Garment labels provide consumers with government-imposed purchasing information. If a company manufactures, imports or sells fur garments or accessories, it must comply with the labeling requirements under the Fur Products Labeling Act (“FPLA”), as imposed by the Federal Trade Commission (“FTC”).
What Needs to be Labeled?
Garments made entirely or partly with fur must have a label disclosing:
Mechanics of Labeling
Enforcement of the Fur Act
Manufacturers, importers, distributors and retail sellers are responsible for complying with fur labeling requirements and may be subject to civil or criminal penalties for selling mislabeled products. A violation of the FPLA or the Commission’s rules under the Act is considered an unfair method of competition and an unfair and deceptive act or practice under the FTC Act. The Commission may issue an administrative order prohibiting conduct that violates the Act. Violators of an administrative order are subject to monetary civil penalties of up to $16,000 per violation. Each instance of mislabeling is considered a separate violation. Criminal proceedings can be brought against willful violators of the FPLA. (FTC).
Sellers may protect themselves from liability under the Act and Rules for selling misbranded fur products by asking their U.S. supplier of fur products for a guaranty of compliance with the FPLA and Fur Rules and relying on the guaranty in good faith. You can satisfy the separate guaranty form’s signature requirement by including the guarantor’s printed name and address. You don’t need to show the shipment date. (FTC).
The FTC will not bring enforcement actions against retailers that:
However, if a retailer knew or should have known the marketing or sale of an item would violate the Fur Act or Rules, those protections won’t apply. (FTC).