16 CFR PART 423 CARE LABELING RULES
I am responding to 16 CFR Part 423 Care Labeling Rules. I am interested in participating in the public workshop at the close of the comment period.
In general, I am strongly in support of the proposed rules as outlined in the document. Some of the statements would suggest that part of this was prepared prior to the introduction of icons for care instructions. I assume the appropriate adjustments will be made to incorporate icons as opposed to worded care instructions. Specifically, there is not currently an icon for professional wet cleaning. In verbal comments, employees of FTC have indicated that the icon would not be adopted until an approved test method was available for manufacturers to evaluate the appropriateness of a wet clean instruction. Within AATCC (American Association of Textile Chemists and Colorists) Subcommittee RA43 is working on an appropriate test procedure for professional wet cleaning. This test method is several months away from being accepted. RA43 is coordinating efforts for test method development with research institutes in Europe and anticipate that an AATCC test method will be very similar, if not identical, to an ISO test method that would also be under development.
Following are responses to Part D, Section by Section Description of Proposed Amendments:
1. Amendments Relating to Required or Permissible Care Instructions
(h) Professional wet cleaning. This definition encompasses only the newest developments in computer-controlled washing and drying technology. Professional wet cleaning is also widely practiced using sinks and table scrubbing.
The European Wet Cleaning Committee has suggested the following definition for wet cleaning "Wet cleaning is a process for cleaning sensitive textiles (wool, silk, rayon, natural and man-made fibers) in water by professionals using a special technology and detergents that lead to minimum fabric shrinkage and damage. It is followed by an appropriate tumble drying and restorative finishing procedure." This definition is broader in scope than the one proposed. I believe the true resolution of this issue would come with the acceptance of an approved test method by which manufacturers can test for the suitability of wet cleaning. The test method most likely would require the use of a machine with a specified diameter, rotation speed, etc. Technology may eventually involve different types of wet cleaning. A recent report on activity from Europe indicates that Ginetex will be introducing wet cleaning symbols which consist of the professional clean circle with the letter W within the circle. There will be three versions of this: l) the normal as described, 2) gentle with the addition of a single underline, and 3) very gentle with the addition of a broken underline. A concern being expressed in Europe that would also apply in the U.S. is the need to be certain that consumers do not confuse a wet cleaning instruction with a home method.
Section 423.6 (b)
I believe there is a sizeable number of garments that are labeled dry clean that could be professionally wet cleaned, and in some cases laundered at home. This proposed change to the rule will increase the requirements for manufacturers to conduct tests and establish a reasonable basis, but it does seem to be in the best interest of consumers. I have some concerns with the commission's proposal to add to section b (3) professional wet cleaning. Requiring the label to state at least one type of professional wet cleaning equipment will appear to the consumer to be endorsing a particular manufacturer of equipment or cleaning organization. This does not seem to be necessary if we adequately define the wet cleaning process and have an appropriate test method. The wet cleaning equipment used would have to fall within the guidelines of what would be specified by a test method. I don't understand the reason for requiring the fiber content of the garment on the care label since fiber content is currently a requirement by another labeling rule. The addition of this section might be interpreted by a manufacturer as relieving them of the requirement to identify fiber content unless the item is to be professionally wet cleaned. Until wet cleaning is further established as a professional industry, I do support the suggestion of including one other method of cleaning or a warning that the garment cannot be washed or dry cleaned.
3. Amendment of Definitions of Water Temperature
I Have no idea how much difficulty consumers have had trying to match care label instructions reading cold, warm and hot with actual temperatures in machines. The machines have dials that also used the same terms of cold, warm, and hot; however, cold and warm temperatures do, indeed, vary widely due to location and season. The only realistic resolution of this problem is to have washing machines that actually used thermostated water as opposed to what is available from either the cold water supply, the hot water supply, or an equal mix of the two. The changes proposed are probably realistic for typical household hot water temperatures. However, the changes do not address the problem caused by water colder than 65 degrees F. I would suggest that the term "very hot" have an upper limit of l60 degrees F. rather than 145 degrees F. for use as a label for professional shirt laundering. It is not a difficult matter to measure water temperature in a washing machine as the machine is filling with a emersion-type thermometer as is commonly found among kitchen utensils. However, it is very doubtful that consumers would actually take the time to measure temperature. It is my observation that consumers are not extremely reliable in their measurement of detergent and bleach amounts.
I have seen dress shirts with labels that indicate professional laundering is recommended. I am not sure how we would address this recommendation using the icons as opposed to worded instructions. The professional shirt laundering not only involves a higher temperature in washing, but also wider changes in pH and higher temperatures and pressures for ironing.