The label is the one part of a garment that is governed by law rather than by your specification. A factory in Vietnam can sew a perfect shirt and still ship goods that cannot be sold, because the fibre content is written in the wrong form, the care symbols belong to another country’s system, or the name on the label is not the party the destination’s law holds responsible.
Japan, the United States and the European Union each ask different questions of the same label. Below is what each primary text says, who is responsible, and what we check before the label is sewn in.
💬 Producing garments, uniforms or towels for more than one market? Tell us where the goods will be sold and we will build the label artwork check into the order from the start.
What does each market require on the label?
Japan requires fibre composition and, for many garments, care instructions in JIS L 0001 symbols plus the labeller’s name and address or telephone number; the United States requires fibre content, country of origin and the responsible company’s identity, and a permanent care label on wearing apparel; the EU regulation requires fibre composition in the language of the country of sale but does not itself set a care-labelling system.
| Japan | United States | European Union | |
|---|---|---|---|
| Instruments | Household Goods Quality Labelling Act; Textile Goods Quality Labelling Rules (CAA Notice No. 4 of 2017, last amended by Notice No. 13 of 25 December 2024, in force from 1 January 2025) | Textile Fiber Products Identification Act (FTC rules); Care Labeling Rule, 16 CFR Part 423 | Regulation (EU) No 1007/2011 on textile fibre names and fibre-composition labelling |
| Fibre content | Every fibre by its designated name with its percentage (Article 3(1)), with specified alternative methods in Article 5 | Fibre content required | Name and percentage by weight of all fibres in descending order (Article 9(1)) |
| Care instructions | Required for the items in Annex Table 1, rows 2 and 4, using the symbols of JIS L 0001:2024 (Article 3(2)) | Required on textile wearing apparel by the Care Labeling Rule | Not set by this regulation |
| Country of origin | Not one of the items this notice requires | Required; on garments with a neck, on the front of a label at the inside centre of the neck | Not set by this regulation |
| Name on label | Labeller’s name and address or telephone number (Article 3(5)), with exceptions in Article 4 | Company name or RN of the manufacturer, importer or other handler | Not specified as a label item by this regulation |
| Language | Designated fibre terms in Annex Table 6 (Japanese, with some English alternatives such as COTTON) | Required disclosures in English; other languages may be added alongside | Official language(s) of the member state where sold to the consumer (Article 16(3)) |
Checked against the published texts on 24 October 2026. Where a cell says “not set by this regulation”, other rules in that market may still apply — confirm them before you rely on a blank.
Japan — composition, JIS care symbols and the labeller’s name
Under Japan’s Textile Goods Quality Labelling Rules the items to be labelled depend on the product: towels, socks, gloves, handkerchiefs and tablecloths need fibre composition only, while shirts, trousers, sweaters, office uniforms, work clothes, aprons, curtains, sheets and pillowcases need fibre composition and household care instructions.
The rules are issued by the Consumer Affairs Agency under the Household Goods Quality Labelling Act (家庭用品品質表示法). Annex Table 1 lists the products and what each must show; coats add water repellency.
Points that matter for an order made in Vietnam:
- Designated fibre names. Article 6 and Annex Table 6 fix the words to be used for each fibre. A trade name can only be added in brackets alongside the designated term.
- Care symbols are JIS L 0001:2024. Article 2(3) defines “care labelling” as the symbols in JIS L 0001:2024, and Article 3(2) requires the symbols to be chosen on the basis of the test methods in that standard’s Annex A, an equivalent method, or accumulated technical information that predicts the result. In other words, the symbol needs a reason.
- Who the labeller is. Article 3 calls the party responsible the 表示者 — the manufacturer, the seller, or a labelling contractor — and Article 3(5) requires their name and either their address or telephone number on the label. Article 4 allows the details to be omitted in limited cases, for example where a labelling contractor labels and adds the manufacturer’s or seller’s details instead.
- Tolerances on percentages. Annex Table 5 sets how far a stated percentage may differ from the actual composition. A fibre-content label should come from a test or a mill specification, not from a sales description.
- Goods for export. Article 3 excludes goods labelled for export from Japan. Goods made in Vietnam for sale in Japan are imports, so the rules apply.
United States — the Textile Act and the Care Labeling Rule
US textile labels must carry fibre content, country of origin and the identity of the responsible company, the importer is legally responsible for labelling imported goods, and wearing apparel additionally needs a permanent care label that stays legible for the life of the garment.
The Federal Trade Commission’s guidance on the Textile Act states that labels must show fibre content, country of origin, and the manufacturer, importer or other dealer — by company name or by a registered identification number (RN). The disclosures must be in English, though other languages may be added. Imported products must name the country where they were processed or manufactured; on a garment with a neck, the origin goes on the front of a label at the inside centre of the neck. The importer is legally responsible for proper labelling of imported textile products. Towels and other household textiles are covered by the Textile Act.
The Care Labeling Rule (16 CFR Part 423) applies to manufacturers and importers of textile wearing apparel and of certain piece goods sold for making apparel, and to anyone who directs or controls that manufacturing or importing. According to the FTC’s guidance:
- The label must give a washing or a dry-cleaning instruction; washing instructions cover method, bleaching, drying, ironing and warnings.
- It must be permanently attached and remain legible for the useful life of the product.
- The company must have a reasonable basis — reliable evidence — for every instruction. Experience can be enough for some products; testing may be needed for others.
- Symbols may replace words, but the FTC guidance says only the ASTM symbols (ASTM D5489-96c) are approved; a 2012 proposal to also allow updated ASTM and ISO 3758 symbols is described as a proposal, so a label with only another system’s symbols is a risk.
- There are exemptions, including products sold to institutional buyers for commercial use, such as uniforms an employer buys for staff. The rule covers wearing apparel, not household textiles such as towels.
European Union — fibre composition under Regulation 1007/2011
The EU regulation requires fibre composition on textile products made available on the market, durable and securely attached, in the official language of the member state of sale; the manufacturer — or the importer where the manufacturer is outside the EU — is responsible, and a distributor that sells under its own name becomes the manufacturer.
Key provisions:
- Article 9 — multi-fibre products show the name and percentage by weight of every fibre in descending order, with limited derogations for “other fibres”.
- Article 7 — only products composed exclusively of one fibre may be described as “pure”, “all” or with a 100-per-cent claim, with a small allowance for technically unavoidable extraneous fibre.
- Article 12 — products containing non-textile parts of animal origin must say “Contains non-textile parts of animal origin”.
- Article 14 — labelling must be durable, easily legible, visible and accessible, and a label must be securely attached.
- Article 15 — the manufacturer ensures the label and its accuracy; if the manufacturer is not established in the EU, the importer does. A distributor that places the product on the market under its own name or trademark, attaches the label itself or changes its content is treated as the manufacturer.
- Article 16(3) — the label must be in the official language or languages of the member state where the product is made available to the consumer, unless that state provides otherwise.
Care labelling is not harmonised by this regulation. Article 24 listed “a harmonised care labelling system”, along with origin labelling, among the issues the Commission was to examine in a review report. A Vietnamese factory will often be asked for care symbols on EU-bound goods anyway — ISO 3758 sets out a care-labelling code using symbols — but whether and how care information is required is a question for the rules of the member states where you sell.
💬 Not sure which of these rules your importer or your customer holds you to? Send us the destination and the product and we will lay out the label content before the artwork goes to the factory.
Who is responsible — the factory, the trading company or the brand?
Legally, responsibility sits with the party the destination names — Japan’s labeller, the US importer, the EU manufacturer or importer or own-brand distributor — while in practice the brand supplies the approved label content, the factory reproduces and attaches it, and someone has to check one against the other.
A factory reproduces the label it is given; it cannot know your labeller details, RN, languages or care symbols unless you supply them. Typical problems are practical: artwork never finalised, an old label reused for a new fabric, or a care label that ignores a trim or print that cannot take the same treatment.
On our sewn-products orders we treat the label as a controlled document:
| Check | When | What we compare |
|---|---|---|
| Label content agreed | Before sampling | Destination, labeller or importer details, RN where used, languages |
| Fibre content | When bulk fabric is confirmed | Label percentages against the mill specification or a fibre test |
| Care symbols | After fabric and trims are fixed | Symbols against test results or documented evidence, for the most sensitive component |
| Artwork proof | Before label production | Proof against the agreed content, symbol system and size |
| Attachment and position | Pre-production sample | Position (for example the neck for US origin marking), permanence after a wash |
| Final check | Pre-shipment inspection | Labels on the goods match the approved proof, carton by carton |
The last line belongs on the inspection checklist; how to build that checklist is covered in pre-shipment inspection and AQL.
Care instructions need evidence, not a template
Both the US rule’s “reasonable basis” and Japan’s requirement to choose symbols from test results or technical information mean the care label has to follow from how the actual fabric, trims and decoration behave — usually by testing the bulk fabric and the most delicate component.
A garment is only as washable as its weakest part: the shirt fabric may tolerate a hot wash while the reflective tape or printed logo does not. The supporting tests — colour fastness to washing, dimensional change, appearance after washing — and when to run them are covered in fabric and garment testing before shipment. For towels and home textiles, where the label requirements differ by product, see sourcing towels and home textiles from Vietnam.
One garment, several markets — can one label work?
Sometimes, but only by carrying every market’s requirements at once — Japanese labeller details, the US identity and origin, EU languages — and by choosing a care-symbol approach each market accepts, so many programmes use market-specific labels instead.
Japan points to JIS L 0001 symbols, the FTC to ASTM symbols, and the EU regulation sets none. Market-specific labels are cleaner but split the lot and need tight carton control.
Country-of-origin rules for customs purposes and preferential tariffs are a separate subject from the origin marking on the label. For those, see proof of origin by destination and the rules-of-origin section of CMT, FOB or ODM.
💬 We coordinate labels, testing and inspection on uniform, bag and towel orders through our sewn-products manufacturing service. Start with your next order.
Frequently asked questions
1. Can the Vietnamese factory decide the care symbols for us?
It can propose them, but legal responsibility sits with the labeller or importer in the destination. Ask for the evidence behind each symbol and approve the symbols yourself before labels are produced.
2. Do work uniforms need care labels in Japan?
Yes, under Japan’s rules office uniforms and work clothes need both fibre composition and care instructions. In the US, the Care Labeling Rule exempts products sold to institutional buyers for commercial use, so check how your uniforms are sold.
3. Is “Made in Vietnam” required on the label?
For the US, yes. Japan’s labelling rules and EU Regulation 1007/2011 do not themselves require it, but other rules in those markets may; confirm with your importer before removing it.
4. Can we use ISO care symbols for the US market?
The FTC guidance names ASTM symbols as the approved system and describes allowing ISO symbols only as a proposal. Check the current FTC position before the artwork is fixed.
5. Who should hold the evidence behind the fibre content and care label?
The party legally responsible in the destination, with copies in the order file. We keep the mill specification, test reports and approved label proofs together for each order.
Sources: Consumer Affairs Agency of Japan, Textile Goods Quality Labelling Rules (CAA Notice No. 4 of 2017, as last amended by Notice No. 13 of 25 December 2024), Articles 1–6 and Annex Tables 1, 5 and 6. US Federal Trade Commission, “Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts” and “Clothes Captioning — Complying with the Care Labeling Rule”; 16 CFR 423.1. Regulation (EU) No 1007/2011, Articles 2, 7, 9, 12, 14, 15, 16, 17 and 24 (EUR-Lex). ISO 3758:2023 (ISO catalogue). Checked on 24 October 2026.