Recent discoveries of unlabeled real fur from raccoon dogs used in garments have spurred discussions surrounding proper labeling methods of fur coats.  According to the Humane Society of United States, the unlabeled faux fur found on jackets sold by DKNY, Rocawear, Baby Phat, Sean John and by retailers like Macy’s and J.C. Penney is actually dog fur, taken from raccoon dogs who are skinned alive.  In 2005, Macy’s pulled coats from its shelves containing raccoon dog fur labeled as raccoon after the Humane Society raised the issue with the chain.

The Federal Products Labeling Act (FPLA), which outlines the labeling rules for fur garments, has a massive loophole which allows clothing trimmed with fur which is $150 or less to be sold without labels.  In addition, products that contain dog or cat fur are also exempt from the FPLA.  However, the Dog and Cat Protection Act of 2000 prohibits importing, exporting, selling, trading, advertising, transporting, or distributing of any products made with dog or cat fur.  In addition, California criminal law prohibits selling dog or cat fur in that state.  Activists argue that raccoon dog is still a type of dog and its use in garments is illegal in the United States.

In general, violations of the FPLA are subject to monetary civil penalties of up to $11,000 for each violation.  Each instance of mislabeling is considered a separate violation.

To avoid such costly penalties, fur product manufacturers should be aware of other labeling requirements specified by the FPLA.

The information provided on labels should include whether the fur is composed of natural, bleached, pointed, dyed, or artificially-colored fur and whether the product is composed of pieces.  The label must also indicate the country of origin of the product.  The country of origin must be stated separately from the animal name, and be preceded by the words "Fur Origin" (for example, "Fur Origin: Ukraine").  According to the FPLA, in the case of fur products manufactured in pairs or groups, only one label is required if all units are made of the same fur and have the same country of origin, are firmly attached to each other when marketed and sold and if the information on the label is applicable to each unit in the pair or group.  The product must contain the name or registered identification number (RN) of the manufacturer, importer or other seller, marketer or distributor of the fur.  The law prohibits marketers from furnishing any false guarantees about the origin or nature of their fur products as shown on invoices, and requires them to keep product records for three years.

In addition to the FPLA, following the recent instances of mislabeling, the New York State Assembly introduced a law this summer according to which any person, firm, partnership or corporation that knowingly imports, sells, manufactures, distributes or markets articles of clothing that include fur not correctly labeled as "faux fur" or "real fur" faces up to a $500 fine initially and a $1,000 fine for each subsequent violation.