Labeling & Marking: Wool

The Wool Products Labeling Act applies to all articles containing any amount of wool, including footwear.  Generally, as applied to footwear, the Wool Act requires the following.

1. Country of Origin (CBP and FTC)

A) Must be permanent, conspicuous and legible.

B) Must be permanently attached.

C) Foreign (or domestic) origin must be disclosed under FTC requirements. CBP requirements reach only foreign merchandise.

D) The country of origin must be disclosed adjacent to any domestic address shown on the garment or its packaging or any phrase from which an implication may be drawn that the garment is produced in a country other than the actual country of origin. (FTC and CBP).  This requirement is applicable where there is the likelihood that the consumer would be deceived or misled as to the origin.

2. Content Labeling (FTC)

General Rule:  The fiber content label, tag or marking must be conspicuously affixed to the product (or where permitted, its package or container) in a secure manner, and be of such durability that it will remain attached to the product through distribution, handling, resale, and until such product is sold to the ultimate consumer.

A. Must be conspicuous (type size, placement) at the point of sale. The label or disclosure need not be permanently affixed; it may be printed on the front or back of the polybag, hangtag, etc.  CBP frequently will insist that permanent attachment is necessary, but will acquiesce in an FTC ruling to the contrary.

B. Fiber content may be placed on reverse side of a label when both sides are readily accessible.  If footwear is packaged, content must also be on package, otherwise content would not be accessible at point of sale.

C. There is no de mimimis exception: all quantities must be disclosed, even quantities of less than five percent.

3. Brand/RN/WPL Identification (FTC)

A. All items must have either a house mark[1] registered with the FTC or an RN number permanently affixed to the garment. RN numbers are issued by the FTC.  This item may be on the reverse side of a label when both sides of the label are accessible at point of sale.[2]  Companies to whom a WPL number has been issued may continue to use them for all purposes.  The prefix RN or WPL is part of the identification number and must appear on the label.


[1]       The FTC does not allow more than a single house mark per firm.  A firm that uses multiple marks will be required to obtain and use the RN identification.

[2]       Note that a phrase referring to text on the reverse side of label is no longer necessary.