US Clothing Label Requirements for Custom Apparel: Fiber Content, Origin, Care, and RN

A custom apparel order sold in the USA needs four things on its labels: fiber content by generic name and percentage, the country of origin, the name or FTC RN of a US company, and care instructions. Imported garments also need a permanent origin mark for Customs. Our factory builds all of it into the garment during production, at a label cost of a few cents per piece.

Most buyers who order custom uniforms, team kits or branded apparel from a factory think about fabric, fit and decoration first and labels last, usually a week before the bulk is cut. That order of work causes the most common compliance problem we see on US shipments: a beautiful garment with a brand label in the neck and nothing else. This guide sets out what US law requires, where each item goes, what happens on sublimated jerseys that have no sewn tag, how the rules change for employer-bought uniforms and youth sizes, and exactly what our Sialkot factory needs from you to get it right the first time. It is written from the factory floor, not a law office, so confirm anything unusual with your own counsel or a US customs broker. Label approval is a fixed step in our sample-first production flow.

What does US law require on a clothing label?

Three federal rule sets touch a garment label, and they are enforced by two agencies. The Federal Trade Commission enforces the Textile Fiber Products Identification Act and its rules (16 CFR Part 303), the Wool Products Labeling Act (16 CFR Part 300) and the Care Labeling Rule (16 CFR Part 423). US Customs and Border Protection enforces country of origin marking on imports under 19 U.S.C. 1304 and 19 CFR Part 134. A fourth, the Consumer Product Safety Improvement Act, adds a tracking label on anything made for children 12 and under.

Required item	What it must say	Rule	Who enforces
Fiber content	Generic fiber names with percentages by weight, in descending order; fibers under 5% as "other fiber" unless functional; wool always named	16 CFR 303	FTC
Country of origin	The country where the garment was made, for example "Made in Pakistan"; on the front of a label at the inside center back neck	16 CFR 303, 19 CFR 134	FTC and CBP
Company identity	Full legal name or FTC Registered Identification Number (RN) of a US manufacturer, importer or dealer; a trademark alone is not enough	16 CFR 303	FTC
Care instructions	At least one safe cleaning method plus warnings; permanent and legible for the useful life of the garment	16 CFR 423	FTC
Tracking label (youth only)	Manufacturer or private labeler, location and date of production, batch or run; permanent, on product and packaging	CPSIA Section 103	CPSC

The penalty exposure is real. The FTC's civil penalty for a knowing violation of a rule or an order stood at $53,088 per violation for 2025, and the Commission's September 2026 inflation notice kept the 2025 levels in place. Each mislabeled garment can count as a separate violation. On the Customs side, a container of unmarked or badly marked apparel can be held at the port until it is re-marked, at your cost, with marking duties on top. The way to stay out of both is simple and cheap: the label sheet is approved before a single panel is cut.

How do you write the fiber content correctly?

The fiber line is where most self-made labels go wrong. The Textile Act wants generic fiber names, not trade names, listed by weight in descending order with a percentage for each. "Polyester" is a generic name; a mill's branded moisture-wicking yarn is not, and if you want the brand on the label it must sit next to the generic name with the percentage. Four rules decide what the line looks like in practice:

• 3 percent tolerance. A label that says 95% polyester, 5% spandex is compliant if the real content is anywhere within 3 points of each figure. The tolerance disappears when the label says "100%" or "All" of one fiber, so a 100% cotton label must actually be 100% cotton in the fabric itself (sewing thread and trim are excluded from the count).
• 5 percent rule. Fibers under 5% of total weight are grouped as "other fiber" or "other fibers" and listed last, unless the fiber does a job you want to name. Spandex at 4% can be listed because it provides stretch. Wool and recycled wool are always named with their percentage, whatever the amount.
• Trim, linings and ornamentation. Collars, cuffs, binding, tape, labels and similar trim are excluded from the fiber disclosure. Decorative trim or a decorative pattern covering 15% or less of the surface is exempt. Ornamentation fibers at 5% or less of weight are exempt if the label says "exclusive of ornamentation." A lining used for structure only is not disclosed; a lining used for warmth is.
• Sectional disclosure. When different parts of the garment have different fiber content, each section is listed separately. A varsity jacket is the classic case: "Body: 80% wool, 20% nylon. Sleeves: 100% leather. Lining: 100% polyester. Filling: 100% polyester." Mesh side panels on a basketball jersey are usually the same polyester as the body, so one line covers them, but a cotton-rich hoodie with a polyester-lined hood gets two lines.

Here are the fiber lines we put on the most common builds in our catalog, written exactly as they go to the label mill. Your mill declaration may differ, so these are examples of format, not a substitute for your own fabric spec.

Garment and fabric	Fiber line on the label	Note
Sublimated jersey, 100% polyester interlock or mesh	100% Polyester	No tolerance on 100%; make sure the collar rib is excluded as trim
Performance tee or polo, polyester spandex blend	92% Polyester, 8% Spandex	Both over 5%, both named; at 4% the spandex could still be named for stretch
Fleece hoodie, cotton-rich	80% Cotton, 20% Polyester	Add "Exclusive of decoration" if the print exceeds 15% of surface
Varsity jacket, wool body, leather sleeves, quilted lining	Body: 80% Wool, 20% Nylon. Sleeves: 100% Leather. Lining: 100% Polyester. Fill: 100% Polyester	Wool Act applies; wool always named
Work trouser, poly cotton twill	65% Polyester, 35% Cotton	Pocketing is excluded as structural lining
Leggings, nylon spandex	78% Nylon, 22% Spandex	Both fibers over 5%, both named

One factory habit saves more trouble than any legal reading: we label from the mill's written fiber declaration for the exact fabric lot, and we file that declaration with the order. The FTC expects manufacturers to keep records that trace from raw material to finished garment for three years. If a buyer ever has to answer a question, the declaration, the lab dip and the packing list are already in one folder.

Where does the country of origin label go, and does "Made in Pakistan" have to be sewn in?

On any garment with a neck, the country of origin goes on the front of a label attached at the inside center of the neck, midway between the shoulder seams, or immediately next to another neck label. That is both the FTC placement rule and the position Customs expects under its long-standing decision on wearing apparel. Garments without a neck, such as shorts, leggings, trousers and skirts, need the origin mark in a conspicuous and accessible position, which in practice means the inside back of the waistband. The wording names the country where the garment was processed or manufactured. For us that is "Made in Pakistan". A region or trade bloc is not acceptable, and "Designed in USA" on a jacket cut and sewn in Sialkot does not replace the origin line.

Does it have to be a sewn label? The Customs standard is that the marking be conspicuous, legible, and as permanent as the nature of the article permits, with marking worked into the article at the time of manufacture treated as the best practice. A woven label sewn into the neck is the zero-argument option, and it is what we use on jackets, polos, hoodies and anything with a sewn collar. A heat transfer or direct print inside the neck is also accepted: in ruling N272034, Customs approved heat transfer origin marks on infant garments as conspicuous, legible and permanent, and rejected one style only because a light aqua transfer had too little contrast against a striped fabric. That ruling is why our rule for tagless labels is contrast first: dark ink on light fabric, white ink on dark fabric, never tone on tone.

On a sublimated jersey there is often no sewn label at all. We sublimate the size, "Made in Pakistan", the fiber line and the care instructions straight into the inside back neck as part of the print file, so the information is in the fabric for the life of the garment and cannot be cut out. The buyer's RN or company name goes in the same block. The FTC allows care information to be printed directly on the product as long as it stays permanent and legible, and the origin mark worked into the fabric is exactly what Customs calls best practice. The one thing to avoid is printing the required text in the same ink color as a busy sublimation background, for the same contrast reason. Browse the custom sports uniform catalog to see the sublimated builds this applies to.

Who goes on the label when the factory is overseas: RN, company name, or both?

The Textile Act requires the label to identify one business in the US distribution chain. There are two ways to do it, and a factory outside the United States is not one of them. The FTC issues Registered Identification Numbers only to US firms that manufacture, import, distribute or sell covered products. A factory in Pakistan cannot hold an RN, and a brand name or trademark on its own does not satisfy the rule. Your options are:

1. Your own RN. Any US business, including a single-member LLC, can apply online with the FTC at no charge. One number per company. It is the cleanest option for a brand, a school district, a club or a company uniform program that will reorder.
2. Your full legal business name. "Riverside Youth Soccer Club, Inc." works exactly as well as an RN. Most team and corporate buyers use this.
3. Your US importer's name or RN. If a US importing entity brings the goods in on your behalf, its name or RN may appear instead, with its consent.
4. A consenting retailer's name or RN. Relevant if you supply a retail chain that wants its own identity on the label.

This is one of the practical reasons US buyers prefer to contract with a US company rather than send money to a foreign factory directly. We operate through a Texas company, QVR Associates LLC, so the invoice, the import paperwork and the label identity chain all sit in the US. If you are new to this model, our guide on paying a US company for overseas manufacturing explains how it works. We never put our factory name in the RN position on a US-bound label, because it would not comply.

What must the care label say, and what are the exemptions?

The Care Labeling Rule asks for at least one safe cleaning method and a warning against any normal procedure a consumer might reasonably use that would damage the garment or other items washed with it. For a washable garment the instruction covers five points: washing method and water temperature if hot water would harm it, bleach (no mention if any bleach is safe, "Only non-chlorine bleach, when needed" if that is the case, "Do not bleach" if none is safe), drying method and temperature, ironing if the garment needs regular ironing, and warnings in plain words such as "Do not", "No" or "Only". You must have a reasonable basis for every instruction: fabric mill data, prior experience with the same fabric, or a wash test. "Dry clean only" needs evidence that washing would harm the garment, so we do not write it on a polyester jersey to be safe; that is itself a violation.

The care label must be attached permanently and securely and stay legible for the useful life of the garment, which is why it lives in the side seam on a woven or printed satin tape, or is printed directly into the neck block on sublimated pieces. Symbols are optional in the US and, where used, follow the ASTM D5489 care symbol set rather than the ISO symbols used in Europe; words alone are always acceptable. Because a large share of our buyers also sell in Canada or export, we usually print words and ASTM symbols together.

Our catalog build	Care instruction we recommend	Basis
Sublimated polyester jersey or shorts	Machine wash cold, inside out, with like colors. Do not bleach. Tumble dry low. Do not iron decoration.	Mill data on disperse-dyed polyester; protects sublimation from heat
Fleece hoodie with screen print	Machine wash cold, inside out. Only non-chlorine bleach, when needed. Tumble dry low. Do not iron print.	Plastisol and water-based inks degrade under hot iron and bleach
Embroidered polo, poly cotton	Machine wash warm. Do not bleach. Tumble dry medium. Warm iron, not on embroidery.	Cotton blend tolerates warm wash; embroidery thread colorfastness
Varsity jacket, wool and leather	Dry clean only. Leather clean by specialist. Do not wash.	Wool melton shrinks and leather stiffens in water; justified
Motorcycle jacket, textile with armor	Remove armor. Hand wash cold. Do not bleach. Hang dry. Do not iron.	Protects CE armor and reflective tape from heat and agitation

Two exemptions matter to uniform buyers. First, the Care Labeling Rule does not require care instructions on products sold to institutional buyers for commercial use, the standard example being uniforms an employer buys and issues to staff rather than selling to them. Fiber content, origin and company identity still apply, and Customs still needs the origin mark, so the exemption only removes one line. We recommend keeping the care label on institutional orders anyway: it costs a few cents per garment, and uniforms are routinely re-issued, resold or donated, at which point the exemption no longer covers them. If you are building a staff program, the corporate uniform program guide covers the ordering side. Second, hats, gloves and shoes are exempt from the Care Labeling Rule, and headwear is outside the Textile Act entirely unless it contains wool, so a polyester cap needs only the origin mark for Customs and, on our labels, the brand and size.

What extra labeling do youth sizes need under CPSIA?

Any garment designed or intended primarily for children 12 and under is a children's product under the Consumer Product Safety Improvement Act, and Section 103 requires a permanent distinguishing mark, the tracking label, on the product and its packaging to the extent practicable. The mark must let a parent or the CPSC identify the manufacturer or private labeler by name, the location and date of production, and cohort information such as a batch, run or style number. Youth soccer kits, little league jerseys, kids' hoodies and children's jackets all fall under this. The rule has been in force since August 2009, and Amazon and large retailers ask for it on children's apparel listings.

Our standard for a youth order is to add two lines to the care label or the printed neck block, in a format like this fictional example: "Riverside FC, Sialkot, Pakistan, 10/2026, Lot 2610-048". The lot number is the same production lot we use internally for QC and reorders, so the garment traces back to the fabric roll and the stitching line. The polybag gets the same information on a sticker. There is no charge for this; it is a few more characters on a label we are printing anyway. The order simply needs to be flagged as youth at the quote stage so the label artwork is built with it from the start. CPSIA also carries testing and certification requirements for children's products that sit outside this labeling guide, so if you sell youth apparel at retail, take advice on a Children's Product Certificate as well.

Woven, printed or heat transfer: which label type should you specify?

The law does not care whether a label is woven, printed or transferred, only that it is securely attached, conspicuous and legible, and in the case of care information, permanent for the life of the garment. The choice is about durability, comfort and cost, and it should match the garment. These are the three label constructions we run, the garments we use them on, and factory-direct cost estimates per piece at typical bulk quantities. Treat the costs as estimates; the label mill's price depends on size, number of colors and quantity, and we quote them exactly on each order.

Label type	Best for	Durability	Factory-direct cost per piece (estimate)	Watch out for
Woven damask neck label	Jackets, polos, hoodies, varsity, anything with a sewn collar	Outlasts the garment; the standard for Customs origin marking	$0.04 to $0.12 at 1,000+; label mill minimums around 500 to 1,000 per design	Fine text under 1.5 mm does not weave cleanly; keep origin and size on this label, move long text to the care label
Printed satin or taffeta care label	Side seam fiber, care, RN and tracking text on any garment	Good; thermal-printed satin stays legible through normal home laundering	$0.02 to $0.06	Taffeta is cheaper but stiffer; use satin on anything worn against skin
Heat transfer (tagless) print	Performance tees, rashguards, leggings, youth kits where a sewn tag irritates	Depends on the film and application temperature; approved by Customs when contrast is good	$0.06 to $0.15 applied	Insist on a wash-tested film; tone-on-tone color is the usual reason a transfer fails inspection
Sublimated neck block	Sublimated jerseys, shorts, cycling kits, training wear	Permanent; it is part of the fabric	No added cost; part of the print file	Keep the block in a solid, contrasting zone of the design

On a full-dress order, for example a fleece hoodie for a US brand, the garment carries a woven brand label in the neck with the size and "Made in Pakistan" on its front, a printed satin care label in the left side seam with the fiber line, care instructions and the RN, and, if the brand wants it, a woven hem tag. On a sublimated basketball uniform the whole set is one printed block inside the back neck of the jersey and inside the back waistband of the shorts. The tackle twill football jerseys we made for four trading-card brands show the typical setup: each brand's woven label in the collar, the compliance text in the seam, every piece polybagged with its own size sticker.

What does the factory need from you to get the labels right?

Labels are ordered from the label mill at the same time the pre-production sample is approved, because custom woven labels take roughly 7 to 10 working days to arrive and must be on the floor before bulk cutting begins. A late label file is the single most common reason a bulk date slips by a week, and it is entirely avoidable. This is the checklist we send every US buyer with the sample approval form:

1. Legal identity line. Your RN, or the full legal business name you want on the label, or your US importer's. If you do not have an RN and want one, apply with the FTC before the sample is approved; it is free and online.
2. Brand artwork for the neck label as vector (AI, EPS or PDF), with Pantone or thread color references, plus the label size you want. Common sizes are about 45 by 15 mm for a woven neck label and 30 by 60 mm for a satin care label; tell us if you want something else.
3. Size range and size marking style (US alpha sizes, youth sizes with the Y suffix, numeric for trousers). Size can sit on the neck label, a small separate size tab, or in the printed block.
4. Market. USA only, or also Canada, UK or EU. Canada needs bilingual English and French text and the CA number in place of the RN; the UK and EU use different fiber naming and the ISO symbol set. We build one label file per market rather than squeezing four jurisdictions onto one tape.
5. Youth flag. Any size designed for 12 and under triggers the CPSIA tracking lines.
6. Institutional or retail. Tells us whether the care exemption applies and whether you want the care label anyway (we recommend yes).
7. Approval in writing. We send a label layout proof, then a photo of the physical label sewn into the pre-production sample. Bulk cutting starts after that approval, not before.

We fill in the fiber line and the care instruction from the mill's declaration and our wash experience with that fabric, and we show you both on the proof. If your own compliance team prefers different care wording, it goes in as long as there is a reasonable basis for it. Everything on the proof is checked again at final inspection against the approved sample as part of our AQL 2.5 photo and video QC, including label position, legibility and the sewn-in orientation, because a care label sewn upside down is a reject in our factory even if it is technically still legal.

How do you order compliant custom apparel from our factory, and what does labeling add to the cost?

Labeling adds very little to a custom order when it is planned at the sample stage: a woven neck label and a printed care label together run roughly $0.06 to $0.18 per garment at bulk quantities, and a sublimated neck block adds nothing. What costs money is fixing it afterwards. Re-marking a held shipment in a US warehouse, with labor to open every polybag, apply a transfer and reseal, runs several times the factory cost of doing it right, before the storage and the missed delivery date. Our minimums are 30 pieces per style for cut-and-sew and from 12 pieces for sublimated team sets, the pre-production sample takes about 12 days after art and measurements are approved, and bulk production runs 3 to 5 weeks after sample approval. Payment is 50 percent deposit and 50 percent before dispatch, and we ship EXW, FOB, CIF or DDP to the USA by DHL, FedEx or UPS, with DDP meaning we handle the customs entry and duty so the labeled, polybagged goods arrive at your door.

To start, send your garment list, quantities per size, decoration, target delivery date, and the label details from the checklist above, or tell us you do not have them yet and we will build the label sheet with you from the first proof. If you are new to ordering from a factory abroad, read how to order custom apparel from an overseas factory safely first. Then request a quote and we will come back with a priced spec that includes the labels, the fiber line and the care wording for your approval.

Frequently asked questions

What are the clothing label requirements in the USA?

Four items: fiber content by generic name and percentage, the country of origin, the name or FTC Registered Identification Number (RN) of a US company responsible for the garment, and care instructions. The first three come from the Textile Fiber Products Identification Act (16 CFR Part 303), care from the Care Labeling Rule (16 CFR Part 423). Imported garments also need a permanent, legible country of origin mark for US Customs under 19 CFR Part 134.

Can an overseas factory put its own RN on my labels?

No. The FTC issues RNs only to US businesses, so a factory in Pakistan, China or anywhere outside the US cannot hold one. The label carries your RN, your full legal business name, or the name or RN of your US importer or a consenting retailer. An RN is free and optional; a full company name does the same job. A brand name or trademark alone does not satisfy the rule.

Where does the country of origin label go on a shirt or jersey?

On garments with a neck, at the inside center back of the neck, midway between the shoulder seams, or next to another neck label. US Customs wants it conspicuous, legible and permanent, and has accepted heat transfer and printed origin marks in that position when the contrast is good. Garments without a neck, such as shorts or leggings, need the mark in a conspicuous, accessible place, usually the inside back waistband.

Do employer-bought uniforms need a care label?

Under the Care Labeling Rule, products sold to institutional buyers for commercial use, such as uniforms an employer buys and does not sell to staff, are exempt from care instructions. Fiber content, country of origin and the company name or RN are still required, and Customs still needs the origin mark. We put a care label on anyway: it costs a few cents and keeps the garment compliant if it is later resold, donated or re-issued.

What is a CPSIA tracking label and does it apply to youth uniforms?

Section 103 of the Consumer Product Safety Improvement Act requires children's products, meaning items designed for ages 12 and under, to carry a permanent distinguishing mark on the product and its packaging: the manufacturer or private labeler name, the location and date of production, and batch or run information. Youth sports uniforms and kids' jackets fall under it. We print these lines on the care label or inside the neck at no extra cost when the order is flagged as youth.

How accurate does the fiber percentage on the label have to be?

The Textile Act allows a 3 percent tolerance on each stated fiber percentage, except where the label says 100 percent or All of one fiber, where no tolerance applies. Fibers under 5 percent are grouped as other fiber unless they have a functional purpose, such as spandex for stretch, and wool must always be named. We label from the mill's fiber declaration and keep it on file with the order for the three-year record requirement.