Labeling of products composed of ground leather and fabric
76 F.T.C. 1119 · Nov. 18, 1969 · Digest No. 391
source volume section (76 F.T.C. 1119)
Text is machine-OCR of the printed volume and may contain errors. Advisory opinions are the Commission's views on proposed conduct, not binding orders.
No. 391. Labeling of products composed of ground leather and fabric.
The Commission is of the opinion that a product which consists of reconstituted leather applied to a fabric base may not be described as "leather" without proper qualification and may not be described as "genuine mil1ed leather, This product may not be described as "leather" unless the word is accompanied by a clear statement as to the product' s true composition. The tenn "leather" used alone means top grain leather and the product referred to, composed of ground leather on a fabric backing, does not come within such a definition. The use of the unqualified term "leather" to describe such product would tend to deceive prospective customers and possibly vioJate Section 5 of the Federal Trade Commission Act.
The product may not be described as "genuine miled leather with or without qualification. It is not clear what is intended by the word "mi1ed" but the phrase as a whole suggests top grain leather in a manner which would make any attempted qualification a contradiction in terms. Use of this phrase would tend to mislead and deceive prospective customers as to the true composition of the product and might violate the Federal Trade Commission Act. The close resemblance of the product to leather may tend to mislead prospective purchasers into the belief that the product is top grain leather. Accordingly, the product should be labeled to indicate its true composition or, optionally, that it is imitation or simulated leather or nonleather.
Finally, the backing of the product appears to be a textile fiber product subject to the Textile Fiber Products Identification Act, and, accordingly, certain information must be disclosed as to the composition of such fabric.
The product may be described appropriately in a number of ways, among which are the following;
Ground leather laminated to fabric (60 percent polyester, 40 percent rayon). Shredded leather laminated to fabric (60 percent polyester, 40 percent rayon) .
Pulverized leather laminated to iabric (60 percent polyester , 40 percent rayon) .
Imitation leather laminated to fabric (60 percent polyester , 40 percent rayon) .
Simulated leather laminated to fabric (60 percent polyester , 40 percent rayon) .
Nonleather fabric backing (60 percent polyester, 40 percent rayon). (File No. 703 7019 Released November 18, 1969)