Replacing Original Tags

When you want to label ready-made products as your own.
Written by Misty Henry
Updated 1 month ago

Let me first start with the fact that there are many discussions...heated discussions...about this practice of removing original tags to sell as ones' own.

This is legal.

The Federal Trade Commission (FTC) allows this practice as long as proper procedure is followed.

  1. Remove original label
  2. Replace ALL required information
    - Country of Origin
    - Care information
    - Fiber Content
  3. Add new manufacturer identity or RN#
  4. Keep records (which should include the original label) for 3 years to show the removed information and the company from where the product was received.

That's it. No other tricks to it. It's that simple.

But what's this "RN"?

Good question, my friend!

The RN, Registered Number, is an identifier for a manufacturer that enables the manufacturer to brand their products. For example, Gildan® is the brand; Gildan Activewear Inc. is the manufacturer.  That's quite a long name to put on labels, so Gildan Activewear Inc. would apply for an RN with the FTC and be permitted to include that number on their labels so they can simply brand as Gildan®.

By the way... Did you know that Gildan was "Born in Canada. Raised in the U.S."? #TheMoreYouKnow

The RN is free and anyone with a location in the US may apply [here]. You can look up current US RNs and Canadian CA Identification Numbers here as well.

What if I don't have an RN?

Not to worry! If you don't have, or want, an RN, it isn't required.  It simply means that the manufacturer identity on your labels will be your full legal name that appears on your business documents like purchase orders and invoices.  That means that if your brand or designer name is not the name that the company actually does business under, you must have both.

I lost you. It's ok, I lost myself. Here's an example:

My legal business name is 'Little Gnome Creations', but I have a clothing line called 'Forester Tots'. My label must say:

Forester Tots
by Little Gnome Creations

No big deal, but "Little Gnome Creations" is quite long on smaller items so I have two options:

  1. Get a DBA (which may cost money with the city/state registration), or
  2. Get the free RN and label with my line name and the RN elsewhere on the label.

A full label for children's clothing may look like this with the RN:

Forester Tots
Made in USA of imported matierals
Size 2T

Care information
Fiber Content

Alright, got it, but how do I private label?

There are a few terms to straighten out first:

Private Label = Buyer decides *all* parameters of the product being made in a facility, and includes buyer's name on the label. This product is exclusive to the buyer.
White Label = Provider of the product decides all parameters of the product, perhaps with semi-custom offers, and includes the buyer's name on the label. Buyer only has input on the label alone. This product is non-exclusive, only the label changes.
Resale = Provider has their own name on labels and buyer sells as-is with no alterations or embellishments.
Relabel = Buyer purchases a resale product and removes the label to replace with their own. Product may or may not be altered.

If the product does not have an existing label, in the case a company would add your labels to the products for you, then it's as if you made the whole thing, you just tell them the required information.

If the product has an existing label, you may remove that label and, as indicated above, replace all of the required information except using your own manufacturing name or RN.

Warning: Be aware that a company may not permit alterations to their products due to repuation, safety, and intellectual property reasons. Seek guidance from an intellectual property lawyer for further assistance.

Links to Agency Resources

- Federal Trade Commission: What is the required labeling for products?, Clothing care information
- Customers & Border Protection: Country of origin markings
- Consumer Product Safety Commission: Tracking Label

More Assistance

Join my free Facebook group, US Product Safety Compliance.
The Makers Community membership.
Free Checklist.
Free basic product safety course.

Support the information


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