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Summary of Country of Origin Labeling Requirements

This guidance is based on Threading Your Way Through the Labeling Requirement Under the Textile and Wool Acts, a publication of the U.S. Federal Trade Commission.

In General

Products covered by the Textile Act and the Wool Act must be labeled to show the country of origin.

Imported products must identify the country where they were processed or manufactured.
Products made entirely in the U.S. of materials also made in the U.S. must be labeled “Made in U.S.A.” or with an equivalent phrase.
Products made in the U.S. of imported materials must be labeled to show the processing or manufacturing that takes place in the United States, as well as the imported component.
Products manufactured in part in the U.S. and in part abroad must identify both aspects.

Imported products made entirely abroad

A textile product made entirely abroad must be labeled with the name of the country where it was processed or manufactured. Importers and other marketers should check Customs regulations to determine the appropriate country of origin for products made entirely abroad.

Unqualified “Made in U.S.A.” labels

A label may say “Made in U.S.A.” only if the product is made completely in the U.S. of materials that were made in the U.S. If a U.S. manufacturer uses imported greige goods that are dyed, printed, and finished in the U.S., for example, they may not be labeled “Made in U.S.A.” without qualification.

Note: The origin of parts of the product exempt from content disclosure (such as zippers, buttons, etc.) does not have to be considered in determining the product’s country of origin.

Products made in the U.S.A. with imported materials

The label must indicate that the product contains imported materials. The label may identify the country of origin of the imported materials, but it doesn’t have to. It can say simply: “Made in U.S.A. of imported fabric” or “Knitted in U.S.A. of imported yarn.” This disclosure must appear as a single statement, without separating the “Made in U.S.A.” and “imported” references. Manufacturers should be aware that for certain products — including sheets, towels, comforters, handkerchiefs, scarfs, napkins, and other “flat” goods — Customs requires identification of the country where the fabric was made.37 To comply with Customs and FTC requirements for this group of products, the label must identify both the U.S. and the country of origin of the fabric. For example: “Made in U.S.A. of fabric made in China” or “Fabric made in China, cut and sewn in U.S.A.”

One step removed rule

In deciding whether to mark a product as made, in whole or in part, in the U.S., a manufacturer must consider only the origin of materials that are one step removed from the particular manufacturing process. For example, a yarn manufacturer must identify imported fiber. A manufacturer of knitted garments must identify imported yarn. A manufacturer of apparel made from cloth must identify imported fabric.

Mechanics of Labeling

The country of origin must always be on the front side of the label.

Other non-required information also may appear on the label with the required disclosures. This additional information cannot be deceptive or misleading and cannot minimize, detract from, or conflict with the required information.

In a garment with a neck, a label disclosing the country of origin (on the front) must be attached to the inside center of the neck.

On garments without a neck, and on other kinds of textile products, the required information must appear on a conspicuous and readily accessible label(s) on the inside or outside of the product.

Label placement and attachment

The label(s) with required information must be securely attached to the product until it is delivered to the consumer. Customs may require that the country of origin of imported goods be on a sewn-in label.