16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00014 

Submission Number:
00014 
Commenter:
John Patterson
Organization:
Complete Cleaners
State:
Alabama
Initiative Name:
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915

Dear Sirs, I have been in the dry cleaning industry for over 30 years now. I have seen the care label evolve from a useful tool for both the consumer and the dry cleaner to a much less effective one which is often used by various manufacturers to avoid liability for garments which are not servicable without damage. It is a difficult issue. Complete instructions for processing every item cannot be written on a small fabric tag. Some of the success or failure must by nature depend on the skill and knowledge of the dry cleaner or the consumer if he processes an item at home. There are now at least 4 dry cleaning solvents that are in common use. Some of them are much more agressive toward trims plastics and dyes than others. Professional wet cleaning has come a long way in the last few years and many (but not all) garments that would have traditionally been dry cleaned can be wet cleaned with good results if the cleaner has proper processes and has proper training. There are also lots of items that can be dry cleaned but say machine or hand wash, In my opinion a care label that reflects ONE way that a garment can be cleaned that has been verified by testing should be sufficient. Manufactures can no longer say "Dry Clean Only" and cover all the possible processes without testing. Some of the solvents (GreenEarth for example that we use at Complete Cleaners) are very safe for dyes fabrics and trims, but even so, delicate trims must be protected from mechanical agitation. Other solvents such as Perchloroethylene may dissolve or harden plastics and buttons that are not damaged in GreenEarth or even Petroleum (hydrocarbon) solvents. In my mind the care label at least needs to address this on items where solvent choice matters. Thank you for soliciting comments. You have a challenging job. Good luck.