Monday, January 22, 2018

TEXTILE RULES: Agency Information Collection Activities; Proposed Collection; Comment Request.

On January 22, 2018, the Federal Trade Commission published in the Federal Register (83 FR 2992) Agency Information Collection Activities; Proposed Collection; Comment Request.

The Textile Fiber Products Identification Act ("Textile Act") prohibits the misbranding and false advertising of textile fiber products. The Textile Rules establish disclosure requirements that assist consumers in making informed purchasing decisions, and recordkeeping requirements that assist the Commission in enforcing the Rules. The Rules also contain a petition procedure for requesting the establishment of generic names for textile fibers.

Estimated annual hours burden: 37,007,147 hours (782,600 recordkeeping hours + 36,224,547 disclosure hours).

Recordkeeping: Staff estimates that approximately 12,040 textile firms are subject to the Textile Rules' recordkeeping requirements. Based on an average burden of 65 hours per firm, the total recordkeeping burden is 782,600 hours.

:Disclosure: Approximately 10,744 textile firms, producing or importing about 20.8 billion textile fiber products annually, are subject to the Textile Rules' disclosure requirements. Staff estimates the burden of determining label content to be 65 hours per year per firm, or a total of 698,360 hours and the burden of drafting and ordering labels to be 80 hours per firm per year, or a total of 859,520 hours. Staff believes that the process of attaching labels is now fully automated and integrated into other production steps for about 40 percent of all affected products. For the remaining 12.48 billion items (60 percent of 20.8 billion), the process is semi-automated and requires an average of approximately ten seconds per item, for a total of 34,666,667 hours per year. Thus, the total estimated annual disclosure burden for all firms is 36,224,547 hours (698,360 hours to determine label content + 859,520 hours to draft and order labels + 34,666,667 hours to attach labels). Staff believes that any additional burden associated with advertising disclosure requirements or the filing of generic fiber name petitions would be minimal (less than 10,000 hours) and can be subsumed within the burden estimates set forth above.

Estimated annual cost burden: $239,778,909 (solely relating to labor costs).

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