A Practical Guide to Labeling Down & Feather Products in the U.S. and Canada

If you’re selling jackets, bedding, furniture, or other stuffed articles filled with down and feathers, the label isn’t just a tag — it’s a compliance statement. Both the United States and Canada have strict standards about when you can call something “down,” how blends must be declared, and what disclaimers are required.

Here’s a clear breakdown of what you need to know before sending your products to market.

Why Labeling Matters for Down/Feather Products

Consumers trust the word “down” to mean warmth, quality, and value. Regulators trust your label to be accurate, measurable, and verifiable. A misstep doesn’t just risk fines — it erodes customer confidence. That’s why testing, documentation, and precise label wording are essential.

U.S. Labeling Standards: When Can You Say “Down”?

In the United States, the word “DOWN” is tied directly to down cluster content.

• Minimum cluster percentage: To be labeled as “DOWN,” a product must contain at least 75% down cluster.
• Show your math: You must disclose the minimum percentage of down cluster on the label. For example:

  • “DOWN (MINIMUM 80% DOWN)”

• Minor wiggle room: To account for unavoidable variations in the manufacturing process, the US government allows a modest deviation of no more than 5% of the product’s actual percentage of down or other plumage. However, if the FTC finds that all or most of your products are 5% less than the stated percentage (e.g. most of your "50% down" pillows are actually 45% down), then the product must be relabeled to reflect the actual amount.

Example U.S. Labels

• Comforter: “DOWN (MINIMUM 85% DOWN)”
• Pillow: "DOWN & FEATHERS (50% DOWN, 50% WATERFOWL FEATHERS)"

Canadian Labeling Standards: More Than Just a Percentage

Canada takes a slightly different approach, defining what it calls “Commercial Down.”

• Composition rules: To qualify as “down,” the fill must meet this mix:

  • At least 75% down & plumules
  • No more than 25% small waterfowl feathers (≤ 60 mm, no quills)
  • No more than 20% fibers (feather + down fiber)
  • No more than 5% residue (including landfowl)

• Never say “100% down”: Labels can’t make that claim. Instead, every “down” label must include this statement:

  • “NOTE: This product contains an amount of feathers not exceeding that allowable by law.”

• Species claims come with rules: If you call it “goose down” or “duck down,” at least 90% of the fill must be from that species.

Example Canadian Labels

• Duvet: “DOWN (GOOSE)”

  • Plus the required note: “This product contains an amount of feathers not exceeding that allowable by law.”

• Pillow: “WATERFOWL FEATHERS” (meets Commercial Waterfowl Feather standards).

Key Differences at a Glance

The Down Compliance Checklist

Before printing your next run of labels, run through this quick list:

1. Test first: Verify cluster percentage, species makeup, and composition through an accredited lab.
2. Choose the right claim: Match U.S. cluster rules or Canada’s Commercial Down definitions.
3. Mind the disclaimers: Add Canada’s required note whenever you use “down.”
4. Be precise with blends: Both nations require precise blend information, with only minor variation allowed in the U.S.
5. Keep documentation: Store your lab results alongside label proofs for future audits.

When In Doubt Seek Us Out

Down labeling might feel like a maze of percentages and disclaimers, but the rules boil down to one principle: accuracy. If you test thoroughly and word your labels precisely, you’ll not only stay compliant — you’ll also build credibility with customers who expect transparency.

And if you sell in both the U.S. and Canada? Plan your label strategy early. Subtle differences like Canada’s mandatory note and species rule can save you costly relabeling later.

To ensure your labels meet the standards both in the U.S. and Canada – contact GRS and we will help you on your way.