ANALYSIS OF PROPOSED CONSENT ORDER
TO AID PUBLIC COMMENT

The Federal Trade Commission has accepted, subject to final approval, an agreement to a proposed consent order from Design Zone, Inc. The agreement would settle a proposed complaint by the Federal Trade Commission that Design Zone violated the Textile Fiber Products Identification Act and engaged in unfair or deceptive acts or practices in violation of Section 5(a) of the Federal Trade Commission Act.

The proposed consent order has been placed on the public record for sixty (60) days for reception of comments by interested persons. After sixty (60) days, the Commission will again review the agreement and the comments received and will decide whether it should withdraw from the agreement or make final the agreement's proposed order.

This matter concerns country-of-origin labeling practices relating to the sale of cotton t-shirts and other textile wearing apparel. The proposed complaint charges that Design Zone removed labels saying "Made in China" from t-shirts manufactured in China and substituted labels containing the statement "Made in USA" or, in some instances, added the "Made in USA" labels without removing the "Made in China" labels.

The proposed consent order contains provisions designed to prevent Design Zone from engaging in similar acts and practices in the future. Part I of the proposed order prohibits Design Zone from misrepresenting, in any manner, the extent to which t-shirts or other items of textile wearing apparel are made in the United States or any other country. It further prohibits it from violating any provision of the Textile Fiber Products Identification Act.

The proposed order also contains standard provisions regarding record-keeping, notification of changes in corporate status, distribution of the order, termination of the order, and filing of a compliance report.

The purpose of this analysis is to facilitate public comment on the proposed order, and it is not intended to constitute an official interpretation of the agreement and the proposed order or to modify their terms in any way.