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 #00029 

Submission Number:
00029 
Commenter:
Manfred Seiter
Organization:
Chemische Fabrik Kreussler & Co.GmbH
State:
Outside the United States
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

1) Professional wetcleaning symbol should be implemented in the new care label. W in a circle is different to conventional household laundry. W in a circle means wetcleaning done in a professional textile cleaning plant. 2)EN ISO 3758:2012 (3rd revision, substitues now version from year 2005) 3) Care instruction - symbols are made for textile care in private households. Symbol in a circle means professional treatment in a drycleaning plant. The textile care recommendation must consider the textile as a whole (f.e. shell, lining, applications)and the textile care treatment should be effective for the most sensitive part of the textile. Furthermore the testing procedures should be defined clearly and easy to understand and testing must be possible in these countries where textiles nowadays are manufactured. 4) Dryclean - dryclean as well as wetcleaning - first of all are professional treatments which cannot be done in private households. The necessary technical equipment in private households is not existing and the know how about textile fibres, dyes etc. is a domain of professional textile care.Drycleaning is a professional textile cleaning treatment, done in closed loop drycleaning machines which use organic solvents as a cleaning fluid. The advantage of using unpolar solvents is that sensitive fibres like cashmere, merino, wool and silk which are the dominating fibres in apparel show no or very little swelling effect. Drycleaning is a very useful textile care treatment for sensitive and often non washable textiles. In industrial drycleaning also heavily soiled workwear, working gloves etc. can be cleaned successfully without contaminating drain water streams. Drycleaning will not contribute to waste water streams, residues from drycleaning industry are collected from professional and certified waste companies. Up to now textile care labels exist only for perchlorethylen and for hydrocarbon solvents. Perc for health and environmental reasons is restricted more and more. Industry is searching for alternatives and it would be fair to consider alternative solvents to be implemented in FTC's update of care labelling rules. The most popular alternative solvents on the market are Decamethylpentacyclosiloxane D5 (GreenEarth solvent), RYNEX 3E and Dibutoxymethane (SOLVONK4). I am the technical director of Kreussler textile chemistry division, responsible for SOLVONK4, so I will only talk about Dibutoxymethane as a solvent in professional drycleaning. SOLVONK4 is a true alternative to perchlorethylen, the most common used drycleaning solvent world wide. SOLVONK4 has ecological and environmental benefits and is dermatologically tested.SOLVONK4 is not persistent and not bioaccumulative. P labelled textiles can be drycleaned with excellent results.In CINET E-News 137, OCT 2012 CINET announced to support new solvents and processes and raised the question in ISO TC 38 "Textiles" to develop appropriate testing procedures for new and promising drycleaning solvents. We would recommend to consider these alternative drycleaning solvents in the revision of FTC textile care labelling rule.