So you’ve focused on your garment design, packaging and logo, but have you thought about the legal requirements of your clothes? Legal standards aren’t just for big brands. They apply to anyone selling clothes from handmade products, to luxury garments and as a fashion brand owner, you are legally responsible for making sure the law is followed.

But fear not. In this post, I’m going to explain the legal requirements for the US. When they apply and what you need to do. I’ll go through the post as a summary of the law first, but there are also some parts taken directly from the different regulations, at the end of the post, so that you can see word for word, what to use and how, if you want to.

By the time you finish this post, you’ll know how to cover you legal responsibilities properly. As long as you add everything you discover to your garments, you can safely and legally sell your clothing line, to whoever you want., without the fear of getting into legal difficulty with Trading Standards, or losing a court case with a customer.


Even if you don’t produce clothing yourself [you wholesale garments, resell products, or import] you may have thought that you would get away with not having to comply with this part of the law. I’m afraid you’re wrong.

The law for clothing is actually quite broad in its terminology, which means that it applies to lots of different people and companies. If you are listed below, then the law applies to you. Ultimately, a customer will sue the retailer that they bought the product from, so retailers needs to ensure that the law is followed, especially as it will also bring bad press. But a smart retailer, will then pass that cost on, by suing whoever was at fault. That could be an importer, factory or wholesaler, depending on the law and who it covers.

Since this is, well, frustrating, stressful and costly, it’s better to know what to look for and what the regulations are from the start.


In the US, the Electronic Code Of Federal Regulations, Title 16 , Chapter I , Subchapter D, Part 423-Care Labeling Of Textile Wearing Apparel And Certain Piece Goods As Amended is the legislation that covers care labeling.

In the US, the following companies and people are covered by garment labeling laws:

  • Manufacturers and importers of textile wearing apparel
  • Manufacturers and importers of piece goods sold to consumers for making wearing apparel
  • Any person or organization that directs or controls the manufacturing or importing of textile wearing apparel or piece goods for making wearing apparel

This basically means that it applies to any person or business, which manufactures [single or multiple garments of any quantity] or imports garments.

There are additional notes in the regulation for importers, which tell you when labeling should be attached. However most of the terms relate to “before sale”, so in other words, as long as the regulation is followed before you sell your product, then they can be bought into America without the labeling attached.

So now that we know who the law applies to, let’s look at the details.

care labels and swing tags for fashion brands and clothing line start ups


It may surprise you that adding washing instructions on garment labels, is not a legal requirement in some countries. But doing it is a REALLY good idea.

Since the 1900’s, the world has moved on from washing natural fabrics by hand, to domestic washing machines, dryers, electric irons, technical fabrics and dry cleaning. In some countries, where there is a culture of consumers suing brands, generally for mistakes that the consumer has made, the consumer can win court cases and thousands of dollars in damage, if there are no instructions telling the consumer exactly how to take care of their garments.

In the US, however, care instructions are a legal requirement.


There are of course exceptions. Shoes, gloves and hats, do not need wash care labels [also called care instructions], but as I mentioned above, you may wish to include an information sheet, or something when the product is sold, just to be on the safe side.

Handkerchiefs, belts, suspenders, neckties and non-woven garments made for one time use, are also excluded from care labelling laws.


At point 423.6 Textile wearing apparel, of the regulation, it talks about how care labels should be displayed.

Simply put, the care instructions must be visible when purchased. For most retailers, this is on a care label, sewn into a garment, but if the garment is folded or packaged so that the label can’t be seen, the instructions must also be on the outside of the packaging.


There are a number of terms that allowed and not allowed under US law. There are references at points 423.2   Terminology, and 423.6 [b]

In general, care labels must give clear instructions about how a customer should take care of their products long-term. This includes things like temperature and processes. For example, “40°C Wash” or “Cool Iron”.  On care labels, a washing, or dry cleaning instruction must be given, but where both could be used to clean your garments, you can choose to use just one. I would however, for the sake of protecting yourself legally, give all instructions that are appropriate.

As well as telling people what to do, you must also inform customers about anything that they shouldn’t do. Instructions on anything that could damage their products must be included on their care labels. So for example, if tumble drying your jumper could damage it, then you must also say “Do not tumble Dry”

The terminology notes in the regulation are extensive, so I have not added them at this point, but you can view them at the bottom of this post, as well as Appendix A of the regulation which lists terms that can be used. The notes are taken directly from the regulation, so that there are no changes to the terms, or meaning.


Although care instructions must be provided, symbols for care instructions, are not actually required by law. My personal advice is that it’s a good idea to have both, but it’s also good to know that there are different symbols for different parts of the world. Most of them are the same, but there are a few that are specific, depending on the country, so it is always a good idea to check.

The regulation for care symbols, changes depending on whether there is wording on the care label, or not. If symbols are provided with wording, then the regulation around the precise artwork of the symbols, are a little more relaxed.

In the US, the symbol system developed by the American Society for Testing and Materials (ASTM) is the standard that should be used. They can also be used on care labels or care instructions, instead of wording. However, to do this [use symbols without words] it must also pass further regulations and starts to get into tricky territory, including scale and detail of the symbols, which must be exact. So as before, my advice is to use both.

You can find out more on care symbols on a previous blog post, RESOURCE: 74 CARE SYMBOLS FOR FASHION LABELS, which includes a pdf download for symbols and their meanings. If you prefer to check out the standards at ASTM, you search for the standard: ASTM Standard D5489-96c Guide to Care Symbols for Care Instructions on Consumer Textile Products. Unfortunately ASTM has strict regulations on linking their website page [weird I know], so I can’t provide a link address for this standard, but a generic search on your web browser will work just fine.

fibre content for fashion brand and clothing care labels. USA standards


Fibre content comes under a different part of US regulation, than the care label law above. Fibre content can be found in the Electronic Code Of Federal Regulations, Title 16 , Chapter I , Subchapter C, Part 303 – Rules And Regulations Under The Textile Fiber Products Identification Act.


The products that are covered in this part of the regulation, are different from care label regulation. There are a lot of products listed in the regulation law, so I have focused below on the products that are fashion related, but it is important to know that there are many more.

  • Clothing, except for hats and shoes
  • Handkerchiefs
  • Scarves
  • Umbrellas and parasols
  • All fibers, yarns and fabrics, but not packaging ribbons

There are of course exemptions that do not require fiber content labeling. Again there are more in the official list, but the following items, refer to fashion products.

  • Linings, interlinings, filling or padding used for structural purposes. If used for warmth, though, the fiber must be disclosed. In addition, if you state the fiber content of linings, interlinings, filling or padding, the products are not exempt.
  • Stiffenings,trimmings, facings or interfacings
  • Sewing and handicraft threads
  • Headwear, including hats, caps or anything worn exclusively on the head.  Wool hats are covered under The Wool Rules
  • Shoes, overshoes, boots, slippers and all outer footwear. But, socks and hosiery are covered; slippers made of wool are covered under The Wool Rules.
  • Waste materials not used in a textile product
  • Textiles used in handbags or luggage

The following fashion items are also exempt from the regulations. Not because they are written down as exempt, but because they are not mentioned in the regulation.

  • Bags — net bags, tote bags, bags for laundry, diapers, cosmetics, sports gear, etc.
  • Beads, sequins, buttons
  • Cummerbunds
  • Dog coats, other pet clothing, and pet furniture
  • Knapsacks and backpacks
  • Leather goods and trim
  • Sports protectors for elbow, knee, chest, etc.
  • Sweatbands

As a last point, there are also a number of products that are not covered by fibre regulations, unless you decide to make claims about the fibre it is made from, then, all regulations apply. For example, if you sell belts, you don’t have to provide fibre labelling. However, if you decide to advertise it as 100% leather, then the all regulations apply. The following are again only the fashion based products, but there are more on the full list.

  • Belts
  • Suspenders
  • Arm bands
  • Neckties that are permanently knotted
  • Garters
  • Diaper liners
  • Labels (individually and in rolls)
  • Looper clips intended for handicraft purposes
  • Shoe laces
  • All textile products manufactured by operators of company stores and sold exclusively to their own employees
  • Coated fabrics and those parts of textile products made of coated fabrics. A fabric is coated if it is coated, filled, impregnated or laminated with a continuous-film-forming polymeric composition, and the weight added to the base fabric is at least 35% of the weight of the fabric before coating.
  • Non-woven disposable products intended for one-time use only


There are a number of additional regulations when talking about specific fibres, such as wool, leather and fur/hair, but for the majority of fibres, you must use the generic name rather than a brand name or trademark, unless you have permission to use the trademark name. For example, Woolmark or Lycra

It’s also important to note that some fibres have specific US terms too and should be used for the US market. For example, Lycra is a trademarked brand name for a particular fibre. Elastane is the same thing, but a generic, worldwide term. In the US, the generic term is Spandex, so ‘Spandex’ should be the term used on care labeling.

You can read more about generic names and fibers in points 303.6, 303.17 and 303.41 of the regulations or in the ISO standard listed below, in Fibre Percentage.


Any fibre that makes up less than 5% of the total fabric weight, does not be named. Instead, if it is 1 specific fibre, then you can just refer to it as “other fiber”. If your fabric has a few fibers that are less than 5% of the total weight, then they should be referred to as “other fibers”. But you should read more on this below, as the 5% Rule has its own set of exceptions.

The regulations on this are quite long and complex, with different standards for natural fibers, fur, synthetics and so on. If you’re looking for something specific, or want to buy the regulation for yourself, then you’ll need to visit ISO, or International Organization for Standardization and look for standard ISO 2076:2010(E), “Textiles—Man-made fibers—Generic names.”

All other fibres need to be listed on your label, with percentage weights, in order from the largest to smallest, for example

62% Cotton, 24% Linen, 14% Silk

Labeling only applies only to fibers in yarns, fabrics, clothing and other household items. So if part of the product is made from a non-fibrous material you don’t have to include that on your label. In other words, zips, buttons, beads and anything that is not a yarn, fibre or fabric, doesn’t have to be included.


There are a couple of exemptions to the 5% rule, which mean you must list these fibers on your label, even if it is less than 5% of the fabric weight. The rule says:

  • You must disclose wool or recycled wool by name and percentage weight.
  • You should state the name and percentage of a fiber that changes the fabric or has some kind of significance. For example, Spandex provides elasticity to a fabric, changing its properties, so you should add that to the label.


The Country of Origin is legally required to be on a garment label. The regulations depend on where a product has been made. Sounds pretty straight forward doesn’t it, but there are some differences in the things you will need to consider, depending on whether you are making abroad, importing materials into the USA first, or making purely in the USA.

In a nutshell, if you are making abroad, then you need to say “Made in [insert country here]”. If products are made in the US with US materials, then you need to say  “Made in U.S.A.”. Any other combination, the you need to check with the Federal Trade Commission [FTC] and Customs, who have their own rules on imported items and materials.


  • Imported products must identify the country where the products were processed or manufactured.
  • Products made entirely in the U.S. of materials also made in the U.S. must be labeled “Made in U.S.A.”
  • Products made in the U.S. of imported materials must be labeled to show the processing or manufacturing that takes place in the U.S., as well as the imported component.
  • Products manufactured partly in the U.S. and partly abroad must identify both aspects.
  • Manufacturers and importers must comply with both FTC and Customs requirements.



As you can see there is a lot more to labeling than most people initially think. This is not restricted to the US of course, as other countries have their own set of rules. Before selling any garments, you really should check with the government of the country you are selling in.

A lot of the documentation referenced in this post and in the resources below, will be in ‘legal speak’ so you might want to ask a lawyer or for some clarification if you are unsure. There are also many companies that also sell ‘Standards’, like ISO or ASTM. ‘Standards’ are basically documents with the details of law or legal regulations, including symbols if needed, but they also provides some explanation alongside the standards themselves. They can be quite helpful if you are new to a particular law, but I should mention that they don’t put the details in ‘normal language’ or explain them in a basic way.


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Care Labels and Washing Symbols for garment labeling for fashion brands and clothing lines. What do the garment washing instructions mean. PDF download.







Electronic Code of Federal Regulations


Electronic Code Of Federal Regulations, Title 16 , Chapter I , Subchapter C, Part 300 – Rules And Regulations Under The Wool Products Labelling Act


Electronic Code Of Federal Regulations, Title 16 , Chapter I , Subchapter C, Part 303 – Rules And Regulations Under The Textile Fiber Products Identification Act


Electronic Code Of Federal Regulations, Title 16 , Chapter I , Subchapter D, Part 423-Care Labeling Of Textile Wearing Apparel And Certain Piece Goods As Amended,



ISO 2076:2010(E), “Textiles—Man-made fibres—Generic names.”




Electronic Code Of Federal Regulations, Title 16 , Chapter I , Subchapter D, Part 423-Care Labeling Of Textile Wearing Apparel And Certain Piece Goods As Amended

423.6   Textile wearing apparel.

This section applies to textile wearing apparel.

(a) Manufacturers and importers must attach care labels so that they can be seen or easily found when the product is offered for sale to consumers. If the product is packaged, displayed, or folded so that customers cannot see or easily find the label, the care information must also appear on the outside of the package or on a hang tag fastened to the product.

(b) Care labels must state what regular care is needed for the ordinary use of the product. In general, labels for textile wearing apparel must have either a washing instruction or a drycleaning instruction. If a washing instruction is included, it must comply with the requirements set forth in paragraph (b)(1) of this section. If a drycleaning instruction is included, it must comply with the requirements set forth in paragraph (b)(2) of this section. If either washing or drycleaning can be used on the product, the label need have only one of these instructions. If the product cannot be cleaned by any available cleaning method without being harmed, the label must so state. [For example, if a product would be harmed both by washing and by drycleaning, the label might say “Do not wash—do not dryclean,” or “Cannot be successfully cleaned.”] The instructions for washing and drycleaning are as follows:

(1) Washing, drying, ironing, bleaching and warning instructions must follow these requirements:

(i) Washing. The label must state whether the product should be washed by hand or machine. The label must also state a water temperature—in terms such as cold, warm, or hot—that may be used. However, if the regular use of hot water up to 145 degrees F (63 degrees C) will not harm the product, the label need not mention any water temperature. [For example, Machine wash means hot, warm or cold water can be used.]

(ii) Drying. The label must state whether the product should be dried by machine or by some other method. If machine drying is called for, the label must also state a drying temperature that may be used. However, if the regular use of a high temperature will not harm the product, the label need not mention any drying temperature. [For example, Tumble dry means that a high, medium, or low temperature setting can be used.]

(iii) Ironing. Ironing must be mentioned on a label only if it will be needed on a regular basis to preserve the appearance of the product, or if it is required under paragraph (b)(1)(v) of this section, Warnings. If ironing is mentioned, the label must also state an ironing temperature that may be used. However, if the regular use of a hot iron will not harm the product, the label need not mention any ironing temperature.

(iv) Bleaching. (A) If all commercially available bleaches can safely be used on a regular basis, the label need not mention bleaching.

(B) If all commercially available bleaches would harm the product when used on a regular basis, the label must say “No bleach” or “Do not bleach.”

(C) If regular use of chlorine bleach would harm the product, but regular use of a non-chlorine bleach would not, the label must say “Only non-chlorine bleach, when needed.”

(v) Warnings.

(A) If there is any part of the prescribed washing procedure which consumers can reasonably be expected to use that would harm the product or others being washed with it in one or more washings, the label must contain a warning to this effect. The warning must use words “Do not,” “No,” “Only,” or some other clear wording. [For example, if a shirt is not colorfast, its label should state “Wash with like colors” or “Wash separately.” If a pair of pants will be harmed by ironing, its label should state “Do not iron.”]

(B) Warnings are not necessary for any procedure that is an alternative to the procedure prescribed on the label. [For example, if an instruction states “Dry flat,” it is not necessary to give the warning “Do not tumble dry.”]

(2) Drycleaning

(i) General. If a drycleaning instruction is included on the label, it must also state at least one type of solvent that may be used. However, if all commercially available types of solvent can be used, the label need not mention any types of solvent. The terms “Drycleanable” or “Commercially Dryclean” may not be used in an instruction. [For example, if drycleaning in perchlorethylene would harm a coat, the label might say “Professionally dryclean: fluorocarbon or petroleum.”]

(ii) Warnings.

(A) If there is any part of the drycleaning procedure which consumers or drycleaners can reasonably be expected to use that would harm the product or others being cleaned with it, the label must contain a warning to this effect. The warning must use the words “Do not,” “No,” “Only,” or some other clear wording. [For example, the drycleaning process normally includes moisture addition to solvent up to 75% relative humidity, hot tumble drying up to 160 degrees F and restoration by steam press or steam-air finish. If a product can be drycleaned in all solvents but steam should not be used, its label should state “Professionally dryclean. No steam.”]

(B) Warnings are not necessary to any procedure which is an alternative to the procedure prescribed on the label. [For example, if an instruction states “Professionally dryclean, fluorocarbon,” it is not necessary to give the warning “Do not use perchlorethylene.”]

(c) A manufacturer or importer must establish a reasonable basis for care information by processing prior to sale:

(1) Reliable evidence that the product was not harmed when cleaned reasonably often according to the instructions on the label, including instructions when silence has a meaning. [For example, if a shirt is labeled “Machine wash. Tumble dry. Cool iron.,” the manufacturer or importer must have reliable proof that the shirt is not harmed when cleaned by machine washing (in hot water), with any type of bleach, tumble dried (at a high setting), and ironed with a cool iron]; or

(2) Reliable evidence that the product or a fair sample of the product was harmed when cleaned by methods warned against on the label. However, the manufacturer or importer need not have proof of harm when silence does not constitute a warning. [For example, if a shirt is labeled “Machine wash warm. Tumble dry medium”, the manufacturer need not have proof that the shirt would be harmed if washed in hot water or dried on high setting]; or

(3) Reliable evidence, like that described in paragraph (c)(1) or (2) of this section, for each component part of the product in conjunction with reliable evidence for the garment as a whole; or

(4) Reliable evidence that the product or a fair sample of the product was successfully tested. The tests may simulate the care suggested or warned against on the label; or

(5) Reliable evidence of current technical literature, past experience, or the industry expertise supporting the care information on the label; or

(6) Other reliable evidence.



Electronic Code Of Federal Regulations, Title 16 , Chapter I , Subchapter D, Part 423-Care Labeling Of Textile Wearing Apparel And Certain Piece Goods As Amended

Appendix A to Part 423—Glossary of Standard Terms
  1. Washing, Machine Methods:
  2. “Machine wash”—a process by which soil may be removed from products or specimens through the use of water, detergent or soap, agitation, and a machine designed for this purpose. When no temperature is given, e.g., “warm” or “cold,” hot water up to 145 degrees F (63 degrees C) can be regularly used.
  3. “Hot”—initial water temperature ranging from 112 to 145 degrees F [45 to 63 degrees C].
  4. “Warm”—initial water temperature ranging from 87 to 111 degrees F [31 to 44 degrees C].
  5. “Cold”—initial water temperature up to 86 degrees F [30 degrees C].
  6. “Do not have commercially laundered”—do not employ a laundry which uses special formulations, sour rinses, extermely large loads or extermely high temperatures or which otherwise is employed for commercial, industrial or institutional use. Employ laundering methods designed for residential use or use in a self-service establishment.
  7. “Small load”—smaller than normal washing load.
  8. “Delicate cycle” or “gentle cycle”—slow agitation and reduced time.
  9. “Durable press cycle” or “permanent press cycle”—cool down rinse or cold rinse before reduced spinning.
  10. “Separately”—alone.
  11. “With like colors”—with colors of similar hue and intensity.
  12. “Wash inside out”—turn product inside out to protect face of fabric.
  13. “Warm rinse”—initial water temperature setting 90° to 110 °F (32° to 43 °C).
  14. “Cold rinse”—initial water temperature setting same as cold water tap up to 85 °F (29 °C).
  15. “Rinse thoroughly”—rinse several times to remove detergent, soap, and bleach.
  16. “No spin” or “Do not spin”—remove material start of final spin cycle.
  17. “No wring” or “Do not wring”—do not use roller wringer, nor wring by hand.
  18. Washing, Hand Methods:
  19. “Hand wash”—a process by which soil may be manually removed from products or specimens through the use of water, detergent or soap, and gentle squeezing action. When no temperature is given, e.g., “warm” or “cold”, hot water up to 150 °F (66 °C) can be regularly used.
  20. “Warm”—initial water temperature 90° to 110 °F (32° to 43 °C) (hand comfortable).
  21. “Cold”—initial water temperature same as cold water tap up to 85 °F (29 °C).
  22. “Separately”—alone.
  23. “With like colors”—with colors of similar hue and intensity.
  24. “No wring or twist”—handle to avoid wrinkles and distortion.
  25. “Rinse thoroughly”—rinse several times to remove detergent, soap, and bleach.
  26. “Damp wipe only”—surface clean with damp cloth or sponge.
  27. Drying, All Methods:
  28. “Tumble dry”—use machine dryer. When no temperature setting is given, machine drying at a hot setting may be regularly used.
  29. “Medium”—set dryer at medium heat.
  30. “Low”—set dryer at low heat.
  31. “Durable press” or “Permanent press”—set dryer at permanent press setting.
  32. “No heat”—set dryer to operate without heat.
  33. “Remove promptly”—when items are dry, remove immediately to prevent wrinkling.
  34. “Drip dry”—hang dripping wet with or without hand shaping and smoothing.
  35. “Line dry”—hang damp from line or bar in or out of doors.
  36. “Line dry in shade”—dry away from sun.
  37. “Line dry away from heat”—dry away from heat.
  38. “Dry flat”—lay out horizontally for drying.
  39. “Block to dry”—reshape to original dimensions while drying.
  40. “Smooth by hand”—by hand, while wet, remove wrinkles, straighten seams and facings.
  41. Ironing and Pressing:
  42. “Iron”—Ironing is needed. When no temperature is given iron at the highest temperature setting may be regularly used.
  43. “Warm iron”—medium temperature setting.
  44. “Cool iron”—lowest temperature setting.
  45. “Do not iron”—item not to be smoothed or finished with an iron.
  46. “Iron wrong side only”—article turned inside out for ironing or pressing.
  47. “No steam” or “Do not steam”—steam in any form not to be used.
  48. “Steam only”—steaming without contact pressure.
  49. “Steam press” or “Steam iron”—use iron at steam setting.
  50. “Iron damp”—articles to be ironed should feel moist.
  51. “Use press cloth”—use a dry or a damp cloth between iron and fabric.
  52. Bleaching:
  53. “Bleach when needed”—all bleaches may be used when necessary.
  54. “No bleach” or “Do not bleach”—no bleaches may be used.
  55. “Only non-chlorine bleach, when needed”—only the bleach specified may be used when necessary. Chlorine bleach may not be used.
  56. Washing or Drycleaning:
  57. “Wash or dryclean, any normal method”—can be machine washed in hot water, can be machine dried at a high setting, can be ironed at a hot setting, can be bleached with all commercially available bleaches and can be drycleaned with all commercially available solvents.
  58. Drycleaning, All Procedures:
  59. “Dryclean”—a process by which soil may be removed from products or specimens in a machine which uses any common organic solvent (for example, petroleum, perchlorethylene, fluorocarbon) located in any commercial establishment. The process may include moisture addition to solvent up to 75% relative humidity, hot tumble drying up to 160 °F (71 °C) and restoration by steam press or steam-air finishing.
  60. “Professionally dryclean”—use the drycleaning process but modified to ensure optimum results either by a drycleaning attendant or through the use of a drycleaning machine which permits such modifications or both. Such modifications or special warnings must be included in the care instruction.
  61. “Petroleum”, “Fluorocarbon”, or “Perchlorethylene”—employ solvent(s) specified to dryclean the item.
  62. “Short cycle”—reduced or minimum cleaning time, depending upon solvent used.
  63. “Minimum extraction”—least possible extraction time.
  64. “Reduced moisture” or “Low moisture”—decreased relative humidity.
  65. “No tumble” or “Do not tumble”—do not tumble dry.
  66. “Tumble warm”—tumble dry up to 120 °F (49 °C).
  67. “Tumble cool”—tumble dry at room temperature.
  68. “Cabinet dry warm”—cabinet dry up to 120 °F (49 °C).
  69. “Cabinet dry cool”—cabinet dry at room temperature.
  70. “Steam only”—employ no contact pressure when steaming.
  71. “No steam” or “Do not steam”—do not use steam in pressing, finishing, steam cabinets or wands.
  72. Leather and Suede Cleaning:
  73. “Leather clean”—have cleaned only by a professional cleaner who uses special leather or suede care methods.





Anna from Spain sent me an email to ask

“Do I need fabric testing”

This will depend on a number of things, but it is a good idea to protect you against law suits and potential issues. It also provides care label instructions that you can put on your clothes or products.

You should also refer to other blog posts on this topic, which you can find here: FABRIC TESTING or LAW for additional legal items you might need. 

For more video’s and answers to your own questions or problems, don’t forget to subscribe to our YouTube channel FASHION SERVICES HONG KONG



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Start a Business Series Part III: With Vicky of Fashion Services HK

Charlotte London does a blog on starting a fashion business. Part 3 is with Vicky, Fashion Services explaining factories, tech packs and manufacturing

This week I sat down with Charlotte, from Charlotte London, to help her out with a series of blog posts she is writing on starting a fashion business. She interviewed me about Tech Packs, sampling and manufacturing, among other things, as part 3 of her series.

Here is a little taste of the interview

Thank you so much for having us! First of all, what is your first and best tip for anyone who wants to start a fashion brand? This series is all about building a business, so any advice for any inspiring entrepreneurs?

Hi Charlotte. Well all successful businesses, whether they realize it or not, work on the system I teach in my Bootcamp. 3 C’s- Core Values; Customer Profile and Consistency. So my first tip is to be clear about why you’re building your business. Who you’re building it for, and how you are going to maintain consistency.

Consistency is the tricky one to implement and often the one people forget about. So start by defining what your core brand values are and how you plan to stick to them throughout the production process and beyond.

When building a brand every decision feeds into the next decision and then back to the first. No brand decision works in isolation. Since production is quite a large part of your process, make sure that your final product, does in fact, resonate with your initial brand message and keep this in mind throughout the production process.

If you want to read the rest of this interview, then head on over to Charlotte London, by clicking the link below.

Start a Business Series Part III: Sampling and Manufacturing: A Guest Post with Vicky of Fashion Services HK


Charlotte London does a blog on starting a fashion business. Part 3 is with Vicky, Fashion Services explaining factories, tech packs and manufacturing





If you’re looking to start a fashion brand, which doesn’t buy and resell products, then you’ll need to make something. That means dealing with factories and going through a sampling process. This is something that I get a lot of questions about, because it’s often misrepresented or not explained properly and needs some clarity on how things work.

So in this post, I’m going to give you a rundown of the sampling process and what you should be expecting at each stage. By the time you finish this post, you should have a clear outline of the sampling process, what you should ask for and what you should expect.


The point of the Sampling Process is to perfect the idea that you have, by getting samples from the factory or people that will produce your final products. In other words, you ask your factory to produce sample after sample, until you have the product you are happy with.

Create garments and clothing for your fashion brand. How To Create Tech Packs For Fashion, Tech Packs for clothing and apparel sampling and mass production.The time that this takes and the amount of samples you will need, depends on the quality of the information you give your factory at the beginning. The information given, is usually in the form of a Tech Pack, or Technical Pack. The quality of your Tech Pack will determine how much time, cost and stress you have throughout. I won’t cover Tech Packs here, since there are many posts already, but I do suggest you take a look at them thoroughly [you can find these listed below] , or if you want to do them yourself, have a look at my 268 page E-book Tech Packs for Fashion.

Essentially, your Tech Pack is at the start of this process and will give clear instructions to your chosen factory, on what they should make and how to proceed on your journey.

Although each product and brand are different, the stages that every sample goes through, from receiving your first sample to production, are the same. There are four key samples that you will receive during this process:

  • Initial Sample
  • Pre-Production Sample
  • Size Set
  • Production

I should note however, that if you have ever worked in retail you may have heard alternative names for them, such as ‘Red Seal’, ‘Salesman Sample’ or ‘Fit Sample’. These are just names that get bounced around or adopted by companies, but are in fact, the same as the four manufacturing terms above.

The product that you create your Tech Pack for, will go through these four sample stages as it moves from an idea to being mass produced and although there are only four samples to receive overall, the sampling process itself is a little more complicated.

Sampling and production for each garment will depend on many factors, such as your design and how complicated it is, or whether you are having an embellishment added, or a fabric specifically printed. But regardless of the design or the product, it all starts with a Tech Pack, and works as follows:

Technical Pack or Tech Pack for clothing apparel. What is inside a Tech Pack. Tech Pack template


Depending on how far away your factory is from you and what you need to send them, will determine how long this part of the process will take. If you have to send something physical, like a fabric swatch, then the post can’t be avoided and will obviously take longer to arrive at its destination, than an email. So this part can take anything from 5 minutes to a week.

However, part one of your journey is simply to send your Tech Pack to your chosen factory.

1st SAMPLE FROM THE FACTORYProblems and issues that happen when you get samples from a factory. How do you write comments or QC the samples? Closure doesn't match. Finished badly at the hem

After you send your Tech pack, you will receive a sample. This is called your Initial Sample. Factories can’t possibly have every single colour thread, or type of material, in stock and ready for your request. They have to order buttons, trims and anything else your design needs. So you have two options for your first sample. Speed or accuracy.

If your aim is speed and you just want to check the sample for fit alone, then the factory can substitute things like fabric and trims for a close substitute. The measurements will be a little rushed and you should expect a couple of them not to match your Tech Pack specifications.

If you can afford to wait for the proper components or want the exact match for everything you asked for, then you have to be prepared to give the factory some time. It will take longer to get your samples back, but it should be far closer to the product you want.

Overall you can expect a sample back in around ten days if it’s a simple design and you need a speedy return or anything up to three weeks for something more specific or complicated. In both cases, you will need to allow for postage time on top and possibly customs delays if your factory is overseas and the package they send you is very large.


Regardless of whether you have asked for speed or accuracy, you will need to check your sample properly against the specifications in your Tech Pack. This includes the design details, quality and measurements, as well as anything else you asked for in your Tech Pack, bearing in mind that as an initial sample, it may not be completely accurate.

If the sample is perfect, then apart from being really lucky, you’ll also be able to ‘Approve’ or ‘Sign Off’ the sample. Meaning that you tell the factory you are happy with it and they can move onto the next sample stage, or Pre Production Sample.

If you’re not happy, or there are corrections to be made, which is usually the case with a rushed Initial Sample, you will need to give comments on anything you want to change or improve. Terminology wise, this part is simply called ‘Comments’.

You should make some time to take photos of anything that is visible, as well as making written comments for every area that needs improvement or changes. Comments can be given to your factory via email, which is good enough for record keeping, but the preferred method is to make a copy of the original Tech Pack and add/change your notes, instructions or measurements, saving this new file with the current date on every sheet. Remember to highlight anything that is different or needs changing from the 1st Tech Pack you sent.

After your comments are received by the factory, they will make sample number 2.

The process of sending comments to the factory and then receiving other samples based on your new comments, will repeat until you are happy with your sample.


As a side note, factories tend to rush first samples in general, which means there will be mistakes, especially for the first sample. This is completely normal.

It will be up to you to check your sample properly and comment thoroughly on anything that needs improving. When the factory knows that you’re serious about placing an order with them, samples tend to be more accurate and Tech Packs get read more thoroughly.

If Tech Packs are done properly first time round and you give thorough comments about the first sample you receive, your second sample should be exactly what you want.  Your factory will correct anything that might have happened due to them rushing.

Really by sample 2, you shouldn’t have to do any more comments or ask for more samples. In the retail world, sample 2 should be exactly what you want and designers needing additional samples, don’t tend to last very long. Sampling costs money after all. However, mistakes and delays do happen, even to the most experienced designers or well-staffed brands, so it’s important to be realistic too. If you are new to sampling, you may need a couple more samples and comments. Don’t worry though. As you gain more experience, you’ll cut down the amount of samples you will need.

Branding for fashion brands. Create a fashion brand and focus on building your brand


Depending on the product you are making, you might have labels, swing tags, embroideries, prints, technical fabric effects, packaging, wash care labels and so on. Throughout the sampling process, you should be sending artwork for these items and asking for samples of these things too.

You should check each item for accuracy against the Tech Pack or artwork information you gave the factory.

Check each item specifically for:

  • Size
  • Layout
  • Placement
  • Colour
  • Quality
  • Finishing
  • Materials

There is no specific time that this part of your sampling process happens. Factories will arrange for these items to be sampled for you and they could arrive with your initial sample [which would be very unusual unless you wait a long time] or later on in the process. This will just depend on how efficient your factory is and how much you remind them about these items. But, like garments, you will have to either ‘Approve’ or ‘Sign Off’ each of these trims and components, or repeat the ‘sample and comment’ process, if you’re not completely happy.


Whatever sample you are happy with, second, third or so on, this sample is then Signed Off or Approved as you already know. The version that you have Approved, then becomes known as a Pre Production Sample and simply gets re-named, so you should only approve your sample [ making it a Pre Production Sample ] when you are completely happy with your product.

This sample should be complete with trims, prints and various other things you have Approved in your design process, however packaging and hangtags that are additional to the product, may or may not be included. This will depend on your factory.

If you have been working on your samples purely for the fit and your current sample does not include trims, prints and so on, you should request a full Pre Production Sample, complete with all details added.

Your Pre Production Sample is the one that all further samples will be compared to. It sets the standard for what you ask your factory to produce as a bulk order, so it is really important to check every measurement and detail. From this sample onwards, there shouldn’t be any more design or fit alterations and all further samples you receive are essentially there to double check production quality and grading for all other sizes.

This sample can also be called a Salesman Sample by suppliers, because it is traditionally the one shown to buyers for selling products.


From the Pre Production Sample onwards, you should be asking for at least two samples per garment, with all tags labels and so on.

One is for you to keep as a record of each sample stage. The second is to send out to buyers, press or anyone else you need to. Since samples have a habit of ‘going missing’ when you are sending them out to people, it’s important to always have an original somewhere just for you.

Larger retailers occasionally ask for multiple samples from the beginning of the sampling process and often ask for three samples rather than two, mainly because samples have to be in various meetings, or with various staff, at any one time. You can do this as well, but you may need to consider the cost of the additional samples, especially if you will be making changes or the factory do not get the sample right first time round.

Your factory will also make an additional sample which stays at the factory and is a record of fit for each sample stage. They keep this sample so that when you make your comments, the factory has an exact replica of the physical garment for reference. These are called Counter Samples. All samples sent to you and kept by the factory, are made at the same time, with the same fabric, same machines etc, so they are an exact match.

want to know more about sampling and manufacturing for garments. need to make garments for your clothing line. find out what a size set isSIZE SET

So now that you’re Pre Production Sample has been finalised and you are happy with your product, the next sample is about checking sizes rather than making further changes to design or fit.

Up to this point, you’ve been working with 1 size for sampling. What that size is, is your choice, but it will be consistent throughout the process. Now you need something called a ‘Size Set’, which is exactly how it sounds. You ask the factory to produce two samples in every size you are planning to manufacture. These samples then get sent to you and as before, you check each and every measurement.

If your Tech Pack has a Grading Sheet [a table of measurements given for every size], then the samples you receive should match the table in your Tech Pack.

At this stage of the process, it should be a simple case of confirming what has been written down. If you do need to make comments or changes, then you can still do so, but this shouldn’t be necessary at this stage.

Like the Pre Production Sample, these should be complete samples with all labels, tags etc…

Fashion buying and selling. If you want to sell your products you will need to know what a purchase order isPURCHASE ORDER

A Purchase Order [ or PO ] is the order that you place with your factory for them to manufacture your bulk garments. It is a legal contract between you and your factory and lists everything that you want them to make.

You should be as specific as possible in terms of fabrics, trims, sizes, delivery, payment options and so on, because once it is signed by you, there is no going back.

This is a legal and binding contract, so you need to make sure you triple check the details on it. You should never sign and send this document [which you have to create] until you haveapproved your samples, which includes all labels, swing tags, packaging etc…

I won’t go into the details of a PO here, but I should mention that there is an additional post BUYERS & WHOLESALE: WHAT’S A PURCHASE ORDER? And you can look at that HERE


Your Production Sample is the last sample that you will receive. It comes to you when you have placed your order with your factory for your mass or bulk production.

When the factory are making the garments you require for your order, they take two garments [ or as many as you request ] out of the production line, finished with packaging and labelling and send it to you for your records. Your Production Sample should be exactly what you are expecting and what you have placed an order for.

If there is something wrong with the production sample, [ which is shouldn’t happen at this stage if you have checked your garments properly throughout] you need to contact the factory immediately to stop the production.

As long as you have kept records of everything you Signed Off, the factory is liable for any remaking costs that might occur if they make a mistake. If you have Signed Off something that you don’t like, or change your mind, unfortunately this will be your responsibility to pay for and correct.

Your order or Purchase Order is a legal contract between you and your factory, so liability is solely down to who made the mistake and what was agreed.

clothing sizes. Size sets for garments


So now we have gone through the sampling process as a whole, including the Initial Sample, Comments, Pre Production Sample, PO and Production Sample, you should now have an overview of how you you will proceed with sampling.

It’s important to look through the additional notes and understand that this is an overview. Much of your time, cost and stress will depend on the quality of your Tech Packs; the attention you pay to checking your samples as well as the contact and relationship you have with your factory.

It’s important to know as well, that things like Purchase Orders and Tech Packs, have their own set of structures and regulations. You will need to research into many of these things to make sure that they are done well and in terms of the PO, you are legally covered and protected.

So in that vein, let’s move onto the actions steps

 Action Steps:

To help with further reading and developing your journey, here are some additional resources that you will find useful.



Question this week from Toodlepip toodlepip

“How do MOQs work with regards to sizing and colourways?”

An MOQ, or Minimum Order Quantity, is a number given by a fashion factory, or other factories. It tells you, the person about to make garments with them, how many products you have to order, minimum, to meet their requirements. Factories have all kinds of minimum quantities, so you need to find one that works for you, as well as what that MOQ includes. For example, does it include all sizes? Different colours?….

For more video’s and answers to your own questions or problems, don’t forget to subscribe to our YouTube channel FASHION SERVICES HONG KONG




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