Submission Number: 00102
Received: 9/5/2011 4:29:38 PM
Agency: Federal Trade Commission
Initiative: 16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915
Attachments: No Attachments
Professional Wet Cleaners Associations, Inc.
1464 Cary Avenue
San Mateo, CA 94401
August 29, 2011
Donald S. Clark
Secretary of the Commission
Federal Trade Commission
600 Pennsylvania Ave., NW
Washington, DC 20580
Dear Commissioner Clark:
The Professional Wet Cleaners Association (PWA) is writing to your office to express our strong support for a new ‘Professional Wet Clean’ care label. We recommend that all items which require professional cleaning or where professional cleaning is recommended be labeled ‘Professional Wet Clean’ if there is a reasonable basis for this new label.
The Professional Wet Cleaners Association is a non-profit organization make up of cleaners exclusively using professional wet cleaning technologies. Our members are approaching 100 and growing rapidly, primarily located in California.
Since the mid-1990s, professional wet cleaning, a process for cleaning and finishing delicate garments typically labeled ‘Dry Clean’ or ‘Dry Clean Only,’ has grown substantially around the world and in the United States. In California alone there are over 200 dedicated professional wet cleaners who are successfully wet cleaning garments they had previously dry cleaned. In addition to dedicated professional wet cleaning facilities, there are many dry cleaners in the United States who also have equipment that can be used for professional cleaning. As professional wet cleaning has grown, so has an infrastructure of equipment manufacturers, detergents manufactures, service technicians, and skilled trainers.
PWCA believes that the current care label laws are unfair and deceptive to the consumers that wear garments labeled ‘Dry Clean Only’ or ‘Dry Clean’ when in fact these garments can also be successfully wet cleaned. The primary difference between dry cleaning and wet cleaning is that wet cleaning uses water as a cleaning solvents and biodegradable detergents as cleaning agents. Now, consumers have an option for how their delicate garments can be cleaned. The care label should be inform customers of these options.
Most the PWA members converted to professional wet cleaning from perc dry cleaning and are now successfully wet cleaning the full range of garments they had previously dry cleaned. This includes traditional business apparel as well as couture garments such as Chanel, Versace, Dolce and Gabanna, Gucci, Vera Wang, Louis Vuitton, just to name a few. Therefore, garments labeled ‘Dry Clean’ or ‘Dry Clean Only’ that can be successfully wet cleaned is unfair to any professional wet cleaner by misinformation existing and potentially new customers about how the garment should be serviced. Customers come into professional wet cleaners every day and ask for their garments to be dry cleaned because the garments are labeled ‘Dry Clean’ or ‘Dry Clean Only’. If we tell them we will be wet cleaning their garments they may decide to go to a dry cleaner. If we say “yes” we are deceiving our customers. This dilemma of either lying to the customer or potential losing existing or new customers makes professional wet cleaning unappealing to many dry cleaners. This is especially true because most owners of dry cleaners are first generation immigrants.
The lack of a ‘Professional Wet Clean’ care instruction is also unfair to professional wet cleaners because it does not provide us with information helpful in processing of the garment. The ‘Professional Wet Clean’ care label system developed by the International Standardization Organization (ISO) provides three variations of the wet clean label which would help inform the wet cleaner on best practices for processing the garment.
Landlords are increasingly aware of the hazards associated with toxic dry cleaning solvents or dry clean solvents that are combustible. Many professional cleaners have been forced to close their doors because landlords are concerned about dry cleaning hazards and are unaware that there is a non-hazardous alternatives, namely professional wet cleaning. In this way, the current care label law is unfair and deceptive to landlords who are unaware of the professional wet cleaning option and unfair to cleaners who cannot obtain a lease renewal due to landlord ignorance about professional wet cleaning..
Many consumers avoid purchasing delicate garments labeled ‘Dry Clean’ or ‘Dry Clean Only’ in order to avoid health hazards associated with dry cleaning solvents. Customers have stated that dry-cleaning chemicals cause allergic reactions to their skin and body. This includes skin redness, rashes, and sometimes headaches. Many consumers also state that they cannot tolerate the odor from clothing that have been dry cleaned. A ‘Professional Wet Clean’ care label would enable consumers to freely purchase and wear a wider range of clothing since wet cleaning would enable a safer and healthier alternative cleaning method compared to perc dry cleaning.
The motto of a prominent environmental company, 7th Generation, speaks of the importance of social responsibility: “In our every deliberation, we must consider the impact of our decisions on the next seven generations.” - From the Great Law of the Iroquois Confederacy. We all have a social responsibility to protect and inform the consumer population about what is true and correct. In addition, this great nation which has been a forerunner of innovation and success should lead the way for other nations to follow its exemplary decisions in ensuring the public well-being of its citizens as well as preserving Mother Nature and the environment that we as humans have been entrusted with.
If you have any questions, please contact with PWC President Gus Chang at 707-486-8934.
We look forward to working with the FTC on this important public policy issue.
LIST OF PWA MEMBERS –
Ventura Marina Village Cleaners
2415 Harbor Boulevard
Ventura, CA 93001-3904 Sun Choi (805) 642-0445
1730 E Ave De Los Arboles # F
Thousand Oaks, CA 91362 Peter Jung 805) 493-2715
Los Angeles Point Dume Cleaners
29211 Heathercliff Road
Malibu, California 90265 Michael Sunwo (310) 457-3606
Los Angeles Colony Cleaners
3872 Cross Creek Road
Malibu, CA 90265 Mina Mallari (310) 456-6202
Sun Hill Cleaners
Boulevard CA 91040-1925 Janet Kwon (818) 353-1808
1465 East Valley Boulevard
Alhambra, CA 91801-5239 Nam (626) 284-5450
1331 East Carson Street
Carson, CA 90745-1631 Brian Yu (310) 518-1064
1168 East Artesia Boulevard
Long Beach, CA 90805-1555 Lisa Tsan (562) 422-3061
2625 North Garey Avenue
Pomona, CA 91767 Lawrence Lee (909) 392-3927
Orange Norton's Cleaners
204 East Yorba Linda Boulevard
Placentia, CA 92870-3417 Jack Norton (714) 524-7130
One Day Cleaners
26012 Marguerite Pkwy # I
Mission Viejo, CA 92692-3263 Sang Im (949) 582-5305
San Bernardino Clean 4 Less Cleaners
4028 Grand Ave # D
Chino, CA 91710-5486 Davis Lee (909) 591-6378
Golden Hanger Cleaners
883 West Foothill Boulevard
Upland, CA 91786-3727 Chong Kim (909) 982-1915
Natures Best Cleaners
8782 19th St.
Rancho Cucamonga, CA 91701 Sung Park (909)989-4777
Riverside Palm Cleaners
10247 Magnolia Avenue
Riverside, CA 92503-3440 Kyong Ha (951) 688-0450
Natures Best Cleaners
364 S. Indian Canyon Dr.
Palm Springs, CA 92262 Jung Choi (760)320-8414
San Diego Sunny Fresh Cleaners
8849 Villa La Jolla Dr # 305
San Diego, CA 92037-1958 Hwa Lee (858) 455-0071
Boulder, CO Plaza Cleaners 2610
Boulder, CO 80304-3542 Seo Oh (303) 442-9247
Newcastle, WA Newcastle Cleaners
6920 Coal Creek Parkway SE Ste. 5.
Newcastle, WA 98059 Glen Kim
MENDOCINO MASTER CLEANERS
502 South State Street
Ukiah, CA 95482-4911 Sung Kim 707-462-4129
SONOMA NATURES BEST CLEANERS
915 Lakeville St.
Petaluma, CA 94952 Gus Chang 707-486-8934
TIP TOP CLEANERS
33 Henry Street
Cotati, CA 94931-4232 Chong Lee 707-578-1626
4211 Montgomery Drive
Santa Rosa, CA 95405-5306 Ho Choe 707-539-6525
MARIN PACIFIC HEIGHTS CLEANERS
Sausalito, CA 94965-3402 KARL HUIE 415-331-3015
CLEAN LOOK CLEANERS
743 East Blithedale Avenue
Mill Valley, CA 94941 YONG SIM 415-381-3447
FAIRFAX FRENCH CLEANERS
173 San Marin Drive
Novato, CA 94945-1209 YONG CHONG 415-898-2040
SACRAMENTO COUNTRY CLUB CLEANERS
2612 Watt Avenue
Sacramento, CA 95821 PAUL LEE 916-482-6166
316 East Bidwell Street
Folsom, CA 95630-3115 CHONG JIN LEE 916-983-2378
CONTRA COSTA BOB? CLEANERS
777 23rd Street
Richmond, CA 94804-1465 SERGIO RIOS 510-236-3471
SAN FRANCISCO VERMONT CLEANERS
600 Vermont Street
San Francisco, CA 94107-2636 BENSON XU 415-647-8080
536 Divisadero Street
San Francisco, CA 94117 YAK LEE 415-552-3736
ALAMEDA HESPERIAN CLEANERS
15848 Hesperian Boulevard
San Lorenzo, CA 94580 SUNG LEE 510-481-5825
MV HOLYDAY CLEANERS
40093 Mission Boulevard
Fremont, CA 94539-3680 DALMO LEE 510-656-8818
SAN JOAQUIN A-1 CLEANERS
136 West Walnut Street Stockton, CA 95204-5730 MARSHA TAKEDA 209-463-4952
SAN MATEO PRESS ON CLEANERS
1464 Cary Avenue
San Mateo, CA 94401 JULI ROH 650-342-2987
445 Old County Rd
San Carlos, CA 94070 PHILIP CHEN 650-592-6328
SANTA CLARA NATURES BEST CLEANERS
1281 West El Camino Real
Sunnyvale, CA 94087 PETER XU 650-969-0469
171 Branham Ln # 4
San Jose, CA 95136-2339 JEAN CHA 408-224-4380
SAN FRANCISCO Pacific Heights Cleaners
2437 Fillmore Street
San Francisco, CA 94115 KARL HUIE 415 567 5999
MARIN Pacific Heights Cleaners
Sausalito, CA 94965 KARL HUIE 415 331 3015
OREGON Vanity Cleaners
1954 NE Highway 101
Lincoln City, OR 97367 Tae-Hwan Kim 541-829-1138
GLENDALE The Cleaning Store
1225 N. Pacific Ave.
Glendale. CA 91202 KUN SONG (213)235-7277
3323 State St.
Santa Barbara, CA 93105 Sergio Castro (805) 687-8113