A lab test says our tee is 57% cotton, but the label says 60%. Is that within tolerance?
US textile rules allow a 3 percentage point tolerance for unintended variation, but not for knowingly wrong labels, and none when the label claims a single fibre.
Our label says 60% cotton, 40% polyester. A retailer's test found 57% cotton, 43% polyester. Another style labelled 100% cotton tested at 98% cotton with 2% polyester. Are we in trouble?
Main answer
For the first tee, probably within tolerance; for the second, no. The FTC's guidance on the Textile Rules allows a 3% tolerance for fibre content claims, meaning that if a label states 60% cotton, the actual cotton content may vary from 57% to 63% of the total fibre weight. The tolerance is for unintended variation in manufacturing. It does not allow a business to knowingly print a figure it knows is wrong.
No tolerance for single-fibre claims
The guidance says no tolerance is allowed if the label states that the product contains one fibre, exclusive of permitted ornamentation or decorative trim. A tee labelled 100% cotton that contains 2% polyester in the body fabric is mislabelled, even though 2% is small. Find out where the polyester came from: blended yarn, a heather yarn, a different rib, or contamination.
Check what was tested
Ask the lab which parts were tested. Rib collars and cuffs are trim and are exempt from fibre disclosure, but if the lab cut them in with the body, the result may not reflect the body fabric. Also check the test method and whether results are reported on clean dry weight or another basis.
Find the source of the gap
Ask the mill for the yarn composition certificate and the knitting recipe for the lot. Heather colours often contain different fibres from solids, so a single label for all colours can be wrong for some of them. If the mill changed yarn supplier, the blend ratio may have moved.
What to do
If the result is inside the tolerance and the variation is unintended, keep the report and ask the mill to aim for the stated blend. If it is outside, or a 100% claim is wrong, stop using the incorrect label, correct the label for future production and decide with your adviser what to do with stock already labelled.
Prevent it
Specify fibre content by colour, require a yarn composition document with each fabric lot, and test fibre content on bulk fabric for new fabrics, new mills and heather colours.
Rounding to the nearest whole number is allowed, so 60.4% polyester can be labelled 60%.
Sources and further reading
- FTC — Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts
- eCFR — 16 CFR Part 303, Textile Fiber Products Identification Act rules
Standards and rules are summarised from their published scope or official guidance. Use the current edition and confirm requirements for your market.
Three perspectives on this question
Purchasing perspective
I'd ask the mill for yarn composition documents per lot and per colour, especially for heathers.
Merchandising perspective
A 100% cotton claim is one customers rely on. If we can't guarantee it, we should change the claim.
QC perspective
We'd check which parts the lab tested and retest body fabric only if collars and cuffs were included.
Working on a similar program?Send your tech pack, fabric references and test requirements. We reply with a quote and the questions we need answered.
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