Fabric from one country, sewn in China. What does the US origin label say?

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Flat illustration of a care label with laundry symbols, a shield with a check mark and a hang tag

Fabric from one country, sewn in China. What does the US origin label say?

US textile labelling rules require the country where the product was processed or made, and the rules describe how to disclose imported materials. Check the regulation.

Labels, Packaging & ComplianceKnitwear Talk3 min readKnitwear Base Editorial Team
Flat illustration of a care label with laundry symbols, a shield with a check mark and a hang tag
Buyer question

We are importing knit tees sewn in China, but the fabric comes from another country. Our label just says Made in China. Is that enough for the US market, or do we need to mention the fabric?

Main answer
Knitwear Base Editorial Team
Main answer

In the United States, origin labelling for textile apparel falls under the Textile Fiber Products Identification Act and the FTC rules in 16 CFR Part 303. For imported products, the label must show the country where the product was processed or manufactured. The rules also set out how origin is disclosed when a product is made in one place from materials made elsewhere. The customs authority has its own origin rules for import purposes, and the two should agree on the label.

Read the FTC rules, not only a template

Look at the country-of-origin section of 16 CFR Part 303 on eCFR, which explains requirements for imported textile products and for products made in the US from imported materials. The FTC business guidance on textile labelling adds examples. The 2014 amendments to the Textile Rules, published in the Federal Register, updated several labelling provisions, so older checklists may be out of date.

Keep records that support the label

Whatever the label says, you need documents showing where the fabric was knitted, dyed and finished, and where cutting and sewing took place. Ask the factory for fabric purchase records and production records for each order, not only a certificate. If the fabric mill changes, the origin facts may change too.

Check customs origin separately

For customs purposes, the origin of textile and apparel products is set by 19 CFR 102.21, which applies a sequence of rules; for many sewn knit garments the result points to the country where the garment was wholly assembled, but check the rule for your product. CBP's guidance on marking of country of origin also notes that when materials come from one country and assembly happens in another, an importer may request a binding ruling under 19 CFR Part 177. Do not assume the FTC label wording and the customs determination work the same way.

Put the agreed origin wording into the label artwork approval, so it is reviewed each time the fabric source or sewing location changes.

Also check whether any retailer you sell through has its own labelling or origin documentation requirements. Large retailers often ask for origin declarations and supporting documents in their vendor manuals, and they may audit them. Agreeing one set of records with the factory at the start of the order is much easier than reconstructing them after a retailer or customs officer asks questions.

Sources and further reading

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

Knitwear Base Editorial Team
Purchasing perspective

I'd require the factory to tell us before any change of fabric mill or sewing location, because either can change the origin wording we must print.

Knitwear Base Editorial Team
Merchandising perspective

Origin wording sits on the same label as fibre content and care. I'd approve all three together on one label proof, so nothing is updated in isolation.

Knitwear Base Editorial Team
QC perspective

At inspection we'd check that the printed origin matches the order documents, and keep a photo of the label in the inspection report.

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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