|July 27, 1998
Dear Mr. Clark:
Thank you for the opportunity to comment on the proposed rulemaking on the Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods. The American Textile Manufacturers Institute (ATMI) is the national trade association for the domestic textile industry. Our member companies operate in more than 30 states and account for approximately 80 percent of all textile fibers consumed by mills in the United States.
The Advanced Notice of Proposed Rulemaking (ANPR) asked for responses for six questions.
Is there empirical evidence regarding whether consumers interpret a "dry clean" instruction to mean that a garment cannot be washed?
To our knowledge, there is no documentation to substantiate the concern that consumers will assume that a "dry clean" instruction means that a garment cannot be washed; however, it is possible that consumers make that assumption. A casual poll indicates that most people accept that "dry clean" means do not wash; however they don't necessarily follow the care instructions. For instance, most silk garments are marked "dry clean only." Experience tells us, though, that many silk garments can be washed by hand or machine, and line dried, albeit with care.
The fact that the FTC only requires the garment to list one satisfactory care method and the fact that many items are labeled "dry clean" may lead consumers to assume that washing may very well harm the garment.
How many domestic businesses provide professional wet cleaning, as defined in Part D.1. above, to the public on a regular basis?
The number of businesses offering professional wet cleaning is still small, but the number grows every day. It seems unlikely, however, that we will see many such businesses in smaller cities for many years. The professional wet cleaners are members of trade associations and a copy of their membership lists will indicate the current number of businesses providing such services.
Should the Rule provide that, if an instruction for professional wet cleaning is provided, no other instruction need be given, or should a professional wet cleaning instruction only be allowed along with another cleaning instruction?
The care instructions provided on the label should be left to the garment manufacturer. If a garment performs best when professionally cleaned, then one instruction is adequate. If home laundering would result in the same appearance, then the garment manufacturer may also prefer to include home laundering instructions, since that will result in reduced maintenance costs. A "professional wet clean" label, however, should be accompanied by an alternative instruction, since it may be unclear to the consumer.
Would the amendment of Section 423.6 (c) (3) of the Rule, which provides that a reasonable basis can consist of reliable evidence that each component of the garment can be cleaned according to the care instructions, to state, additionally, that a manufacturer or importer must possess a reasonable basis for the garment as a whole, clarify the reasonable basis requirements? Is any additional clarification needed?
There needs to be a definition for "reasonable basis" that may include a test of the composite garment or some other definitional factor. We have seen instances of garments damaged when one component bled onto another, such as when a red or blue panel bled onto an adjacent white panel. Yet the color loss was not picked up by AATCC tests of color loss of each component. Fashion will continue to expand, and more complex combinations of components will require further clarification.
How can consumers best be made aware of the approximate water temperatures in which they can safely and effectively wash their clothing? How can consumers best be made aware of how these temperatures correlate to the descriptors "hot," "warm," and "cold" washing?
The label should state the preferred method, including a description of the temperature of the water. Words are easily understood, but symbols would be effective, if accompanied by a consumer education effort that is conducted over an extended period. Conveying the meaning of a quantitative factor such as water temperature to the consumer in understandable terms is difficult. One family member may bathe in water that is 10 to 15 degrees hotter that that used by another. Yet both use water as warm as they can. It seems likely that consumers assume the temperature employed by their washing machine matches the temperature suggested on the garment label. In other words, if the garment says "machine wash hot water," the consumer assumes that matches the "hot" temperature selection on their home machine. However, factors such as the temperature set for the hot-water heater, the ambient temperature, the season, and other factors may influence the actual temperature in the washing machine. It seems clear that, on this question, the washing machine manufacturers ought to work toward consensus on temperatures with input from others affected by the definition, and develop methods of standardizing them.
Would consumers understand an instruction to use "very hot" water? Could consumers use this information either to select the optimal temperature offered by their washing machines for clothes labeled for "very hot" water or to determine that such clothes should be washed by a professional cleaner?
Depending on the consumer, responses may range from using the hottest temperature they can get from their water heater to adding a pot of boiling water to using the services of a professional wet cleaner. The advice provided in articles in homemaker's magazines will influence their behavior, provided there is consistent advice. Additional comments on what constitutes "very hot" are important. Perhaps the label could indicate the consumer should use "Temperatures which normally exceed home laundry and water heater settings," which would justify a larger label if "very hot" is truly the preferred method.
Suzanne M. Hough