How to start a clothing brand
Last reviewed . General information, not legal or tax advice.
To start a clothing brand, design a small first collection, find a manufacturer, and label every garment as the FTC requires: fiber content by generic name and percentage, country of origin, your company name or RN number, and permanent care instructions. Check the CPSC flammability rules, and the extra rules for children's clothing, before you sell.
What must a clothing label say?
Two FTC rule sets cover garment labels. The Textile and Wool Rules require three disclosures, and the Care Labeling Rule adds a fourth:
| Disclosure | What the rule asks for |
|---|---|
| Fiber content | Generic fiber names with percentages by weight, in order of predominance, for example "60% Cotton, 40% Polyester". Use "100%" or "All" for a single fiber. |
| Country of origin | Where the garment was processed or manufactured. "Made in U.S.A." alone only if made in the US of US materials; otherwise, for example, "Made in U.S.A. of imported fabric". |
| Who is responsible | Your company name or your Registered Identification Number (RN). |
| Care instructions | A permanent label with at least a washing or a drycleaning instruction, plus warnings about anything a consumer might assume is safe but would harm the garment. |
Details that trip up first collections:
- Fibers under 5% are listed as "other fiber" unless they have a functional purpose at that level, such as spandex added for stretch. Wool must always be named, at any percentage.
- On a garment with a neck, the country of origin goes on a label at or near the inside center of the neck. Fiber content and your name or RN can be on that label or on another conspicuous one, such as a side seam.
- Care labels must stay attached and legible for the garment's useful life, and you need a reasonable basis for every instruction. You cannot write "Dryclean only" unless you have evidence washing would harm it.
- You may use the ASTM care symbols in place of words, as long as they meet the rule's requirements.
Do I need an RN number?
No. The FTC says you do not need an RN to do business; it is simply a way to identify your company on labels instead of printing your full name. Each company is assigned only one, and it cannot be transferred. The FTC lists the benefits: buyers can find you through the RN directory, it takes less space than a company name, and it helps with record-keeping.
If a factory labels garments with your brand's RN or name, make sure the goods really go to you. The FTC warns that if goods labeled with a retailer's name or RN are sold to someone else instead, the label must be removed and replaced with the name or RN of the company actually distributing them.
What do I have to say when I sell clothes online?
The FTC requires country of origin in mail order and internet advertising too. Each product description must say whether the item was made in the U.S.A., imported, or both:
- "Made in U.S.A." only if all units are made completely in the US of US materials.
- "Made in U.S.A. and Imported" for US manufacture from imported materials, or part made in the US and part abroad.
- "Made in U.S.A. or Imported" when some units come from a domestic source and others from abroad.
The description must match the label on the garment. If you also print "Made in USA" in your branding, it has to meet the FTC's general Made in USA standard.
Which safety rules apply to clothing?
The CPSC's Standard for the Flammability of Clothing Textiles applies to clothing and the textiles used to make it, and bans dangerously flammable ones. It excludes some items, such as hats that do not cover the neck, face or shoulders, gloves up to 14 inches long and most footwear. Two kinds of fabric are exempt from testing to support a guaranty: plain-surface fabrics weighing 2.6 ounces per square yard or more, and fabrics made entirely of acrylic, modacrylic, nylon, olefin, polyester or wool. Fabrics outside those two groups, such as lightweight plain weaves or a cotton fleece, are the ones to ask your fabric supplier about.
Children's clothing carries more rules:
- Sleepwear has its own, stricter flammability standards: 16 CFR part 1615 for sizes up to 6X and part 1616 for sizes 7 through 14, with exceptions for items like tight-fitting garments.
- Drawstrings: the CPSC treats children's upper outerwear in sizes 2T to 16 with drawstrings that do not meet ASTM F1816-97 as a substantial product hazard.
- Certification: a product designed or intended primarily for children 12 or younger needs a Children's Product Certificate based on tests by a CPSC-accepted third-party laboratory.
How do I plan and price the first production run?
Keep the first collection small. A few styles in a few colors let you learn sizing, fit and demand before you commit cash to stock. Then:
- Prepare a tech pack for each style: flat sketches, measurements by size, fabric and trims, and your label content from the sections above.
- Approach manufacturers with it and ask for minimum order quantities, sample costs and lead times; see how to find a manufacturer.
- Approve a fit sample and a pre-production sample before the run, and check the labels on them.
- Cost each style per unit: fabric, trims and labels, cutting and sewing, freight and duties, packaging, then your channel's fees, and set a price that leaves a margin at wholesale if you plan to sell to shops (pricing guide).
Frequently asked questions
What has to be on a clothing label in the US?
Under FTC rules, most garments need fiber content by generic name and percentage, the country of origin, and the name or RN number of the company responsible, plus a permanent care label with washing or drycleaning instructions and any needed warnings. On garments with a neck, the country of origin goes at or near the inside center of the neck.
Do I need an RN number to start a clothing brand?
No. The FTC says an RN is optional; you can print your company's full name on labels instead. An RN is one number per company, cannot be transferred, takes less space than a name and lets buyers look you up in the FTC's directory, so it is worth considering once you produce labels in volume.
Can I sell clothes with a "Made in USA" label if the fabric is imported?
Not unqualified. The FTC allows "Made in U.S.A." alone only for garments made in the US of US materials. If the fabric is imported, the label must say so in one statement, such as "Made in U.S.A. of imported fabric." Online product descriptions must also say made in USA, imported, or both.
Do clothes need flammability testing?
Clothing textiles must meet the CPSC flammability standard in 16 CFR part 1610. Plain-surface fabrics of 2.6 ounces per square yard or more, and fabrics made entirely of acrylic, modacrylic, nylon, olefin, polyester or wool, are exempt from testing to support a guaranty. Children's sleepwear has separate, stricter standards.
Sources
- Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts, Federal Trade Commission. https://www.ftc.gov/business-guidance/resources/threading-your-way-through-labeling-requirements-under-textile-wool-acts
- Clothes Captioning: Complying with the Care Labeling Rule, Federal Trade Commission. https://www.ftc.gov/business-guidance/resources/clothes-captioning-complying-care-labeling-rule
- Complying with the Made in USA Standard, Federal Trade Commission. https://www.ftc.gov/business-guidance/resources/complying-made-usa-standard
- 16 CFR Part 1610, Standard for the Flammability of Clothing Textiles, U.S. Consumer Product Safety Commission (eCFR). https://www.ecfr.gov/current/title-16/chapter-II/subchapter-D/part-1610
- 16 CFR Part 1615, Standard for the Flammability of Children's Sleepwear: Sizes 0 Through 6X, U.S. Consumer Product Safety Commission (eCFR). https://www.ecfr.gov/current/title-16/chapter-II/subchapter-D/part-1615
- 16 CFR 1120.3, Products deemed to be substantial product hazards, U.S. Consumer Product Safety Commission (eCFR). https://www.ecfr.gov/current/title-16/chapter-II/subchapter-B/part-1120/section-1120.3
- Children's Product Certificate, U.S. Consumer Product Safety Commission. https://www.cpsc.gov/Business--Manufacturing/Testing-Certification/Childrens-Product-Certificate
This guide is general information, not legal or tax advice. Rules differ by state and city and change over time, so confirm the details with the official sources above or a licensed professional.