16 CFR Part 423; Public Roundtable Analyzing Proposed Changes to the Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods as Amended #00013

Submission Number:
00013
Commenter:
David Anderson
Organization:
Escalade Cleaners
State:
California
Initiative Name:
16 CFR Part 423; Public Roundtable Analyzing Proposed Changes to the Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods as Amended
Matter Number:

R511915

1. Definition of Dry Clean...the consumer has no understanding of the word "solvent". It is inappropriate to recommend on a care instruction label that the use of petroleum or perc based solvents are safe to use. The definition should be "clean in silicone, glycol either, carbon dioxide, or aldehyde based solvents". 2. Care Labels and Wet Cleaning...the consumer has no idea how intricate it is to successfully wet clean a garment. If the phrase wet cleaning is allowed on the care label the consumer will wash the garment at home which will result in a less than satisfactory outcome. The label should say 1)Professional Dry Clean recommended (conditioned on the fabric/garment manufacturer's guarantee that there are no fugitive dyes in the fabric), 2) Professional Wet Clean is possible (conditioned on the fabric/garment manufacturer's guarantee that shrinkage would not occur). 3. Elimination of the word "only" in the phrase Dry Clean Only...once again the consumer is clueless with regards to how dry cleaning works, and which method is the best way to clean a garment. If a garment manufacturer recommends that a garment be dry cleaned the word "only" must be included on the care label instruction. If the word "only" is omitted consumers will wash their garments at home with a very poor result. If it is against manufacturer's recommendations to wash a garment at home the care instruction label must say "Do Not Wash". 4. Garment manufacturer's have not been required to do sufficient testing of fabrics and trims for dye transfer and dye bleeding concerns. This oversight by the FTC has resulted in profoundly negative and costly effect on the consumer, on dry cleaners, and on retail clothiers. It is my experience that every day my small dry cleaning business is forced to deal with, on average, ten garments with bleeding and dye transfer issues. Unfortunately for the consumer, I am only able to salvage, on average, about 80% of the garments. The remaining balance of damaged garments are given back to (now angry) consumers who must deal with returning the garments to clothiers for refunds or the consumer is forced to accept the loss and dispose of the garments. This problem is real and needs to be addressed.