Introduction
A single mislabeled shipment can be held at customs for weeks. An incorrect fiber content claim can trigger an FTC investigation. A missing care label can result in Amazon removing your listing — permanently.
Textile labeling compliance isn’t optional, and it’s not something you figure out after production. The label requirements are baked into the product itself — the fiber content you declare determines what yarn your factory sources, the care instructions affect your finishing process, and the origin marking dictates how you structure your supply chain documentation.
This guide covers the complete labeling requirements for knitwear brands selling in the European Union and the United States, with specific attention to cashmere labeling rules, practical checklists you can bring to your factory, and common pitfalls that catch small brands off guard.
In this guide, you’ll learn:
- The specific regulations that govern textile labels in the EU and US
- How to correctly label cashmere and cashmere-blend products
- Care labeling systems (Ginetex for EU, FTC for US)
- E-commerce and digital compliance requirements
- A side-by-side comparison of EU vs. US rules
Why Textile Labeling Matters More Than You Think
It’s a Market Access Requirement
Customs authorities in both the EU and US actively inspect imported textile shipments. If your labels don’t meet requirements, the consequences are immediate:
- EU: Shipments can be blocked at border inspection. National market surveillance authorities can issue fines and force product recalls under the EU Textile Regulation (1007/2011).
- US: US Customs and Border Protection (CBP) can seize, exclude, or re-export non-compliant goods. The FTC can bring enforcement actions with civil penalties of up to USD 50,120 per violation (as of 2026, adjusted annually).
E-Commerce Platforms Enforce Compliance
This is where most small brands get caught. Amazon, Zalando, Farfetch, and other major marketplaces have their own compliance requirements that often go beyond government regulations:
- Amazon: Requires CPSIA compliance documentation for children’s products and has specific textile listing requirements. Non-compliant listings are deactivated without warning.
- Zalando and European marketplaces: Require fiber content disclosure in product descriptions that matches physical labels.
- Shopify-based stores: While Shopify itself doesn’t enforce labeling, consumer protection laws in the EU require that all material information be “clearly available before purchase” — which means your website must display the same information that appears on the physical label.
Real-World Consequences
In 2024, the FTC issued multiple enforcement actions against fashion brands for fiber content mislabeling, including brands claiming “100% cashmere” that contained measurable amounts of wool or synthetic fibers. Penalties ranged from USD 50,000 to over USD 500,000. For small brands, even a single enforcement action can be existentially threatening.
EU Textile Labeling: The Complete Breakdown
The Governing Regulation
The primary EU legislation governing textile labeling is EU Textile Regulation (EU) No 1007/2011, which has been in effect since May 2012. It applies to all textile products on the EU market, regardless of where they are manufactured.
Fiber Content Labeling Rules
Every textile product sold in the EU must carry a label indicating its fiber composition. The rules are specific:
Fiber composition must:
- Be present, durable, easily legible, and accessible on the product
- Be indicated in the official language(s) of the Member State where the product is sold
- Use the generic fiber names listed in Annex I of the regulation (e.g., “cashmere,” “wool,” “cotton,” “polyester” — not brand names)
Key rules for cashmere specifically:
| Rule | Detail |
|---|---|
| Definition | “Cashmere” refers exclusively to fibers from the goat Capra hircus laniger |
| Minimum fiber diameter | Must meet the definition (typically interpreted as ≤ 19 microns average diameter) |
| Adulteration | No more than 3% non-cashmere fibers by weight (excluding decorative fibers) |
| Labeling | Must use the term “cashmere” — not “pashmina,” “shawl wool,” or other regional terms |
| Blends | If blended, the percentage of cashmere must be stated precisely (e.g., “70% cashmere, 30% silk”) |
The 2% rule: Fibers that account for less than 2% of the total weight may be grouped together as “other fibers.” However, this exception does not apply to fibers that have a specific function (e.g., elastane for stretch), which must always be declared individually regardless of percentage.
Percentage rounding:
- 0.1% to 0.9% → round to “not less than 1%” or “1%”
- Exact percentages may be used
- The total must always add up to 100%
Country of Origin Marking
The EU does not have a mandatory “Made in” label requirement for textiles in the same way as some other jurisdictions. However:
- “Made in EU” claims are regulated under the Unfair Commercial Practices Directive — if you claim EU origin, the product must have undergone its last substantial transformation in the EU
- “Made in China” is generally required for products manufactured in China and sold in the EU (this is interpreted through customs origin rules and country-of-origin marking requirements under EU customs law)
- Origin claims in marketing (website, social media, packaging) must be truthful and verifiable
Care Labeling (EN ISO 3758 / Ginetex)
Care labels in the EU follow the GINETEX (International Association for Textile Care Labelling) system, standardized as EN ISO 3758. The five standard care symbols are:
- Washing (washtub symbol)
- Bleaching (triangle symbol)
- Drying (square symbol)
- Ironing (iron symbol)
- Professional textile care (circle symbol)
Each symbol can be modified with dots (temperature), lines (gentle process), crosses (do not), and letters (dry cleaning solvents).
For cashmere knitwear, the most common care instructions are:
- Hand wash or machine wash cold/gentle (washtub with 30°C, single line underneath)
- Do not bleach (crossed triangle)
- Flat dry (square with horizontal line inside)
- Low heat iron (iron with one dot)
- Do not tumble dry (crossed circle-in-square)
- Professional dry cleaning possible (circle with P or F letter)
Important: Care labels in the EU are advisory, not mandatory under Regulation 1007/2011. However, under the EU General Product Safety Directive (2001/95/EC), a care label is effectively mandatory because the manufacturer must provide “information necessary for the consumer to assess the risks” — and incorrect care is a risk to the product.
E-Commerce Requirements
Under EU consumer protection law (specifically the Consumer Rights Directive and the Digital Content Act), all information that appears on the physical label must also be available to the consumer before purchase in online sales. This means:
- Fiber content must be clearly stated on the product page
- Care instructions must be accessible (not hidden in a downloadable PDF)
- Country of origin must be disclosed if claimed on the label
- Information must be in the language of the consumer’s country
EU Compliance Checklist
| Requirement | Regulated By | Action |
|---|---|---|
| Fiber content label | Regulation 1007/2011 | Label with correct fiber names and percentages |
| Language | Regulation 1007/2011 | Use official language(s) of destination country |
| Generic fiber names | Regulation 1007/2011 Annex I | Use “cashmere,” not brand names |
| Cashmere definition | Regulation 1007/2011 | Verify fiber source is Capra hircus laniger |
| Origin marking | Customs law / UCPD | Truthful and verifiable claims |
| Care labeling | EN ISO 3758 / Ginetex | Follow standard symbol system |
| E-commerce disclosure | Consumer Rights Directive | Display all label info on product page |
| REACH compliance | REACH Regulation | Ensure no SVHC > 0.1% in components |
US Textile Labeling: The Complete Breakdown
Governing Laws
The US has multiple overlapping regulations for textile labeling:
- Textile Fiber Products Identification Act (TFPIA) — requires fiber content disclosure
- Textile Rules (16 CFR Part 303) — FTC regulations implementing TFPIA
- Wool Rules (16 CFR Part 300) — additional requirements for wool products (applicable to cashmere as it’s classified under wool rules)
- FTC Care Labeling Rule (16 CFR Part 423) — requires care instructions
- CPSIA — additional requirements for children’s products
Fiber Content Requirements
Under the FTC’s Textile Rules, every textile product must have a label disclosing:
Required information:
- Fiber content — listed in descending order of predominance by weight
- Manufacturer identity — name or RN (Registered Identification Number)
- Country of origin — where the product was processed or manufactured
Cashmere-specific rules (Wool Rules, 16 CFR Part 300):
The FTC defines cashmere precisely:
| Parameter | FTC Requirement |
|---|---|
| Fiber source | Cashmere goats (Capra hircus laniger) |
| Average fiber diameter | Must not exceed 19 microns |
| Non-cashmere fibers | Maximum 3% by weight (excluding decorative fibers) |
| Coarse hair content | Maximum 3% by weight of fibers exceeding 30 microns |
| Labeling term | “Cashmere” or “Pashmina” (pashmina has separate, stricter requirements) |
Critical FTC rule: If your product is labeled “100% cashmere,” it must be exactly that. The FTC has actively pursued brands making exaggerated cashmere claims. A product containing 96% cashmere and 4% wool cannot be labeled “100% cashmere” — it must be “96% cashmere, 4% wool.”
The 5% rule: For decorative or ornamental fibers (e.g., metallic thread for sparkle) that make up less than 5% of the product weight, you may use the phrase “contains decorative fibers” or name the specific fiber with its percentage, but the decorative fiber can be excluded from the total fiber content percentage. However, if the decorative fiber is wool or cashmere, it must be counted toward the total.
Generic names required: You must use the FTC-designated generic fiber name. Brand names (like “Supima” for cotton or “Lycra” for spandex) can be included alongside the generic name but cannot replace it. Example: “85% cashmere, 15% silk” is correct. “85% Cashmere, 15% Slumber Silk” would not be compliant without the generic name “silk.”
Country of Origin Marking
Under US customs law (CBP regulations), every imported textile must be marked with its country of origin in a conspicuous, legible, and indelible manner. The marking requirements are strict:
- “Made in China” or “Made in [Country]” must appear on the label
- The origin marking must be visible at the time of importation
- For knitwear, the label is typically sewn into the neck seam or side seam
- If the product is packaged, the origin must be visible through the packaging or on the packaging itself
Substantial transformation rule: A product’s country of origin is generally where it underwent its last substantial transformation. For knitwear produced in China from imported cashmere yarn, the origin is “Made in China” because the knitting process constitutes substantial transformation.
Care Labeling (FTC Rule)
The FTC Care Labeling Rule (16 CFR Part 423) requires that every textile product sold in the US carry a permanent care label with:
- Washing instructions (machine wash, hand wash, or dry clean)
- Drying instructions (tumble dry, line dry, flat dry)
- If applicable: ironing temperature, bleach instructions, dry cleaning instructions
- A warning if the consumer could reasonably be expected to use a care procedure that would harm the product (e.g., “Do not bleach — may cause discoloration”)
Key requirements:
- Labels must be permanent (remain attached for the useful life of the product)
- Labels must be legible and conspicuous
- Care instructions must not cause harm to the product when followed
- If a garment can be washed and dry cleaned, you must provide both sets of instructions
- If a garment can only be dry cleaned, you must say so — you cannot use a washing symbol that implies machine washability
Registered Identification Number (RN)
Every textile product sold in the US must identify the manufacturer, importer, or distributor. You can use either:
- Your company’s full name
- An RN number issued by the FTC
RN numbers are free to obtain through the FTC website. The application is straightforward, and most brands receive their RN within a few business days.
US Compliance Checklist
| Requirement | Regulated By | Action |
|---|---|---|
| Fiber content label | TFPIA / 16 CFR Part 303 | Generic names, descending order by weight |
| Cashmere definition | Wool Rules / 16 CFR Part 300 | Verify ≤ 19μ diameter, ≤ 3% non-cashmere |
| Country of origin | CBP regulations | Conspicuous, legible, permanent marking |
| Care label | 16 CFR Part 423 | Permanent, with wash/dry/iron/bleach/dry clean |
| RN number | FTC | Obtain RN or use full company name |
| “100%” claims | Wool Rules | Only if truly 100% — tested and verified |
| Children’s products | CPSIA | CPC, tracking label, third-party testing |
EU vs. US: Key Differences at a Glance
Understanding the differences between EU and US requirements is essential for brands selling in both markets. Here’s a side-by-side comparison:
| Aspect | EU | US |
|---|---|---|
| Governing regulation | Regulation 1007/2011 | TFPIA + Textile Rules + Wool Rules |
| Cashmere definition | Capra hircus laniger, ≤ 3% non-cashmere | Capra hircus laniger, ≤ 19μ, ≤ 3% non-cashmere, ≤ 3% coarse hair |
| “100%” claims | Allowed if accurate | Allowed if accurate, FTC actively enforces |
| Country of origin | Not always mandatory (but origin claims must be truthful) | Mandatory — required on every imported textile |
| Care labeling | Advisory (GINETEX/ISO 3758 symbols) | Mandatory (16 CFR Part 423) |
| Care language | Symbols (no words required) | Words required (symbols optional as supplement) |
| Language | Official language(s) of destination country | English (no multilingual requirement) |
| Manufacturer ID | Not specifically required | RN number or company name required |
| E-commerce | Must display label info before purchase | No specific e-commerce labeling law (but FTC advertising rules apply) |
| Enforcement | National market surveillance authorities; fines vary by country | FTC (civil penalties up to USD 50,120/violation); CBP (seizure/exclusion) |
| Penalty severity | Varies; typically EUR 500–5,000+ per violation | Up to USD 50,120 per violation |
Practical implication: If you sell in both markets, design your label to meet both sets of requirements simultaneously. This is straightforward — you include fiber content, care symbols (GINETEX) plus care words (FTC), country of origin, and your RN number. A single label can satisfy both jurisdictions.
Cashmere-Specific Labeling Pitfalls
Cashmere is one of the most heavily scrutinized fiber categories in both the EU and US. Here are the traps that catch brands.
“100% Cashmere” Claims
This is the most common area of enforcement. The FTC has brought multiple cases against brands claiming “100% cashmere” when the product contained wool or synthetic fibers.
The rule: If your label says “100% cashmere,” it must be 100% cashmere. No exceptions. No “approximately.” No “commercially pure.”
Reality check: Even with careful sourcing, trace amounts of other fibers can appear in cashmere through cross-contamination in sorting, combing, or spinning. If your lab tests show 97–99% cashmere, label it with the exact percentage — not “100%.”
Pashmina Labeling Disputes
“Pashmina” has specific FTC requirements:
- Must be from the Capra hircus laniger goat
- Average fiber diameter must be no greater than 16.5 microns (stricter than the 19μ standard for generic cashmere)
- Maximum 3% non-pashmina fibers
- Must be labeled as “pashmina” AND “cashmere” (e.g., “100% pashmina cashmere”)
In the EU, “pashmina” is not a recognized generic fiber name under Regulation 1007/2011. Products marketed as “pashmina” in the EU must use the term “cashmere” on the label.
Recycled Cashmere Labeling
As recycled cashmere becomes more common, labeling rules are evolving:
- US: Recycled cashmere must be labeled as “recycled cashmere” or “cashmere (recycled)” — not simply “cashmere.” The FTC considers this a material distinction.
- EU: Under Regulation 1007/2011, recycled fibers can use the same generic name as virgin fibers. However, the European Commission has proposed amendments that would require disclosure of recycled content.
“Cashmere-Like” Marketing Claims
Phrases like “cashmere feel,” “cashmere-soft,” or “cashmere-like” applied to non-cashmere products have triggered FTC action. If your product is not cashmere, do not use the word “cashmere” in any product description — even as a comparison or metaphor. Use “luxuriously soft” or “ultra-soft” instead.
Dehaired Cashmere vs. Regular Cashmere
“Dehaired” refers to the process of removing coarse guard hairs from cashmere fiber, leaving only the fine undercoat. While dehairing is standard practice in quality cashmere processing:
- “Dehaired cashmere” is not a recognized generic term in either the EU or US
- The label should simply say “cashmere”
- However, some brands use “dehaired cashmere” as a marketing claim on their website — this is acceptable as long as the physical label uses the correct term
Label Design Best Practices for Knitwear
Woven Labels vs. Printed Labels
For cashmere knitwear specifically, each type has trade-offs:
| Label Type | Advantages | Disadvantages |
|---|---|---|
| Woven label | Premium feel, durable, consistent with luxury positioning | Higher cost (USD 0.15–0.50/label), longer lead time (2–3 weeks), less flexible for multi-market text |
| Printed label (heat transfer) | Lower cost (USD 0.05–0.15/label), faster production, easy to change text | Can fade or crack over time, less premium feel |
| Satin/hang tag | Very premium for retail, easy to update | Separate from garment, can be removed by consumer |
Recommendation for cashmere knitwear: Use a woven main label (brand name) with a separate printed or woven care/content label. This gives you the premium feel on the visible brand label while allowing flexibility on the compliance side.
Label Placement on Knit Garments
Standard placement for knitwear:
- Crewneck / V-neck sweaters: Center back neck, sewn into the neck seam
- Cardigans: Inside center back neck or inside left side seam (near top)
- Scarves and wraps: End of scarf (one end) or center back
- Hats: Inside crown or inside brim
Tip: Avoid placing labels where they’ll be visible when the garment is worn — especially for luxury cashmere where consumers expect a clean aesthetic.
Multi-Market Labels
If you sell in both the EU and US, a single label can satisfy both requirements. Design your label to include:
- Brand name (top line)
- Fiber content (descending order by weight)
- Care symbols (GINETEX) + care words (for FTC)
- Country of origin: “Made in China” or equivalent
- RN number (for US sales)
- Size
This fits on a standard 3.5 × 5 cm woven label with two sides (front: brand + fiber content; back: care instructions + origin + RN).
Cost Considerations
| Label Component | Cost Range (per label) | Setup Cost |
|---|---|---|
| Woven brand label | USD 0.08–0.25 | USD 150–300 (mold fee) |
| Woven care/content label | USD 0.10–0.35 | USD 150–300 |
| Printed care/content label | USD 0.03–0.10 | USD 50–100 |
| Hang tag (paper/cardboard) | USD 0.05–0.15 | USD 100–200 (die cut) |
For small-batch production (100–300 units), total label cost is typically USD 0.25–0.80 per garment — a small percentage of total cost but a critical compliance component.
Digital Compliance: E-Commerce Labels
Product Page Requirements
For both EU and US e-commerce, your product pages should display:
Mandatory information:
- Full fiber content (same as physical label)
- Care instructions
- Country of origin
- Manufacturer/distributor identity
Recommended additions:
- Detailed sizing with measurements (not just S/M/L)
- Fabric weight or GSM
- Specific yarn count or ply information (for knitwear enthusiasts)
- Certifications (OEKO-TEX, GOTS, etc.)
Amazon-Specific Requirements
Amazon has become increasingly strict about textile compliance:
- Fiber content must be stated in the product title or bullet points
- Product images showing the care label are required for some categories
- Children’s products require CPSIA documentation (CPC) uploaded to Seller Central
- “Cashmere” claims may trigger additional documentation requests from Amazon’s compliance team
Post-Brexit: UK Requirements
Since Brexit, the UK operates its own textile labeling regime. The key differences from the EU:
- UK Labeling of Textile Products Regulations use the same fiber names and rules as EU Regulation 1007/2011
- Country of origin marking follows UK customs rules (similar to EU but separate enforcement)
- Language requirement: English is the primary requirement
- The UKCA mark may be required (depending on product type) alongside or replacing the CE mark
If you sell in the UK, treat it as a separate market from the EU for compliance purposes, even though the technical requirements are currently aligned.
Looking Ahead: Digital Product Passports & Supply Chain Traceability
A major regulatory shift is coming that will affect every textile brand selling in the EU: Digital Product Passports (DPPs).
Under the EU’s Ecodesign for Sustainable Products Regulation (ESPR), most textile products will eventually be required to carry a digital passport — a unique identifier (typically a QR code or NFC tag) linked to an online registry containing the product’s full material composition, origin, environmental impact data, and recyclability information.
What This Means for Knitwear Brands
- Full fiber traceability will no longer be optional — you’ll need documented supply chain data from yarn to finished garment
- Third-party verification of material claims will become the norm, not the exception
- Brands that build traceability infrastructure now will have a significant competitive advantage when DPP requirements take full effect
Getting Ahead of the Curve
Now in China,some companies actively building our traceability capabilities using Trustrace — a supply chain transparency platform that maps material flows from raw fiber through finished product. This investment means our partners will be better positioned to meet DPP requirements as they roll out, without scrambling at the last minute.
If you’re building a brand that plans to sell in the EU for the next 5–10 years, traceability isn’t a “nice to have” — it’s a compliance prerequisite. Start asking your supply chain partners about their digital traceability capabilities now.
Frequently Asked Questions
Do I need different labels for the EU and US?
Not necessarily. A single label can satisfy both markets if it includes fiber content, care symbols with words, country of origin (“Made in China”), and your RN number. The main differences are language (EU requires local language, US requires English) and care format (EU uses symbols, US requires words). Design your label to include both, and you’re covered for both markets.
What happens if my cashmere label says “100% cashmere” but testing shows 97%?
Under both EU and US law, this is a mislabeling violation. The FTC can pursue enforcement action, and EU authorities can force a product recall. You must label with the tested percentage (“97% cashmere, 3% wool” or whatever the test reveals). Never round up to 100% unless your testing consistently confirms it.
Can I use a care symbol only (no words) on my US labels?
No. The FTC Care Labeling Rule requires written care instructions in English. Care symbols alone are not sufficient for US compliance, although they can be included as a supplement. The EU, conversely, accepts symbols alone under the GINETEX system.
Is an RN number required for selling on my own Shopify store?
Technically, the FTC’s Textile Rules require a manufacturer identity (name or RN) on every textile product sold in the US, regardless of the sales channel — including your own website. In practice, enforcement on small DTC brands is less common than on marketplace sellers, but the legal requirement exists regardless of sales volume.
How much does textile compliance testing cost?
Third-party testing for fiber content typically costs USD 30–80 per sample, depending on the lab and turnaround time. For a full compliance package (fiber content, care verification, country of origin documentation), budget USD 200–500 per style. This is a one-time cost per production run and should be factored into your development budget.
What are Digital Product Passports, and do they affect my brand?
Digital Product Passports (DPPs) are a forthcoming EU requirement under the Ecodesign for Sustainable Products Regulation. They will require brands to attach a digital identifier (QR code or NFC) to each product, linking to an online registry with full material composition, origin, and environmental data. While the exact timeline is still being finalized, the regulation is expected to apply to textile products in the coming years. Brands investing in supply chain traceability tools like Trustrace now will be ahead of the compliance curve.
Conclusion
Textile labeling compliance for knitwear selling in the EU and US comes down to three non-negotiable elements:
- Fiber content must be accurate — especially for cashmere, which faces heightened scrutiny
- Care labels must be permanent and truthful — both symbols (EU) and words (US)
- Country of origin must be clearly marked — mandatory in the US, effectively mandatory in the EU
The good news: once you have a compliant label template designed, it becomes a repeatable process for every subsequent production run. The upfront investment in understanding the requirements and designing proper labels pays for itself many times over in avoided penalties, customs delays, and marketplace takedowns.
At Cawool, we help brands navigate compliance requirements as part of the production process — including label design guidance, testing coordination, and documentation support.
Need a compliance check before production? Contact our team to discuss your labeling needs. We can review your label design, coordinate third-party testing, and provide a compliance checklist tailored to your target market (EU, US, or both).
Further reading: OEM vs ODM Cashmere Knitwear: Which Model Is Right for Your Brand? · How to Vet a Knitwear Factory: 10 Questions Every Brand Must Ask · Cashmere Quality Control: Preventing Common Production Issues
Sources: EU Regulation 1007/2011, FTC Textile Rules (16 CFR Part 303), FTC Wool Rules (16 CFR Part 300), GINETEX Care Labelling, FTC RN Registration, Trustrace, EU ESPR — Ecodesign for Sustainable Products