ACT Supports FTC Action on Digital Care Labels
Federal Trade Commission Public Comment: Digital Labeling and the Care Labeling Rule
Submitted by: American Circular Textiles (ACT)
April 18th, 2025
On behalf of American Circular Textiles (ACT), I am submitting this comment in response to the Federal Trade Commission’s (FTC) request for public input regarding the AAFA-initiated petition to allow for digital compliance with the Care Labeling Rule. American Circular Textiles (ACT) is a first-of-its-kind coalition representing over thirty leading companies working across the U.S. circular textile and domestic manufacturing economy. Our membership spans the value chain, from apparel and footwear brands, used clothing collection, resale, recycling, innovative technology, and U.S. manufacturing. We are united in advancing policy that creates sustainable jobs, educates consumers, and reduces textile waste.
As an organization focused on developing policy solutions that promote transparency, driving domestic economic growth, and supporting environmental responsibility, ACT recognizes digital labeling as a critical inflection point. The AAFA petition proposes that the FTC modernize the Care Labeling Rule to permit digital formats, such as QR codes or web links, to communicate required care instructions. The petition highlights increased consumer convenience, environmental savings, and business cost reductions.
ACT agrees with this direction and encourages the FTC to initiate rulemaking that requires digital labeling. ACT urges the FTC to also consider the broader systemic value of digital labeling as it relates to consumer protection and market integrity, while aligning with broader national priorities.
By supporting digital labeling initiatives, the FTC has the opportunity to expand its leadership in safeguarding consumers and promoting fair competition. To that end, we encourage the FTC to evaluate the role digital labeling can play in advancing four key outcomes:
Standardization of Recycled Content in Textiles and Enabling Traceability: While the FTC’s Green Guides offer important guidance on recycled content claims, they do not currently address textiles specifically, leaving the opportunity to standardize what constitutes "recycled content" in textiles in a gray area. Currently, marketers may label garments as recycled without disclosing source material, percentage, or claim substantiation, leading to consumer confusion, enabling greenwashing, and distorting fair competition.
Digital labeling offers a powerful solution to help businesses and consumers understand what a recycled claim actually means. Labels can embed verifiable information such as the type of recycled content (e.g., post-consumer or post-industrial), the source material (e.g., plastic bottles, old garments, factory scrap), and its percentage of the total content.
By making this information accessible at the product level, digital labeling not only supports truthful marketing but also holds brands accountable for a consistent standard of transparency. Additionally, digital labeling enables the FTC to gather real-time data on what materials are being used and claimed as recycled content in textiles. This visibility can inform future rulemaking, improve enforcement, and strengthen consumer trust and fair competition in the marketplace.
Extending Product Life and Improving Consumer Access to Information: Many garments are discarded prematurely simply because consumers lack access to care, repair, and reuse services or don’t know where to find them. Digital labeling can help close this gap by linking consumers directly to care instructions, repair resources, resale platforms, and textile recycling locations.
Digital labels can play a key role in making this information readily available throughout a product’s lifecycle. They empower consumers to care for and rewear garments longer, repair what they own, and resell or donate what they no longer want, reducing waste and stretching product value.
By embedding lifecycle guidance and material data directly into garments, digital labeling gives consumers access to clear, detailed, product-specific information that enables them to make informed, responsible decisions, while creating the foundation for accurate labeling across the industry.
Supporting the Advancement of Domestic Infrastructure for Textile Reuse and Recycling: The U.S. lacks scalable infrastructure to sort, repair, and recycle textiles, resulting in overreliance on exports, increased landfill use, and the potential for missed opportunities to grow domestic economic activity. With the growing textile recycling sector, there is a timely opportunity to invest in U.S.-based infrastructure in this sector. Digital labeling can help accelerate this growth by providing standardized, detailed product data that allows current and emerging reuse and recycling operators to sort garments more accurately and determine their next best use.
A major barrier to textile recycling is the lack of accessible information about fiber content, chemical treatments, dyes, and non-textile components. Most physical labels are removed after purchase and lack the space to include these critical details. Without this data, sorters and recyclers often discard otherwise recoverable textiles or export them to countries with insufficient waste systems, which limits sorters and recyclers' ability to provide traceability and accountability to consumers concerning where their clothing is going after donation or resale. According to the U.S. Environmental Protection Agency (EPA), in 2018, the United States generated approximately 17 million tons of textile waste. Of this amount, only 2.5 million tons were recycled, resulting in a recycling rate of about 14.7%. The remaining textiles were either landfilled or combusted with energy recovery.
Digital labels can close this gap by embedding verifiable material information directly into garments, supporting accurate sortation, enabling emerging recycling technologies, and improving transparency at end-of-life. In doing so, they strengthen consumer trust and help build a domestic recycling system that is efficient and accountable.
While the FTC does not manage recycling infrastructure, its support for digital labeling can facilitate the conditions needed to scale these systems nationwide. This would support traceability while also enabling domestic job creation in this sector and accurate material recovery.
Supporting Global Competitiveness and Regulatory Alignment. As global markets shift toward greater product transparency, this presents an important opportunity for U.S. businesses to compete and lead. In 2023, the United States exported approximately $884 million worth of apparel products to Europe. Regulatory frameworks like the EU’s Digital Product Passport and California’s SB 707 are already setting expectations for traceable disclosures.
By empowering digital labeling, the FTC can help establish a common standard that aligns the U.S. framework with the existing EU Digital Product Passport and upcoming U.S. state regulations, reducing friction for U.S. businesses engaged in international trade and strengthening domestic rulemaking in the process.
Digital labeling is not just a tool for compliance, it is a strategic investment in a more innovative, accountable, competitive, and modern marketplace that empowers companies to create incentives for U.S. leadership.
Recommendations
Support the inclusion of product-level data such as fiber content, chemical additives, and finishings, critical for claim substantiation, consumer protection, and recycling.
Engage the circular value chain, including collectors, recyclers, secondhand platforms, and repair providers, in developing digital labeling standards to ensure alignment with real-world infrastructure.
Ensure interoperability with emerging domestic and international frameworks, including the EU Digital Product Passport and U.S. state-level EPR programs.
Digital labeling presents a critical opportunity to modernize the Care Labeling Rule in a way that strengthens consumer protection, supports fair competition, advances domestic innovation, and aligns with global policy expectations. It also aligns with broader national priorities: enabling domestic job creation in manufacturing and strengthening U.S. competitiveness in a rapidly evolving global apparel economy.
ACT urges the Commission to move forward with rulemaking that enables digital labeling while ensuring these tools serve the public interest and promote a more transparent, circular textile economy.
Warmly,
Rachel Kibbe
CEO and Founder, American Circular Textiles (ACT)