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Guide to the Labelling of Stuffed or Filled Textile Articles

June 28, 2019

This guide is intended to help dealers of consumer textile articles containing filling or stuffing (Stuffed or Filled Articles) understand their labelling obligations under the Textile Labelling Act (TLA) and Textile Labelling and Advertising Regulations (TLAR).

The Competition Bureau is the independent law enforcement agency responsible for enforcing the TLA and TLAR.  The TLA and TLAR set out labelling requirements for most consumer textiles sold in Canada to ensure that Canadians have access to the information they need to make informed purchasing decisions.

Ontario, Manitoba, and Quebec also regulate the labelling of Stuffed or Filled Articles. These provincial regulations are in addition to the federal labelling requirements and do not replace the TLA and TLAR requirements. Dealers selling in these provinces must ensure their Stuffed and Filled Articles have labels that meet both federal and provincial requirements.

Ontario is repealing its Upholstered and Stuffed Articles Regulation on July 1, 2019, and Manitoba will repeal its Bedding and Other Upholstered or Stuffed Articles Regulation on January 1, 2020. These changes do not affect the TLA or TLAR. Dealers must still comply with federal labelling requirements as well as any other consumer product safety and protection laws.

How should my stuffed or filled article be labelled?

A dealer must attach a federal label to their Stuffed or Filled Articles unless they are exempt from the TLAR. When deciding how to label, the dealer must consider each textile part of the Stuffed or Filled Article. These generally fit into three broad categories:

  1. Outer covering and shell

    The fibre content of an article's outer covering and shell must always be disclosed on the federal label. Examples of articles with an outer covering or shell include pillows, mattresses, or winter jackets.

  2. Findings

    Findings are textile fibre parts added to a textile article for a functional purpose other than filling, stuffing or providing warmth. Examples include zippers or padding. These do not require disclosure of fibre content on the federal label.

    However, if a dealer chooses to make a claim or representation about the findings (e.g. "the padding in this costume is made entirely of polyester"), then the fibre contents of the findings must be disclosed on the federal label. This does not apply if the representation is made as part of a provincial label.

    Linings and interlinings used for warmth are not findings and their fibre composition must be stated on the federal label.

  3. Stuffing or filling

    The fibre composition of an article's stuffing or filling must be disclosed on the federal label unless the filling or stuffing is used in one of the following articles:

    • mattresses
    • box-springs
    • cushions
    • chair pads
    • pot holders
    • oven mitts
    • place mats
    • mattress protectors, or
    • upholstered furniture

    However, if a dealer chooses to make a claim or representation about stuffing or filling used (e.g. "this pillow is stuffed with cotton wadding") in one of the above articles, then the fibre content of the stuffing or filling must be disclosed on the federal label. This does not apply if the claim or representation is made as part of a provincial label.

The below flow chart is intended to help dealers label their Stuffed and Filled Articles.

A flow-chart detailing the procedure for labelling stuffed and filled articles. Text version below.

  • Flow Chart

    Procedure for labelling stuffed and filled articles: to begin, is the stuffed and filled article exempt from TLAR (for example, a stuffed toy)?

    • If yes, then no federal label is required.
    • If not, then we must determine what parts of the stuffed and filled article require a label.
      • If the article is an excluded article (i.e. mattress, box spring, cushion, chair pad, pot holder, oven mitt, placemat, mattress protector, or upholstered furniture), then a label must be applied to the textile outer covering and shell.
        • Additionally, a label must be applied to the stuffing and filling, but only if a claim is made, as well as the textile findings, but again, only if a claim is made.
      • If the article is any other stuffed or filled article (i.e. not an excluded article), then a label must be applied to the textile outer covering and shell, as well as to the filling and stuffing.
        • Additionally, a label must be applied to the textile findings, but only if a claim is made.

What does my label need to say?

At minimum, a federal label must disclose:

  • the fibre content, in percentages, of each part of the textile article in both English and French; and
  • the dealer identity (CA number, or name and postal address).

Information setting out the fibre content of findings, stuffing or filling must be separate and listed after the fibre content of the rest of the article.

Examples of federal labels to help dealers understand what they should look like are provided below.

Please refer to the Bureau's Guide to the Textile Labelling and Advertising Regulations for more details regarding dealers' obligations and the labelling requirements for textile articles subject to the TLA and TLAR.

TLA compliant label (excluded article)

  • TLA compliant label (excluded article)

    A TLA compliant label indicating that for an excluded article, the label must note what the fibre content is for the outer covering only, provide the generic fibre name and composition of the outer covering (i.e. 50% Cotton, 50% Nylon), and include the dealer's name/address or their CA number.

TLA compliant label (non-excluded article)

  • TLA compliant label (non-excluded article)

    A TLA compliant label indicating that for non-excluded article, the label must note what the fibre content is for the outer covering only, provide the generic fibre name and composition of the outer covering (i.e. 50% cotton, 50% Nylon), note a separate fibre disclosure for filling only, provide the fibre name and composition for the filling (i.e. 80% Cotton, 20% Nylon), and include the dealer's name/address or their CA number.

TLA compliant label (non-excluded article with findings)

  • TLA compliant label (non-excluded article with findings)

    A TLA compliant label indicating that for a non-excluded article with findings, the label must note what the fibre content is for the outer covering only, provide the generic fibre name and composition of the outer covering (i.e. 50% cotton, 50% Nylon), note a separate fibre disclosure for filling only, provide the fibre name and composition for the filling (i.e. 80% Cotton, 20% Nylon), note a separate fibre disclosure for findings only, disclose the generic fibre name and composition of the findings (i.e. 100% Polyester), and include the dealer's name/address or their CA number.

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