How to label bamboo viscose under FTC and UK textile rules

Bamboo viscose labelling in the US and UK

Bamboo viscose is rayon made using bamboo as the plant source, not fibre taken directly from the bamboo plant. US sellers must name this fibre rayon or viscose. "Made from bamboo" may be added if it is true, but the fabric may not be called bamboo unless it is actual bamboo fibre (FTC bamboo guidance, FTC labelling advice). On a UK composition label the name is "viscose", not "bamboo" or "rayon" (Annex I).

Rayon vs viscose bamboo

For bamboo viscose, rayon and viscose mean the same material. The FTC calls them "the same thing" (FTC). Its labelling guide explains that viscose is the ISO name for the main form of rayon: "You may use either name" (FTC, Threading Your Way). So "rayon derived from bamboo" and "viscose derived from bamboo" describe the same fibre, and either way the name and any plant-source wording must follow the labelling rules (FTC labelling advice).

The US rule for rayon made from bamboo

A label must give the generic name of each fibre present at 5% or more of total fibre weight (16 CFR 303.6). Section 303.7 defines rayon as "a manufactured fiber composed of regenerated cellulose" and incorporates the generic names in ISO 2076:2013(E) (16 CFR 303.7).

You can add a truthful descriptive term beside the generic name (16 CFR 303.16(d)). For bamboo-based rayon, the FTC gives "rayon (or viscose) made from bamboo" as permitted wording. Only textiles made directly from actual bamboo fibre can be called bamboo (FTC). Such fibre is often called "mechanically processed bamboo" (FTC labelling advice).

For a product made entirely of this fibre, "100% viscose", "100% viscose made from bamboo" or "100% rayon made from bamboo" follows that pattern. "100% bamboo" does not. Confirm the composition before a 100% claim, and the plant source before any bamboo wording (FTC labelling advice).

Product titles and environmental claims

But a correct fibre-content label doesn't fix a misleading product title. The FTC says it is "a mistake" to think a rayon label permits unqualified "bamboo" titles and descriptions (FTC blog). On the product, extra wording must not be false or misleading (16 CFR 303.16(c)).

Environmental claims need evidence too. In its 2022 enforcement announcement, the FTC said converting bamboo to rayon uses toxic chemicals and emits hazardous pollutants (FTC, 2022). Its guidance requires competent and reliable evidence: "Relying on other people's claims isn't substantiation." A supplier's assertion alone is not enough; obtain evidence that supports the claim (FTC labelling advice).

FTC bamboo penalties

The FTC warned 78 retailers in February 2010, including Wal-Mart, Target and Kmart (FTC warning letters). Later penalty cases show the risk for sellers:

• January 2013: four retailers agreed to $1.26 million in penalties. Sears, including Kmart, accounted for $475,000, Amazon $455,000, Macy's $250,000 and Leon Max $80,000 (FTC).
• December 2015: Bed Bath & Beyond, Nordstrom, J.C. Penney and Backcountry.com agreed to $1.3 million in penalties. They had received warning letters in 2010 (FTC).
• April 2022: the Department of Justice filed complaints and proposed orders that would require Kohl's to pay $2.5 million and Walmart $3 million. The FTC described that proposed penalty as its largest-ever civil penalty for bogus bamboo marketing (FTC).

The 2022 complaints also challenged environmental claims. Kohl's advertised products as "Produced free of harmful chemicals, using clean, non-toxic materials" (Kohl's complaint). Walmart used "eco-friendly & sustainable" (Walmart complaint).

What bamboo lyocell means

Lyocell is not the viscose process. Under US rules it is still a type of rayon: cellulose precipitated from an organic solution, with no hydroxyl substitution and no chemical intermediates. "Lyocell" may be the generic name (16 CFR 303.7(d)).

The FTC has not given "lyocell made from bamboo" as an example. That wording can still follow the lyocell definition plus a truthful description beside the generic name (16 CFR 303.16(d)). Use it only when the supplier documents a solvent process and a bamboo source. If the process is undocumented, do not guess lyocell or viscose.

Viscose from bamboo on UK labels

Under the UK text of Regulation 1007/2011, only names listed in Annex I may describe fibre compositions on labels and markings (Article 5). Annex I includes viscose, modal, cupro and lyocell. It has no entry for bamboo or rayon (Annex I). Actual bamboo fibre has no listed name either. A fibre not yet listed may be called "other fibres". In Great Britain an application for a new name goes to the Secretary of State (Regulation 1007/2011).

For an all-viscose product, use "100% viscose" on the composition line. A trade mark or company name may sit next to that line. Other information has to be displayed separately. Read together, Articles 5 and 16 support keeping any truthful "from bamboo" claim off the composition line. Check that placement with Trading Standards or your Primary Authority. The composition must be visible before purchase, including online. In Great Britain the labelling must be in English (Article 16).

Making a product available in Great Britain in breach of the provisions listed in the 2012 regulations is an offence, punishable by a fine, with a due diligence defence. Local weights and measures authorities (Trading Standards) enforce it in Great Britain (SI 2012/1102).

These naming points follow the FTC guidance, the US lyocell definition and the UK text of Articles 5 and 16. RegAffairs AI's bamboo viscose answer links to the source documents behind its labelling advice.