Does fur trim need a label? The $150 exemption ended in 2011

Yes, fur trim needs a label. The Truth in Fur Labeling Act, signed December 18, 2010, removed the exception for fur products containing relatively small quantities or values of fur, and the Federal Trade Commission says its exemption for fur products with a component value of $150 has not been in effect since March 18, 2011.

That is the answer to a question that still circulates in shopping forums and some sellers' fine print, usually as the idea that a pom, collar or hood trim under a certain price does not count. It stopped being true more than a decade ago.

What the old exemption was

Before 2011, the FTC's rules let fur products with a small component value escape the labeling requirements. The dollar line was $150. Under that exemption, inexpensive trim did not have to carry the information a fur coat carried.

Congress closed that gap with the Truth in Fur Labeling Act of 2010, Public Law 111-313. The statute amends the Fur Products Labeling Act by removing the exception for products containing "relatively small quantities or values of fur," effective 90 days after enactment. The FTC's labeling guide states that the exemption for fur products with a component value of $150 has not been in effect since March 18, 2011.

What the Act left in place

The Act did not remove every exemption. It added one for fur products from trapped or hunted animals when the trapper or hunter sells them in a face-to-face transaction at a temporary location, such as a craft fair, and when fur or apparel sales are not that person's main source of income. Notice how narrow that is: it covers a direct seller who is not primarily a clothing business, not a retailer, not a brand and not a website.

The Act also directed the FTC to publish notice in the Federal Register and seek public comment on a review of the Fur Products Name Guide within 90 days. That is the guide that tells labelers which animal names to use.

What a fur label has to say

The FTC's guide lists the contents. The label must name the animal, using the name guide. Adjective country forms such as "Russian Mink" are optional. It must show the name or RN of the manufacturer, importer or seller. Imported fur must show its origin, for example "fur origin: Canada." Domestic fur may show origin but cannot be labeled or advertised in a way that implies it is imported.

The label must disclose whether the fur is pointed, dyed, bleached or artificially colored. If none applies, the fur should be labeled "natural." It must disclose if the product is made in whole or substantial part, meaning more than 10 percent of surface area, of pieces such as paws, tails or scraps. Used or damaged fur must be disclosed. Any textile or wool content must also be disclosed under the Wool Act rules; the guide's example is a wool coat with fur trim, which carries both kinds of information.

The label must be durable enough to stay on the fur until delivery. The required information has to be legible and conspicuous, in letters of equal size, all on one side of the label.

Invoices, ads and the online loophole people assume

The required information must also appear on invoices and in fur advertising. Ads covering furs from several countries may use the statement "Fur products labeled to show country of origin of imported furs." The guide says that statement does not apply to catalog or internet ads, where buyers cannot examine the label first.

That detail matters for online shoppers. A product page for a coat with fur trim cannot rely on the generic statement. The origin information has to be available where the buyer decides.

The general rule in the regulations

The regulations at 16 CFR 301.2(a) put the starting rule in one sentence: "Each and every fur product, except those exempted under § 301.39 of this part, shall be labeled and invoiced." The section we reviewed does not itself spell out what counts as a fur product or address faux fur, and the FTC page we cite does not discuss faux fur either, so this piece makes no claim about how synthetic fur is treated. If you are shopping animal-free materials, our explainer on vegan leather covers the non-leather side of the same question.

A separate ban

The guide also notes that the Dog and Cat Protection Act prohibits importing, exporting, manufacturing, selling, trading, advertising, transporting or distributing products made with dog or cat fur. That law sits alongside, not inside, the labeling rules.

Penalties

The FTC treats violations of the Fur Act or Fur Rules as an unfair method of competition and an unfair or deceptive act or practice. Violators of an administrative order face civil penalties of up to $53,088 per violation, and each instance of mislabeling is a separate violation. Businesses without a prior order can face civil penalties, an injunction and consumer redress in federal court, including where a company knowingly engages in practices the commission has already found unfair or deceptive.

No named official or executive has been quoted here, because the statute and the FTC guide are the primary text.

Our take

The small-trim exemption is a dead letter. If a garment has fur on it, from a collar to a pom on a hat, the seller owes you the animal name, the origin and the treatment on the tag, and the invoice and ad rules back that up. If a tag is missing that information on something that looks like fur, that is a fair question to put to the seller and, if the answer is thin, a reason to walk away.