Competition Bureau
Guide to the Labelling of Down and FeathersMarch 2000
I. INTRODUCTION
V. FALSE AND/OR MISLEADING REPRESENTATIONS ON PLUMAGE PRODUCTS
VI. DEALER IDENTITY APPENDIX A LIST OF PLUMAGE RELATED DEFINITIONS I. INTRODUCTIONThe purpose of these guidelines is to clarify the requirements for the labelling of down and feather filled consumer textile articles under the Textile Labelling and Advertising Regulations. This information should be read in conjunction with the appropriate sections of the Textile Labelling Act and Textile Labelling and Advertising Regulations which will govern. Printed copies of the Textile Labelling Act and Textile Labelling and Advertising Regulations may be obtained for a fee at the following address:
Electronic copies of the Act and Regulations are available at: II. THE IMPORTANCE OF ACCURATE LABELLING OF PLUMAGE PRODUCTSAccurate labelling of down and/or feather-filled consumer textile articles is of importance to both consumers and dealers; it not only enhances the ability of consumers to differentiate among product choices, but protects both consumers and dealers against product misrepresentation. Down fillings, feather fillings and down and feather-filled blends not only differ in cost but also in quality. Therefore, it is important that manufacturers and importers verify the accuracy of the labelling on shipments of fill and/or plumage-filled articles, as the differences in the cost and quality of goods ordered and those actually received may be substantial. In cases where the accuracy of the fibre content labelling has not been verified by the manufacturer or importer, both manufacturers and consumers may be paying a premium price for goods of lesser quality. A documented quality control system will help ensure the accuracy of the fill and/or articles. Quality assurance aims above all at preventing non-conformity. It allows the company to promptly detect cases of noncompliance, correct them and prevent their reoccurrence. A good quality control program leads to cost savings. It is also suggested that identifying numbers or codes, such as lot numbers, be provided on the product label. This makes the identification of the supplier or manufacturing line easier and assists in separating product lines should corrections be required. III. PROPERTIES OF DOWN AND FEATHERS"Down" is the undercoating of waterfowl (goose, duck or swan) and consists of light, fluffy filaments growing from a central quill point, thereby creating a three dimensional structure which traps air and gives down insulating ability. The properties of down which make it so popular are its light weight, compressibility, recovery power, resilience and breathability. DOWN "Feathers" are the individual horny structures which form the outer body covering of birds and consist of a quill point, quill shaft, vanes and usually an aftershaft. Feathers share the same properties as down, however, since they are two-dimensional structures, they do not trap air as efficiently and are, therefore, generally not as good insulators. As a rule, waterfowl feathers are superior to landfowl feathers with respect to both filling power and resilience. FEATHER IV. LABELLING OF PLUMAGE PRODUCTS
A dealer is permitted by the Regulations to label a plumage product as "down" if it meets either the appropriate definition for "down" or for "commercial down" (see items d) or j) of Appendix A). The definition of "commercial down" incorporates realistic tolerances, which are intended to accommodate the imprecise nature of processing and manufacturing non-homogeneous down and feather mixtures. The tolerances are not to be construed to permit intentional adulteration. The declaration "down" may not be preceded by words or figures indicating one hundred percent on a plumage product filled with "commercial down". In addition, the declaration "down", in such products, must be accompanied by the following statement:
The purpose of this statement is to alert the consumer to the fact that a product labelled as "down" may nonetheless contain some feathers. This statement should not be used on products containing a blend of down and feather.
The Regulations allow a dealer to label feather-filled products as "feather" if it meets the appropriate definition for "commercial feather" (see items g) or k) and l) of Appendix A). The definition, which incorporates realistic tolerances, intended to accommodate the imprecise nature of processing and manufacturing non homogeneous feather and down products and not intentional adulteration, can be used whether the feather is used by itself or in a blend. The declaration "feather" on a label must always be preceded by the word "waterfowl", "landfowl" or "the name of the bird" of origin, whichever is preferred, due to the differences in quality and price between the different types of feathers. The definition for "commercial feather" incorporates realistic tolerances. Therefore, the declaration "feather" may not be preceded by words or figures indicating one hundred percent in a plumage product filled with "commercial feather".
The statement "down blend" may refer to a blend of different species of down, ie., duck and goose, or to a blend of down and polyester or some other fibre. The usual 5% tolerance which applies to the percentage disclosures on blends does not apply to blends of commercial down and/or feather. This prevents a double tolerance from applying to blends of down and/or feather: firstly a tolerance on the composition of both the down and feather; and secondly, a general tolerance on blends. The 5% tolerance does apply, however, to blends of commercial down and any other fibre except feather, for example, a blend of commercial down and polyester. 4. Crushed Feathers"Crushed feathers" are feathers which have been processed by a curling, crushing or chopping machine which has changed the original form of the feather without removing the quill. Crushed feathers do not come under the definition for residue (see item i) of Appendix A). Articles filled with crushed feathers should be disclosed as:
When down or any other fibre which is required to be shown by its generic name is a reclaimed fibre, the word "reclaimed", "reprocessed" or "reused" must be shown immediately preceding the generic name. Examples of labels for plumage products have been provided in Appendix B. The fibre content information is required to be bilingual unless the article is sold in an area where only one official language is used by consumers when making purchases. V. FALSE AND/OR MISLEADING REPRESENTATIONS ON PLUMAGE PRODUCTSSection 5 Act False or misleading representations in the labelling of consumer textile articles are prohibited by section 5 of the Textile Labelling Act. False or misleading representations include:
Whenever a statement as to the bird of origin of down or feathers is made, the plumage must be at least 90% from the stated bird. For example, if a label refers to down as "duck down" and the product contained less than 90% duck plumage, it would be considered false and misleading. Furthermore, if a label states "eider duck down", 90% of the plumage must be from the eider duck.
It is clearly misleading to label products containing commercial down, commercial waterfowl feather or commercial landfowl feather as "100%", "pure" or "all" down or feather, when tolerances are permitted due to the practical commercial difficulty of obtaining "pure" down or feathers; therefore using these words is prohibited on these products. Only when the down or feather meets the generic definitions (an unlikely situation) can the modifiers "100%", "pure" or "all" be used.
Articles in which the body fill is down but other sections such as the sleeves, hood, collar or pocket are filled with another material and in which these latter sections could be mistaken for down due to their appearance, should not be labelled as "down-filled". It would be considered false and misleading to label the product as "down-filled" unless it is clear that it is only the body of the garment which is down-filled, e.g., "body down filled". 4. Expressions such as "Down-like"If an expression such as "down-like" is used to describe a product and the product does not have some of the properties of a down product, the expression would be considered misleading. If the product does in fact have some of the properties of a down product, the expression "down-like" may be used to describe the product as long as there is a clear indication that the fill is not down, e.g., "down-like polyester fibrefill". The misleading advertising and deceptive marketing practices provisions of the Competition Act may also apply. Generally speaking these provisions prohibit making a materially false or misleading representation for the purpose of promoting a product or business interest. Table of Contents
Dealer identity information is also required on the label. This information consists of the name and complete postal address of the manufacturer, processor, finisher, importer or retailer. Alternatively, a dealer residing in Canada may purchase a registered identification number commonly known as a CA number, and use this number as dealer identity information in lieu of the full name and address on the label. A CA number can be obtained from most Competition Bureau, Industry Canada offices.
Dealers involved in the advertising of down-filled and/or feather-filled consumer textile articles should consult The Guide to the Advertising of Consumer Textile Articles. VIII. PRODUCT TESTINGFor product testing of down and feathers, there is only one known Canadian laboratory which does such testing on a commercial basis. For further information please contact:
IX. PROVINCIAL UPHOLSTERED AND STUFFED ARTICLES LEGISLATIONAll manufacturers of upholstered or stuffed articles (furniture, pillows, outerwear, etc.) whose goods are destined for sale in the provinces of Ontario, Quebec or Manitoba should contact the respective office listed in Appendix C. X. FURTHER ASSISTANCECopies of our other publications and further assistance concerning the labelling of down and feathers may be obtained from your nearest Competition Bureau office of Industry Canada listed in Appendix D. Also electronic copies can be obtained from our Internet site or by E-mail. Internet: http://www.cb-bc.gc.ca APPENDIX ALIST OF PLUMAGE RELATED DEFINITIONS(Reference Section 25 and 26 of the Textile Labelling and Advertising Regulations) a) Plumage b) Landfowl Plumage c) Waterfowl Plumage d) Down e) Down Fibre f) Plumule g) Feather h) Feather Fibre i) Residue j) Commercial Down
where the components referred to in paragraph b) to d) do not exceed 25% of the plumage. k) Commercial Landfowl Feather
l) Commercial Waterfowl Feather
APPENDIX BEXAMPLES OF LABELS FOR PLUMAGE PRODUCTSa) An acceptable disclosure label for a down filled nylon ski jacket would be as follows:
The down filling of a product labelled as above must conform to the following composition requirements:
b) An acceptable disclosure label for a 50% down and 50% waterfowl feather filled nylon ski jacket would be as follows:
The fill for a product labelled as above must conform to the following composition requirements:
NOTE: No additional tolerance is allowable on a blend of down and feathers
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| Outer Shell: | 100% nylon | Extérieur : | 100 % nylon |
| Fill: | 50% down 50% polyester |
Remplissage : | 50 % duvet 50 % polyester |
| CA00000 | |||
The fill for this product must conform to the following composition requirements:
| a) polyester | 45.0% to 55.0% |
| b) down and plumules | 32.5% to 42.5% |
| c) waterfowl feathers not more than 60 mm in length | 17.5% maximum |
| d) waterfowl feather fibre and down fibre | 5.0% maximum |
| e) residue | 2.5% maximum |
NOTE: An additional tolerance of plus or minus 5% has been incorporated on the blend of polyester and down (see section IV, item 3, "Labelling of Plumage Products - Down Blends").
APPENDIX C
OFFICES DEALING WITH THE PROVINCIAL REQUIREMENTS
FOR UPHOLSTERED AND STUFFED ARTICLES
| Location | Location | Telephone and Fax # |
|---|---|---|
| Quebec | Ministère de l'Industrie, du Commerce, de la Science et de la Technologie Direction du développement des réseaux commerciaux 380 ouest, rue St-Antoine 4e étage Montréal, (Québec) H2Y 3X7 |
Tel: (514) 499-2176 Fax: (514) 499-2191 |
| Ontario | Technical Standards and Safety Authority Upholstered and Stuffed Articles Program 3300 Bloor Street West The Mutual Group Centre, 4th Floor West Tower Etobicoke, Ontario M8X 2X4 |
For labelling: Tel: (416) 325-0381 Fax: (416) 326-8248 For registration |
| Manitoba | Consumer's Bureau Dept. of Consumer and Corporate Affairs 258 Portage Avenue, Room 302 Winnipeg, Manitoba R3C 0B6 |
Tel: (204) 945-3800 Fax: (204) 945-0728 Toll free in Manitoba |
APPENDIX D
COMPETITION BUREAU, INDUSTRY CANADA OFFICES
E-Mail: compbureau@cb-bc.gc.ca
Internet: http://www.cb-bc.gc.ca
| Region | Location | Telephone and Fax # |
|---|---|---|
| Atlantic | 50 Brown Avenue Burnside Industrial Park Dartmouth, Nova Scotia B3B 1X8 |
Tel: (902) 426-5422 Fax: (902) 426-1000 |
| Quebec | 6850 Sherbrooke East 1st Floor Montreal, Quebec H1N 1E1 |
Tel: (514) 283-3109 Fax: (514) 283-3834 |
| Ontario | 151 Yonge Street 4th Floor Toronto, Ontario M5C 2W7 |
Tel: (416) 954-2608 Fax: (416) 973-5092 |
| Prairie | 400 St Mary Ave. 4th Floor Winnipeg, Manitoba R3C 4K5 |
Tel: (204) 983-8905 Fax: (204) 983-5511 |
| Pacific | 300 West Georgia Street Room 2000 Vancouver, B.C. V6B 6E1 |
Tel: (604) 666-2191 Fax: (604) 666-6111 |
| National Capital | Phase 1, Place du Portage 17th Floor 50 Victoria Street Hull, Quebec K1A 0C9 |
Toll free: 1-800-348-5358 Tel: (819) 997-4282 Fax: (819) 997-0324 |
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Created: 2000-03-01 Updated: 2005-05-17 |
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