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 #00006 

Submission Number:
00006 
Commenter:
Brad Johnson
Organization:
Executive Dry Cleaners & Shirt Laundry, Inc
State:
Colorado
Initiative Name:
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

Two issues need to be addressed during the updates to the FTC Care Labeling Rules. First, the ASTM guidelines need to be updated to reflect the significant changes to the dry cleaning industry. The GreenEarth cleaning method has gained widespread popularity worldwide not only for its environmental friendliness, but also due to the ability to clean garments that have been particularly difficult to handle with other solvents. Thousands of locations are already using this method of cleaning. Thus, the ASTM guidelines should allow the inclusion of a GreenEarth specific mark of some kind. Many manufacturers would welcome this due to the friendliness of this solvent for both garments and embellishments. Second, the FTC needs to consider the opportunity for vast consumer misperceptions surrounding the language used around wetcleaning. While professional wetcleaning is certainly a valid cleaning method, there is a huge difference between professional wetcleaning and a consumer washing their clothing at home. Either the term “Professional Wetclean” or “Do Not Home Launder” or something similar should be included as labeling options. If simply “Wetclean” is an option, consumers will likely think they can wash the garment at home. This is likely to cause problems for the entire industry if not addressed correctly because damaged garments will then be brought to the dry cleaner to correct and it is going to cost the reputable dry cleaner dearly.