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 #00014 

Submission Number:
00014 
Commenter:
John  Camerino
Organization:
Veribest Cleaners
State:
California
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

It is very important that labels say "Professional Wet Clean" not just use a Circle W symbol or say "Wet Clean." I am a professional wet cleaner, and my customers DO NOT understand what that means. To them, “wet cleaning” means cleaning in water, they would assume a "Wet Clean" label means they can just wash their garments at home instead of bringing them in to be professionally cleaned. A professional wet cleaner needs to take into account the control of equipment, injection of softeners and/or texturizers etc. The most important thing consumers need to know is whether or not they can clean a garment at home or if they need to bring it in for professional cleaning. As a professional, I make the decision about whether to use a dry or wet cleaning technique based on what is the best care for each garment. Wet cleaning accounts for more than 70% of my business. If a clothing-maker wants to be green and recommend wet cleaning when dry cleaning is also okay, and you don't require it to say "Professional wet clean" I could lose a lot of business. I am also a GreenEarth cleaner. This is cleaning with silicone solvent . But customers would never know that, they only know it as GreenEarth because it is the only solvent with a brand name. And it is A LOT different than a few of the other solvents you plan to recognize under your new rule - some of those have KB values over 70!! That is worse than perc when it comes to solvent aggressiveness and risk of damage! If the care label is supposed to identify when a solvent like perc is too aggressive and will damage the garment, and all the alternative solvents are lumped together and treated as equal alternatives, then we haven't helped solve the problem. It would be wonderful to have a GreenEarth symbol on the care labels as opposed to the traditional perc symbol because perc can damage garments and GreenEarth never does. Consumers are unaware of the differences between a regular silicon cleaner vs. GreenEarth, a care label would distinguish the two. Because GreenEarth is patented, no other dry cleaners can use silicone to clean unless they are GreenEarth. Having something accepted as an eco-safe method would also be great. Customers care about this and there is a lot of greenwashing going on in our industry.