Keep Uncle Sam at Bay
• Advertising. Each textile or wool product description must contain a clear and conspicuous statement about where it was processed or manufactured. The origin statement must be consistent with the manufacturer’s or importer’s origin labeling. You don’t have to state the foreign country of origin, but you must state Imported, Made in U.S.A. or both. You can’t put in your catalog a blanket statement such as “All items imported unless otherwise noted.” The origin must be in each individual copyblock of all covered textile or wool products.
When making a required fiber disclosure, generic names must appear by order of weight. It’s unnecessary to include the percentage of each fiber. Fibers present in amounts of less than 5 percent must be listed as “other fiber(s).” If you use a fiber trademark, you still must include the generic fiber name at least once in the copyblock.
FTC’s Pricing Guidelines
Sale Prices. If you show a sale price for an item (which includes showing a price, slashing it and showing another price—even if you don’t use the word “sale”), you must have previously sold the item at the original price. You can’t offer something “on sale” that you’ve never actually sold at a higher price. Although not spelled out in the guideline, the rule of thumb is that the product should be offered for sale at the regular price for 30 days before it can be marked down.
Price Comparisons. If you make claims that compare your prices to other marketers’ prices or manufacturers’ suggested prices, you must know that substantial sales have indeed been made at those prices in the same trade area.
Words to Avoid. “Free,” “bonus” or similar words for something that’s always included when you sell that product. For example, if you offer a free item with the purchase of another item, but you never intend to offer either item for sale without the other, then you can’t represent this as a free offer.