Submission Number: 00082
Received: 11/16/2012 6:12:51 PM
Commenter: Robert Blacker
Organization: R.R. Street & Co. Inc.
Agency: Federal Trade Commission
Initiative: 16 CFR Part 423 - Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods (the “Care Labeling Rule”); Project No. R511915
Attachments: No Attachments
With respect to 16 CFR Part 23 amendments, R.R. Street & Co. Inc. submits the following comments.
In Part 423.1 Definitions – paragraph (c) amends the definition of “Dryclean” by providing several examples of drycleaning solvents currently in use within the industry. The proposed examples include “aldehyde” as a drycleaning solvent. The term “aldehyde” is not widely recognized in the drycleaning industry, and currently there are no solvents in use in the industry that are “aldehydes”. Therefore, we would recommend that “aldehyde” be removed from the examples as it does not adequately describe any of the solvent technologies in use today.
The above change would apply to the amendments to Appendix A to Part 423-Glossary of Standard Terms, paragraphs 7.a and 7.c as well.
Concerning amendments to part 423.6 concerning wetcleaning, we would recommend that when the words wetclean or wetcleaning are to be used on garment care labels, they should be preceded by the word “Professional”. While wetcleaning is a common term in the drycleaning industry, it is a relatively new term to consumers and may be confused with regular home laundry. The use of the terms “Professionally Wetclean” or “Professional Wetcleaning” would help to clarify this issue and coincide with the proposed ASTM and ISO symbols.
R.R. Street & Co. Inc. is the industry leader in providing the highest quality processes, products and services to produce the best quality fabric care for 136 years.