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 #00014

Submission Number:
00014
Commenter:
Dart Poach
Organization:
Professional Leather Cleaners Assoication
State:
Minnesota
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

Comment and question post March 28, 2014 round table on the Care Labeling Rule. Considering the Professional Leather Cleaners Association testimony and the testimony of the alternative solvent producer present, that leather trimmed textiles need professional leather cleaning and refinishing, would the commission re-consider a change to App. A, 8 to read as; 1. "Leather Clean and Refinish by a Professional Leather Cleaner Only" or a shorter version which reads; 2. "Professional Leather Clean and Refinish Only" or adding one word, re-finisher,to the current wording which now would read as; 3. "have cleaned only by a professional cleaner and re-finisher who uses special leather or suede care methods" I would encourage the commission to realize the significance this one word insertion would be toward the additional protection for the consumer as well as the clarity it would give the rest of the apparel industry. The high majority of these units need some type of additional process in the refinishing department and dry cleaners simply do not have refinishing departments. I have confidence that this one word clarifying addition to the language would fall into that category that you had mentioned; the FTC's ability to make some changes that did not require the whole process to start over. Thank you for re-visiting this additional consumer protection element. Dart Poach The Professional Leather Cleaners Association