The Federal Trade Commission's 16 CFR Part 423 (the "Care Labeling Rule") tells anyone selling apparel in the US exactly what care information must appear on every garment, and how. Combined with the Textile Fiber Products Identification Act (16 CFR Part 303), it forms the legal foundation for every US wash care label.
What 16 CFR Part 423 requires
- Provide instructions for regular care needed for the ordinary use of the product.
- Warn against any procedure that the consumer might assume is safe but is not (e.g. "Do not bleach" if the garment can't take chlorine).
- Use either text instructions, ASTM D5489 care symbols, or both — most US brands use text only.
- The label must be permanently attached and legible for the useful life of the product.
Required wording order
When using text-only instructions, the order required is: 1) washing or dry-cleaning instructions, 2) bleaching instructions, 3) drying instructions, 4) ironing instructions, 5) any necessary warnings. Skipping the bleaching instruction is one of the most common audit failures.
RN vs WPL: which number do you need?
- RN (Registered Identification Number) — 5-digit number issued by the FTC, replaces the company name on the label. Free, applied for online.
- WPL (Wool Products Labeling) — older 4-digit number, only relevant if you have an existing one; new WPL numbers are no longer issued.
- If you don't use an RN, you must print your full company name as registered in the state of incorporation.
Required identification information
- Fibre content (per 16 CFR Part 303), in English, by weight in descending order.
- Country of origin (e.g. "Made in China", "Made in USA of imported fabric").
- RN or company name of the manufacturer, importer or seller.
Common US compliance failures
- Care label sewn in the wrong location — for tops, it must be at the inside center back of the neck, or in a side seam.
- Care label not durable enough — must survive 10 home launderings without fading.
- Using only ISO symbols without text on a garment sold under a US-only brand — FTC accepts symbols, but most US consumers don't read them.
- Wrong country of origin format — "Made in PRC" is incorrect; use "Made in China".
Apply for an RN number once, use it forever. It saves your label real estate and protects your company name from being printed on every garment in your supply chain.