FTC Reviewing Digital Care Label Proposal: What Brands Need to Know

The U.S. Federal Trade Commission is reviewing a proposal that would update the country’s apparel labeling requirements. Specifically, it is considering whether to allow digital care labels as an alternative to the physical tags currently mandated under the Care Labeling Rule.

The change was proposed by the American Apparel & Footwear Association (AAFA), which represents over 1,100 brands. The group argues that current rules are outdated, costly, and misaligned with both consumer behavior and global regulatory trends.

The proposal does not seek to change the information that must be included on care labels. Instead, it requests that brands be allowed to present this information digitally, such as through a QR code or URL linking to a webpage with the required care instructions.

While the FTC has not yet made a decision, the fact that this proposal is under review reflects broader momentum toward digital product information and more scalable compliance solutions.

What the Proposal Aims to Change

The Care Labeling Rule was introduced in 1971 and is enforced by the FTC. 

It requires that clothing sold in the United States include permanent, physical labels with care instructions for washing, drying, ironing, and dry cleaning. 

The original purpose of the rule was to protect consumers from damaging garments due to lack of proper care instructions and to hold manufacturers accountable for providing clear information. 

However, the rule has remained largely unchanged since its inception, despite significant shifts in consumer behavior, global trade, and technology.

The petition notes that in 2024 alone, an estimated 18.4 billion garments were subject to this rule, costing brands over $217 million annually in compliance. These costs include labor, label production, and application (not accounting for environmental impact). 

Why Digital Care Labels

The push for digital labeling is not just about removing tags. It reflects a broader need for the apparel industry to modernize how product information is shared.

"Labels are too large to be comfortable or aesthetically pleasing but too small to contain all the information that modern-day consumers want," the AAFA wrote in its petition.

Physical labels have several limitations, including space constraints, language barriers, and functionality challenges. They also become difficult and expensive to update when regulations change or products are sold in multiple markets. 

This is what the AAFA refers to as “label creep” — when international requirements are increasingly being crammed onto small, hard-to-read physical tags, often in multiple languages and cryptic symbols.

In contrast, digital labels can provide:

• Reduced waste and lower labeling costs
• Better accessibility for visually impaired and non-English-speaking consumers
• Continued access to care information throughout a garment’s lifecycle
• Expanded product information for consumers
• Support for circular economy goals, including reuse, resale, and recycling
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Global Implications for Apparel

This proposal mirrors a much bigger trend around transparency and traceability.

In the European Union, the Digital Product Passport (DPP) is set to become a core regulatory requirement across industries. It mandates that brands provide structured, accessible product data covering materials, origin, repairability, and environmental impact.

If approved, digital care labels in the U.S. would be a meaningful step toward global interoperability. For brands selling internationally, this shift could simplify compliance and reduce friction.

See the full petition by the American Apparel & FootwearAssociation (AAFA) here.