16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00022 

Submission Number:
00022 
Commenter:
Sally Conant
Organization:
Association of Wedding Gown Specialists
State:
Connecticut
Initiative Name:
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915

Accurate care labels are especially important with regard to wedding and other specialty gowns because they are so costly both in dollars and in sentiment. Words at the point of sale are more useful to most brides, who can rarely read symbols. Also, words are more useful to brides when they ask a potential cleaner about the care the gown will receive. English is the most useful language as it is nearly universal, but if a second language is required, Spanish is a good choice. It is widely spoken in the United States and Canada, and as a Romance language, it can be understood in many European countries. Currently care instructions need not be the best or only way to clean a garment. In the past many designers/manufacturers specified “Dry Clean Only” to protect against the careless use of water but this instruction is insufficient because some dry solvents damage decorations on wedding and specialty gowns. Of the dry solvents perchloroethylene, arguably the solvent most widely used by dry cleaners, damages almost all decorations on wedding gowns, and it also dulls the finish of silk gowns. Hyrdrocarbon is safe for almost everything as is silicon dioxide. However, dye bleeds can be a problem in silicone dioxide. Carbon dioxide destroys acetate linings in gowns and also damages most beading. The new Solvon K4 System is only a little less aggressive than perchloroethylene and can also damage certain decorations. Responsible care should include testing. With regard to today’s emphasis on wet cleaning, water has caused much heartbreak for brides who do not realize professional wet cleaners and often those who advertise themselves as green cleaners wash gowns in water. It is almost impossible to wetclean silk gowns successfully. Silk gowns washed in water are almost always ruined because water disturbs the sizing that gives the fabric body and sheen. Also, the various types of fabrics used for the exterior and interior of the gown react differently to water, and “bubbles” or fiber distortions occur. Worse, once a silk gown is unsuccessfully washed in water there is nothing that can undo the damage. About once a week, it falls to me to give an unfortunate bride this sad truth. If nothing else, wedding gown care labels should caution against the use of water. Designers/ manufacturers have learned to take refuge in the instruction “Spot Clean Only,” which is currently a legitimate instruction but provides extremely unsatisfactory results from the point of view of the consumer. Some go farther still and instruct “Do Not Dry Clean. Do Not Wash,” which is also a legitimate instruction but is even more frustrating to the consumer because it suggests the garment, no matter how much it cost, is in effect a throwaway. Our association provides care labels to designers at no charge, and we currently use language suggested by the Drycleaners and Laundry Institute. Professionally Dry Clean Only In Petroleum Solvent Short Cycle-Tumble Dry on Low Heat Experienced cleaners can choose whether to take the responsibility for cleaning the garment in something other than petroleum and/or which new alternative solvents might safely be used. Obviously our current suggestion would not be appropriate across the board for any new regulation you devise, but clearly “Dry Clean Only” is not sufficient. On the other hand, requiring designers and manufacturers to determine the proper solvent for decorations is not practical, the time and cost involved in testing would be a significant burden. Perhaps a compromise would be: Preferred Care: Spot Cleaning Do Not Wash Safe in Some Dry Solvents Test before Using Dry Solvent In any case precise language is needed for wedding and specialty gowns. These garments are very special indeed, and the consumer needs to be protected against the loss of a significant investment which is not only financial but also--and perhaps even more importantly—emotional.