The Fur Products Labeling Act (Fur Act) prohibits the misbranding and false advertising of fur products. The Fur 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 provide a procedure for exemption from certain disclosure provisions under the Fur Act.
The Federal Trade Commission is requesting a change from its burden estimate of
168,098 hours under its current OMB clearance up to 249,541 hours, partially from a program change and partially from an upward adjustment. The program change derives from recent statutory amendments to the Fur Act by Congress which eliminated the Commission's power to exempt from the labeling requirements items where either the cost of the fur trim to the manufacturer or the manufacturer's selling price for the finished product is less than $150. This accounts for part of the increase in the number of garments subject to the Fur Act and Rules (1,610,000 in 2015 and 1,336,000 in 2011), which imposes higher recordkeeping and labeling costs on manufacturers, importers, and retailers. In addition, sales of fur garments that would not have fallen under the exemption increased.
There was also an upward adjustment derived from updated compliance estimates provided by Fur Information Council of America for recordkeeping and disclosure. For example, it is estimated that entities spend more time on average complying with disclosure requirements that determine label content (30 hours per year in 2015 and 26 hours in 2011) and for drafting and ordering disclosure labels (10 hours in 2015 and 7 hours in 2011).
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Fur SS - 2015 - FINAL.pdf
Recordkeeping-Manufacturers and Fur Processors