INTERNATIONAL TRADE LAW
How to Import Textiles into the U.S.
Importing textiles into the United States means meeting four separate requirements: FTC fiber-content and care labeling, CBP country-of-origin marking, CPSC flammability standards, and forced-labor screening under the Uyghur Forced Labor Prevention Act. Each is enforced by a different agency, and satisfying one does not satisfy the others. Textiles are also a high-enforcement category, so the labels and the supply-chain documentation both need to be right before the goods ship.
Four Requirements, Four Agencies
The obligations on an imported garment or fabric stack on top of each other. Use this as the starting map.
| Requirement | Agency | Core rule |
|---|---|---|
| Fiber content + care labeling | FTC | TFPIA / Wool Act; Care Labeling Rule |
| Country-of-origin marking | CBP | 19 U.S.C. § 1304 |
| Flammability | CPSC | Flammable Fabrics Act standards |
| Forced-labor screening | CBP | UFLPA (19 U.S.C. § 1307) |
A garment can clear flammability testing and still be detained for a UFLPA concern, or carry a correct CBP origin marking and still violate the FTC label rules. Plan for all four.
FTC Labeling: Fiber Content and Care
Most textile and wool products sold in the U.S. must carry a label disclosing fiber content, country of origin, and the identity of the manufacturer or marketer, under the Textile Fiber Products Identification Act (rules at 16 CFR Part 303) and the parallel Wool Products Labeling Act. Fiber content is listed by generic name and percentage by weight, in descending order. The responsible company can use its FTC-issued Registered Identification Number (RN) in place of its name. Separately, the FTC Care Labeling Rule (16 CFR Part 423) requires a care instruction — washing or dry-cleaning guidance — on most wearing apparel. The fiber/identity label and the care label are both FTC requirements and both have to be present and accurate.
CBP Country-of-Origin Marking
Origin marking is a customs requirement distinct from the FTC label. Under 19 U.S.C. § 1304, every imported article (or its container) must be marked conspicuously, legibly, and permanently with the English name of its country of origin so the ultimate purchaser can see it; CBP’s marking rules are in 19 CFR Part 134, and textile-specific origin rules are in 19 CFR 102.21. For apparel, the rules are specific about where the marking goes and how durable it must be. The FTC label and the CBP marking often appear together but answer to different agencies — see our overview of country-of-origin labels and classifying textile goods for import.
CPSC Flammability
Wearing apparel must meet the Flammable Fabrics Act standard for clothing textiles at 16 CFR Part 1610, which classifies fabrics by burn rate and prohibits the most dangerously flammable (Class 3) textiles for clothing use. Children’s sleepwear carries stricter, separate standards at 16 CFR Parts 1615 and 1616, with limited exceptions for tight-fitting or infant-sized garments. Flammability is a CPSC matter, and the same garment that satisfies labeling and origin rules still has to pass these tests. Children’s textile items can also trigger the broader children’s-product testing regime that applies to imported toys.
UFLPA Forced-Labor Screening
The Uyghur Forced Labor Prevention Act creates a rebuttable presumption that goods produced wholly or in part in China’s Xinjiang region — or by entities on the UFLPA Entity List — are made with forced labor and barred from entry under 19 U.S.C. § 1307. Cotton is one of the highest-risk inputs, which puts apparel squarely in CBP’s enforcement focus. If CBP detains a shipment, the importer must produce supply-chain tracing documentation showing the goods are outside the Act’s scope. Map your cotton and fabric sourcing before importing rather than after a detention notice.
Frequently Asked Questions
Is the FTC label the same as the CBP origin marking? No. FTC fiber-content and care labeling come from the Textile and Wool Acts and the Care Labeling Rule; CBP origin marking comes from 19 U.S.C. § 1304. They are separate requirements from separate agencies, and a garment needs both.
What does the fiber label have to say? The generic fiber names and their percentages by weight in descending order, the country of origin, and the manufacturer or marketer’s name or FTC-issued RN. Most apparel also needs a care label.
Do all textiles need flammability testing? Wearing apparel must meet the clothing-textile flammability standard (16 CFR Part 1610), and children’s sleepwear must meet stricter standards (Parts 1615/1616). These are CPSC requirements separate from labeling.
How does the UFLPA affect textile imports? It presumes goods tied to China’s Xinjiang region or listed entities are made with forced labor and inadmissible. Cotton is high-risk, so importers should hold supply-chain tracing documentation to rebut a CBP detention.
Importing apparel or textiles? Reidel Law Firm prepares flat-fee import/export compliance memos and advises importers on labeling, origin, and customs compliance with direct attorney access. Get an import compliance memo →
