Wool Products Labeling Act: A Guide for Clothing Brands
Last updated: October 20, 2026
The Wool Products Labeling Act of 1939 requires any clothing that contains wool to carry a label stating the wool content, the origin and the responsible company. Wool has its own rules, separate from the Textile Fiber Products Identification Act, so a sweater with 5% wool and a cotton T-shirt are governed by different regimes.
What counts as a wool product?
A wool product is generally any product that contains wool, with exceptions for carpets, rugs, mats and upholstery. The FTC's rules are in 16 CFR Part 300.
Wool and recycled wool
The Act distinguishes types of wool, and the label must use the right term:
- Wool: fiber from the fleece of a sheep or lamb (or the hair of an Angora or Cashmere goat or certain other animals) that has never been used or reclaimed from any woven or felted product.
- Recycled wool: wool that has been reclaimed from woven or felted products and reprocessed.
- Older terms such as reprocessed and reused wool are now covered by the Act's "recycled wool" category.
You cannot call a garment "100% wool" if part of it is recycled wool. It would need a breakdown, such as "60% Wool, 40% Recycled Wool".
What the label must show
- Fiber content, with the percentage of wool, recycled wool and each other fiber, in descending order.
- Responsible company, by name or FTC RN.
- Country of origin.
Care instructions are required separately by the Care Labeling Rule. See Are Care Labels Required for Clothing Sold in the US?
Specialty wool: cashmere, mohair, alpaca and more
Specialty fibers such as cashmere, camel hair, alpaca, llama, mohair and vicuna have their own definitions and may be used only when the fiber meets the FTC's criteria. The Act's cashmere definition requires an average fiber diameter of 19 microns or finer, with no more than 3% by weight of fibers over 30 microns, so a "cashmere" label on a coarse blend can be a violation. Ask suppliers for testing evidence before using these terms in your labels or marketing.
Differences from the Textile Act
| Topic | Textile Act | Wool Act |
|---|---|---|
| Scope | Most fiber products | Products containing wool |
| Wool type matters | No | Yes: wool, recycled wool and others must be distinguished |
| Paperwork | Labels and certain invoices | Labels, plus invoices for unfinished goods that identify wool content, origin and manufacturer |
Because importers of unfinished goods must also identify wool content, origin and the company issuing the invoice, wool brands should check their supply-chain paperwork as well as the final label.
Wool labeling on Shopify
Show the same fiber breakdown and origin online. Avoid claims such as "pure wool" or "luxury cashmere" unless the label and supplier testing support them. Our Shopify checklist shows which product fields to create.
Common wool labeling mistakes
- Calling a recycled blend "100% wool"
- Using "cashmere" for fiber that does not meet the definition
- Omitting the wool percentage because it is small
- Letting marketing copy say "all wool" while the label shows a blend
- Forgetting that unfinished goods need compliant invoices
Frequently asked questions
Is Merino wool treated differently? "Merino" describes a sheep breed and wool, not a separate legal type. The wool label rules still apply.
Do I need an RN for wool products? You may use either a name or an RN. See Do Clothing Brands Need an FTC RN Number?
Can I say "virgin wool"? Only if the wool has never been used. Confirm with your supplier.
Does a small percentage of wool still trigger the Act? Yes, a wool product label must disclose wool content.
Related guides
- US Clothing Label Requirements: A Complete Checklist
- FTC Textile Labeling Requirements: The Ultimate Shopify Checklist
- How to Handle Fiber Content and Country of Origin Disclosures on Shopify
This article is general information, not legal advice.