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The Federal Trade Commission (FTC) has published a guide providing instruction on the rules that govern the labeling of products, including footwear, when it comes to leather content.  There is no general requirement to disclose the content of the materials used in the production of footwear sold in the United States.  However, you must disclose the use of imitation or artificial leather when used in your footwear.  These rules apply to materials used in in the upper, lining, sock and outsole of a pair of shoes.  For those shoes that have multiple materials contained in the upper, you should disclose the predominant material first.

These rules also apply to advertising.  Remember, the FTC’s main objective is the governance of information provided to consumers, so these guides are designed to ensure false information or deceptive practices are not being used to sell products.

So remember:

  • No general requirement to disclose materials
  • Disclose that artificial leather is not leather
  • Rules apply to upper, lining, sock and outsole
  • Multi-material uppers – disclose predominant material first (surface area)
  • Rules apply to advertising

Source Material:

FTC Guides for Select Leather and Imitation Leather Products

FTC Leather Guides Text

For additional information or tailored labeling consulting services, please contact FDRA directly at info@fdra.org.