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Federal Register / Vol. 86, No. 104 / Wednesday, June 2, 2021 / Notices
and importers of furs and fur products keep certain records in addition to those they may keep in the ordinary course of business. Staff estimates that 950
retailers incur an average recordkeeping burden of about 18 hours per year 17,100 hours total; 75 manufacturers incur an average recordkeeping burden of about 60 hours per year 4,500 hours total; and 950 importers of furs and fur products incur an average recordkeeping burden of 30 hours per year 28,500 hours total. The combined recordkeeping burden for the industry is approximately 50,100 hours annually.
Disclosure: Staff estimates that 1,025
respondents 75 manufacturers + 950
retail sellers of fur garments each require an average of 30 hours per year to determine label content 30,750 hours total, and an average of 30 hours per year to draft and order labels 30,750
hours total. Staff estimates that the total number of garments subject to the fur
labeling requirements annually is approximately 3,680,000.3 Staff estimates that for approximately 50
percent of these garments 1,840,000
labels are attached manually, requiring approximately four minutes per garment for a total of 122,667 hours annually.
For the remaining 1,840,000, the process of attaching labels is semi-automated and requires an average of approximately one minute per item, for a total of 30,667 hours. Thus, the total burden for attaching labels is 153,334
hours, and the total burden for labeling garments is 61,500 hours per year 30,750 hours to determine label content + 30,750 hours to draft and order labels.
Staff estimates that the incremental burden associated with the Fur Rules invoice disclosure requirement, beyond the time that would be devoted to preparing invoices in the absence of the Rules, is approximately one minute per
Task
Hourly rate
Burden hours
Labor cost
Determine label content
Draft and order labels
Attach labels
Invoice disclosures
Prepare advertising disclosures
Recordkeeping

$30.00
19.00
5 13.00
14.00
30.00
18.00

30,750
30,750
122,667
67
38,000
50,100

$922,500
584,250
1,594,671
938
1,140,000
951,900

Total

5,194,259

Pursuant to Section 3506c2A of the PRA, the FTC invites comments on:
1 Whether the proposed collection of information is necessary for the proper performance of the functions of the
agency, including whether the information will have practical utility;
2 the accuracy of the agencys estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used;
3 ways to enhance the quality, utility, and clarity of the information to be collected; and 4 ways to minimize the burden of maintaining records and providing disclosures to consumers. All comments must be received on or before August 2, 2021.
You can file a comment online or on paper. For the FTC to consider your comment, we must receive it on or before August 2, 2021. Write Fur Rules;
PRA Comment: FTC File No. P072108
on your comment. Your comment including your name and your state will be placed on the public record of this proceeding, including the https
www.regulations.gov website.
Due to the public health emergency in response to the COVID19 outbreak and the agencys heightened security screening, postal mail addressed to the
Commission will be subject to delay. We encourage you to submit your comments online through the https
www.regulations.gov website.
If you prefer to file your comment on paper, write Fur Rules; PRA Comment:
FTC File No. P072108 on your comment and on the envelope, and mail your comment to the following address:
Federal Trade Commission, Office of the Secretary, 600 Pennsylvania Avenue NW, Suite CC5610 Annex J, Washington, DC 20580; or deliver your comment to the following address:
Federal Trade Commission, Office of the Secretary, Constitution Center, 400 7th Street SW, 5th Floor, Suite 5610 Annex J, Washington, DC 20024. If possible, submit your paper comment to the Commission by courier or overnight service.
Because your comment will become publicly available at https
www.regulations.gov, you are solely responsible for making sure that your comment does not include any sensitive or confidential information. In
3 The total number of imported fur garments, furtrimmed garments, and fur accessories is estimated to be approximately 3,500,000 based on industry data. Estimated domestic production totals 180,000.

4 The invoice disclosure burden for PRA purposes excludes the time that respondents would spend for invoicing, apart from the Fur Rules, in the ordinary course of business. See 5 CFR 1320.3b2.

5 Per industry sources, most fur labeling is done in the United States. This rate is reflective of an average domestic hourly wage for such tasks performed in the United States, which is derived from recent BLS statistics.

Staff believes that there are no current start-up costs or other capital costs associated with the Fur Rules. Because the labeling of fur products has been an integral part of the manufacturing process for decades, manufacturers have in place the capital equipment necessary to comply with the Rules labeling requirements. Industry sources indicate that much of the information required by the Fur Act and Rules would be included on the product label even absent the Rules. Similarly, invoicing, recordkeeping, and advertising disclosures are tasks performed in the ordinary course of business so that covered firms would incur no additional capital or other nonlabor costs as a result of the Act or the Rules.
Request for Comments
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invoice for pelts.4 The invoice disclosure requirement applies to fur pelts, which are generally sold in groups of at least 1100, on average. Based on information from the Fur Industry Council of America, staff estimates total sales of 4,450,000 pelts annually. Thus, the invoice disclosure requirement entails an estimated total burden of 67
hours 4,046 total invoices one minute.
Staff estimates that the Fur Rules advertising disclosure requirements impose an average burden of 40 hours per year for each of the approximately 950 domestic fur retailers, or a total of 38,000 hours.
Thus, staff estimates the total disclosure burden to be approximately 252,901 hours.
Estimated annual cost burden:
$5,194,259 solely relating to labor costs. The chart below summarizes the total estimated costs.

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