your company is or recently has been selling as “bamboo” are made from rayon, as well. I want 

to make you aware of these concerns so that you can take corrective steps to avoid Commission 

action. 

 When your company sells textile products, you must attach a label that describes the type 

of fiber used to make the product. This label must use the fiber name recognized by the FTC 

under its Textile Rules if the fiber is manufactured or use the fiber’s common name if it is natural. 

See 16 C.F.R. §§ 303.6 - 303.7. You also must use these names in advertising when your 

company describes or implies the fiber content of a textile product. See 16 C.F.R. § 303.40. The 

term “bamboo,” therefore, may be used in labeling or advertising a textile product (e.g., “bamboo 

shirt”) only to describe textile fibers taken directly from the bamboo plant without the type of 

chemical processing necessary to make rayon. Rayon, even if manufactured using cellulose from 

bamboo, must be described by an appropriate term recognized under the FTC Textile Rules. If 

rayon is manufactured using bamboo as the cellulose source, then you also may include that 

information in the textile label, for example, by describing the fiber as “rayon made from 

bamboo.” Failing to properly label and advertise textiles misleads consumers and runs afoul of 

both the Textile Rules and the FTC Act. 

 Please review the labeling and advertising for the textile products sold by your company 

and remove or correct any improper “bamboo” labeling or advertising. To assist you in this 

process, I am enclosing a copy of the Commission’s recent Business Alert: How to Avoid 

Bamboozling Your Customers. 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Division of Enforcement 

Bureau of Consumer Protection 
Page 2 

I also am enclosing a synopsis of Commission decisions holding that the failure to 

use proper fiber names in labeling and advertising textile products constitutes a deceptive 

act or practice and violates the FTC Act. With this synopsis, we are putting [COMPANY 

NAME], on notice that the failure to correct improper labeling or advertising of textile 

products could subject the company to civil penalties of up to $16,000 per violation. 

Copies of the decisions discussed in the synopsis are on the Commission’s website at 

www.ftc.gov/bamboo. Other materials on the website further clarify your responsibilities 

under the FTC Act, the Textile Fiber Products Identification Act, 15 U.S.C. § 70 et seq., 

and the Textile Rules issued thereunder, 16 C.F.R. Part 303. 

 In its recent “bamboo” cases, the Commission challenged claims that “bamboo” 

textiles have a variety of environmental benefits, including that they are manufactured 

using an environmentally-friendly process, that they retain inherent antimicrobial 

properties of the bamboo plant, and that they are biodegradable. While the enclosed 

synopsis does not relate to these claims – and our staff has not determined that your 

company is making such claims – you may find our Environmental Marketing Guides, as 

well as our publication, Complying with the Environmental Marketing Guides

(www.ftc.gov/energy) helpful going forward. 

 If you have any questions about this letter or the enclosed materials, please 

contact Korin Ewing at kewing@ftc.gov or at 202-326-3556. 

 

 Sincerely yours, 

 

 James A. Kohm 

 Associate Director 

Enclosures