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 #00019 

Submission Number:
Ian Noble
Rick's Cleaners
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

FTC is proposing four specific revisions to the Rule: 1. Allow garment manufacturers and marketers to include instructions for professional wetcleaning on labels. MY THOUGHTS: a) We currently are a high volume cleaners that does not do wetcleaning. b) Customers normally never say a word about care label instructions. That is our job. However, it would be extremely helpful for tags to at least say whether they can or can not be dry cleaned. Many labels we receive have no wording or symbols regarding dry cleaning. This becomes an issue if something was dry cleaned that shouldn't be. The care label should clearly give you instruction one way or the other. 2)Permit the use of ASTM Standard D5489-07, "Standard Guide for Care Symbols for Care Instructions on Textile Products," or ISO 3758:2005(E), "Textiles — Care labeling code using symbols," in lieu of terms. MY THOUGHTS: a)Care symbols without words do not hurt our business. If the symbol itself for dry clean or do not dry clean is present that is all we need. However, I do agree that for specialty cleaners it is important for an explanation to be present (ex: low heat cycle - do not steam press) b) I would estimate that nearly 50% of labels we receive have no symbols or wording referencing dry cleaning. It would be extremely beneficial to a consumer if this information was on the tag. Lots of people use dry cleaners, and consumers have the same right we do to know exactly how something should be cleaned. 3. Clarify what can constitute a reasonable basis for care instructions. Currently, a reasonable basis must consist of reliable evidence, not necessarily testing, supporting the instructions on the care label. The FTC is considering requiring “testing of the garment as a whole” in certain cases. MY THOUGHTS: a) Testing of garments is imperative prior to adding a care label. We have numerous brands and materials that say dry clean only that simply can not withstand the process. This leaves the consumer and the dry cleaner in a bad situation. For example,we have come across Burberry, Ann Taylor, and Zara garments that contain Polyurethane but say dry clean only. Under no circumstance do we dry clean polyurethane anymore because it shrinks up and loses its' shape - even if the care label says dry clean only. b) Garments that are black and white need to be tested for color fastness. The company "White House | Black Market" is the worst about this. All of their products are black, white, or mixed with the two. Although the care label says "Dry Clean Only," 60% of the time the black transfers on to the white. This again is to encourage the testing of all clothing prior to putting the care label on. It should be illegal to have a label without testing the product. c) Another major issue is beads/sequins on garments that have "Dry Clean Only" labels. The issue is that because they are not properly tested, many times the garment itself can be dry cleaned, but the beads/sequins are add-ons that cannot withstand any dry clean solution. This is another major problem for consumers and dry cleaners. This is a direct result of lack of testing. It could easily be prevented if all garments were required to be tested. 4. Update and expand the definition of “dryclean” to reflect current practices and account for the advent of new solvents. Currently only perc and petroleum are specifically recognized under the Rule. The proposed definition change includes other currently available solvents (perc, petroleum, silicone, glycol ether, carbon dioxide, aldehyde). MY THOUGHTS: a)Currently Perc and Petroleum are covered under the care label laws. Our plants either use Perc or Petroleum. 40% of our business is cleaned in Perc and 60% Petroleum. We will be switching to all Petroleum soon. The only problem I have with general "Dry Clean Only" instructions is that many items that have beads/sequins have a better chance surviving Petroleum vs Perc.