We buy blank tees and replace the neck label with our own. What must our new label show?
You may replace the original label, but the new one must carry all the required information: fibre content, country of origin and your name or RN. Keep records of the removed label.

We buy blank tees from a wholesaler, print them, cut out the original neck label and sew in our own brand label. Our label shows only our logo and size. Is that enough?
Main answer
No. Under the Textile Fiber Products Identification Act and the FTC's Textile Rules, 16 CFR Part 303, a tee sold to consumers in the US must be labelled with its fibre content, its country of origin, and the identity of the manufacturer or of a business that markets or handles it, by company name or Registered Identification Number (RN). The FTC's guidance says a business may replace the original label with its own, but the substitute label must carry all the required information. A label with only a logo and a size does not.
What the new label needs
Copy the fibre content and country of origin from the original label, using the same generic fibre names and percentages. The FTC guidance says the new label must show the name or RN of the business making the change, so identify your business by the full name under which you trade, or by your RN. Under the FTC Care Labeling Rule, 16 CFR Part 423, the tee also needs permanent care instructions, so either keep the care information on your new label or make sure a permanent care label stays in the garment.
Where it goes
For garments with a neck, the FTC guidance says the country of origin must appear on the front of a label at the inside centre of the neck, midway between the shoulder seams or close to another label there. Fibre content and identity can be on the back of that label or on another conspicuous label, such as a side-seam label.
Records
The FTC guidance says a business that substitutes a label must keep records for three years showing the information on the removed label and the company the products were received from. Keep the original labels or photographs of them, with the supplier and order reference.
Practical steps
Ask the blank supplier for the fibre content and origin in writing for each style and colour, since heather colours often have a different blend. If you print or embroider, check whether the decoration changes what the fibre label needs to say. Proof your label and check a finished tee before you relabel the full order.
If you are unsure about a specific case, the FTC's business guidance and the rules themselves are the reference, and a compliance adviser can confirm the wording.
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
- eCFR — 16 CFR Part 423, Care Labeling of Textile Wearing Apparel
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 blank supplier for fibre content and origin by style and colour in writing before we design our labels.
Merchandising perspective
Our label can still look like our brand. We'd put the logo and size on the front and the required details in a clear block.
QC perspective
We'd check a relabeled tee against the original label for each colour and keep photos of the removed labels with the order record.
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