Fine and Superfine WoolU.S. RegulationThe Wool Suit Fabric Labeling Fairness and International Standards Conforming Act of 2006 amended the Wool Products Labeling Act of 1939 by incorporating the IWTO Fabric Labelling Code of Practice. A violation of the Wool Products Labeling Act, or the Federal Trade Commission’s (FTC) rules under that act, is considered an unfair method of competition and an unfair and deceptive act or practice under the Federal Trade Commission Act. The FTC Act provides various remedies for these violations. The Commission may issue an administrative order prohibiting the act or practice that violates the FTC Act. Violators of an administrative order are subject to monetary civil penalties of up to $11,000 for each violation. Each instance of mislabeling under the Wool Products Labeling Act is considered a separate violation. Businesses not subject to a previous administrative order also can be subject to monetary civil penalties, an injunction, and other remedies — including consumer redress — in a federal district court action. The Commission can bring a civil penalty case against a company that knowingly engages in practices — such as the mislabeling of textile products — that the Commission has determined in prior cases to be unfair or deceptive. In this kind of case, “knowledge” refers to knowledge of the law. Because the Commission has widely distributed copies of the statutes, rules, and prior decisions in the wool area, many manufacturers and sellers have knowledge of the labeling requirements. Improperly labeled imported items can be held up by Customs and possibly subject to liquidated damages. |