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FTC Advisory opinion #1

Section 5, Federal Trade Commission Act.

(1) Any use of the word "chamois" in conjunction with a product not made from (a) the skin of the Alpine antelope or (b) sheepskin fleshers which have been oil-tanned after removal of the grain layer is unlawful and a deceptive act or practice in commerce.

The commission was requested to express an opinion concerning the legality of describing unsplit sheepskin as "Chamois-like Sheepskin" or "Chamois-type Sheepskin" on the basis, it is claimed, that the product looks and feels like chamois leather, and possesses the same qualities as the genuine product.

This problem has been before the Commission in different forms on several occasions. In each instance the Commission has taken the position that it will prohibit the branding or labeling of leather products as "Chamois," "Chamois Type" or "Chamois Like" unless such products are made (a) from the skin of the Alpine antelope, commonly known and referred to as Chamois, or (b) from sheepskin fleshers which have been oiled-tanned after removal of the grain layer.

The word "chamois" has its origin in the common name of a small goatlike Alpine antelope whose skin was made into a soft, pliable leather used in the manufacture of glove, and for polishing such articles as glass, jewelry, fine metals and wood. It possessed the additional feature of absorbing water readily and returning, when dry, to its original state of softness and pliability. The animal became virtually extinct for commercial purposes about 1890 and since that time the word acquired a secondary meaning after being widely used commercially to designate certain leathers produced from split sheepskin fleshers.

The necessity for splitting sheepskin is to remove the impervious grain layer so as to make the underside more receptive to tanning. Since the two layers do no stretch uniformly and will eventually rip and crumble. In any event, irrespective of the relative merits of the many processes which may be employed to produce the leather, the fact remains that the grain layer must be separated from the sheepskin flesher in order that an acceptable chamois will result. This requirement the requesting party’s product does not fulfill.

The claim that the subject product is equal in all respects to genuine chamois is not true, since the grain layer has not been removed. The genuine product has become firmly established in industry and elsewhere as herein defined, and such product is what the public is entitled to get when it purchases chamois even though the choice may be dictated by caprice or fashion, or perhaps by ignorance. The fact that the product is equal or will serve substantially the same purpose is wholly immaterial. F.T.C. vs. Algoma Lumber Co., 291 U.S. 67, 68, 78. To the same effect see Benton Announcements, Inc. vs F.T.C., 130 F.2d 254.

The question posed herein is whether the word chamois might be a permissible designation for the subject product if qualifying terms as "like" or "type" were added. Use of the word in any manner is a representation that the product is that which has traditionally been sold as chamois and so accepted by the public after years of buying experience. Although the ordinary purchaser may not know how chamois is made, he is entitled to believe that the particular product sold under that name is in fact a chamois as it is understood in the industry, and such implication cannot be offset by qualifying words. After reading both, an ordinary consumer would still not know the truth about the product without resort to specialized information. In other words, the capacity and tendency to deceive through any other application of the word chamois would continue to exist.

The requesting party was advised that the definition of chamois has been firmly established in law, in industry, and in the public’s mind to mean nothing less than those leather products made from the skin of the Alpine antelope or from the fleshers of sheepskin which have been oil-tanned after removal of the grain layer and that any other use of the word. whether or not modified by qualifying language, to describe leather made by other or incomplete processes would serve only to dilute its accepted meaning and would not be in the general public interest. Consequently, to label the subject product in the manner contemplated world be a deceptive practice and subject the requesting party to a charge of violation of Section 5, Federal Trade Commission Act.

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1. Scope:
This Standard covers the characteristics for genuine chamois made from sheepskin or lambskin fleshers, fish-oil tanned.
2. Purpose:
2.1 This Standard is not intended to establish grades or quality differentiations of genuine chamois. It is specifically intended to define the general characteristics and performance characteristics of the genuine chamois skin as a basis of identification only, without regard to size or configuration. It is for whole skins or any cut patterns derived therefrom, and not for pieced skins.
2.2 The General Characteristics in Section 3, Physical Characteristics in Section 4, and Chemical Characteristics in Section 5 are such as may be met by any correctly oil tanned chamois.
2.3 It is specifically intended that the compliance with this Standard shall not be claimed, referenced, or in fact, be recognized, for any products meeting only parts or the combined Characteristics in Sections 3, 4 and 5. Reference of compliance to parts or Sections of this Standard shall only be made, when the statement of partial compliance is accompanied by a specific enumeration of the numbered Sections of the Standard for which compliance is not, or cannot be claimed.
3. General Characteristics:
3.1 MATERIAL.Chamois shall be made from undersplit of sheepskin, or lambskin, split before tanning
3.2 TANNAGE.Chamois covered by this Standard shall be full fish oil-tanned so as to produce a soft absorbent material. No combination process of tanning, utilizing cod or other oils in mixture with significant amounts of other tanning agents, as described in Table II, Chemical Characteristics, shall be permitted.
3.3 FINISH.Chamois shall be suede finished on one or both sides.
3.4 COLOR.Chamois shall be the natural color obtained from oil tannage. It shall not be subjected to any form of chemical bleaching or dyeing.
3.5.1 Chamois in this Standard may be whole skins, pattern cut skins, pocket-shaped or any configuration obtained from the original skin after tanning.
3.5.2 Either extreme dimensions of overall length and width or square area are recognized as an acceptable industry practice of determining size
4. Physical Characteristics:
The median thickness of any skin, breaking strength, water absorption, water removed by wringing and time wetting, shall meet the values specified in Table I and shall be according to tests specified in paragraph 7.
Median Thickness Minimum Breaking Strength Minimum Water Absorption Minimum Water Removed by Wringing Minimum Time of Wetting Maximum
1/64 Inch 30 pounds 375 grams per 100 grams of conditioned leather 200 grams per 100 grams of conditioned leather 30 seconds
4.1 REPAIRED SKINS. Skins which have been repaired by sewing will be considered as in compliance with this Standard if the chamois used otherwise meets all the requirements of this Standard.
5. Chemical Characteristics:
The chemical characteristics of chamois leather shall be shown in Table II when tested as specified in paragraph 7.
*Moisture free basis
Maximum Minimum
*TOTAL ASH % 12.0 -
*IRON AND ALUMINUM AS Fe2O1 + A12O1 % 1.5 -
*CHROMIUM AS CR2O1 % 0.0 -
- 6.5
6. Marking:
6.1 Each skin shall carry the identifying mark, name of trademark of the distributor, or other person entering the skin into commerce for the purposes of retail sale.
6.2 Compliance with this Standard does not give any right to use the registered trademark of the Sponge and Chamois Institute for Genuine Chamois except where specific license for such use is in effect.
7. Test Procedures:
The following procedures shall be used to establish conformance with the provisions of this Standard. Questions relating to procedures and test methods shall be verified and arbitrated through the official published methods of the American Leather Chemists Association, c/o University of Cincinnati, Cincinnati, Ohio.
Characteristic Paragraph No. Test Method
Finish 3.3 Visual inspection
Physical Characteristics per Table I 4.0 (See appendix A)
Chemical Characteristics per Table II 5.0 (See appendix B)
Marking 6.0 Visual Inspection
8. Reference Documents:
The latest issues of the following:
1) Federal Specifications:
KK-L-311, Leather, Methods of Sampling and Testing KK-C-300, Chamois, Leather, Sheepskin, Oil-tanned
2) Published methods of the American Leather Chemists Association
3) License Agreement for the Chamois Mark of the Sponge and Chamois Institute
I. Test Methods
(a) Physical Characteristics (see Section 7.0)
1) Median thickness. Thickness shall be determined by the average of five measurements taken an equal distance along the length dimension, In accordance with applicable portions of Method 1011 of Federal Specification KK-L-31a (January 19, 1953).
2) Breaking Strength. Shall be determined in accordance with Method 2031.1 of Federal Specification KK-L-311a, Amendment 4, Part 3 (November 6, 1962).
3) Water absorption. Water removed by wringing shall be determined in accordance with paragraph 4.3.1 of Federal Specification KK-C-300c (June 13, 1969).
4) Time of wetting. Shall be determined in accordance with paragraph 4.3.3 of Federal Specification KK-C-300c (June 13,1969).
(b) Chemical Characteristics (see Section 7.0)
1) Total ash. Shall be determined in accordance with Method 6421 of Federal Specification KK-L-311a (January 19, 1953).
2) Iron and Aluminum. Shall be determined in accordance with Method 6531 of Federal Specification KK-L-311a (January 19,1953).
3) Chromic oxide. Shall be determined in accordance with Method 6521 of Federal Specification KK-L-311a (January 19, 1953) and footnote 4 of Table, paragraph 4.3 of Federal Specification KK-C-300c (June 13, 1969).
4) Free formaldehyde. Shall be in accordance with paragraph 4.3.4 of Federal Specification KK-C-300c (June 13, 1969).
5) Acidity (pH). Shall be determined accordance with Test Method 6621 of Federal Specification KK-L-311a (January 19, 1953).
II. Testing Lot
For compliance determination purposes, testing shall require submissions of no less than six skins selected at random.
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Frequently Asked Questions

What is a Chamois?
The "Chamois" originally referred to the skin of a certain variety of antelope, but over the years came also to refer to products of split sheepskin. The term "Chamois" was defined by the Federal Trade commission in Advisory Opinion Digest No. 1. Additionally, the Sponge & Chamois Institute codified the industry standard in "Chamois Standard CS99-1970."
How can I tell if it is a real Chamois?
See Chamois Leather Genuine or Counterfeit?
What is FTC Advisory Opinion No. 1?
See FTC Advisory Opinion No.1
What is Chamois Standard CS99 - 1970?
See Chamois Standard CS99 - 1970
Are there other laws or regulations regarding Chamois?
There are a variety of court decisions directly addressing what is a chamois. In addition, civil claims are available pursuant to Section 43(a) of the Lanham Act (15 U.S.C. 1125(a)). Complaints may also be filed with the Federal Trade Commission, and the U.S. Council of Better Business Bureaus.
What is a Sponge?
  1. Any of numerous aquatic, chiefly marine invertebrate animals of the phylum Porifera, characteristically having a porous skeleton composed of fibrous material or siliceous or calcareous spicules and often forming irregularly shaped colonies attached to an underwater surface.
  2. The light, fibrous, flexible, absorbent skeleton of certain of these organisms, used for bathing, cleaning, and other purposes.