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 #00030 

Submission Number:
00030 
Commenter:
William Shaffer
Organization:
Shaffer Dry Cleaning & Laundry
State:
Arizona
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

I would like to see the definition for reasonable basis changed so that it includes more specific items for example, spandex, elastic and vinyl. This would be better for dry cleaners because the care label instructions would be more specific and would prevent a lot of garments from being ruined. I come across mismarked care labels on a regular basis, having labels that are consistent would be extremely helpful. Approximately half of my business is wet cleaning, and the rest is dry cleaning- using GreenEarth. I think that there should be more than just perc and hydrocarbon recommended on care labels- especially since I am using a much gentler alternative to these solvents. I would like to have GreenEarth grouped with similar solvents that have low KB values. The industry is trending towards these lower KB value solvents because of the positive environmental aspects of the solvents. Perc and hydrocarbon are becoming less and less popular within the industry and will be gone from use in the future. I think that consumers would not understand a label that just says “wet clean”, the label needs to also have the word “professional”. Otherwise, they might mistake the meaning of wet cleaning for regular at-home washing, which in most cases, would ruin the garment. Care labels should also say “do not wash” so that consumers don’t try and wash the garment at home. This is a very important detail about garment labeling. In cleaning many band uniforms we have found those manufacturers will put on the care label "Dry Clean Only". The uniforms clean best with wet cleaning, but the manufacturers use "dry clean only" because too many uniforms have been ruined by band Moms washing them at home when they have had "wet clean" on the care labels. The manufacturers of these band uniforms have found that if they put "dry clean only" on the care label, the uniforms are then taken to a professional cleaner where the best process of cleaning - usually that is wet cleaning - will be done correctly. They have experienced far fewer problems as a result of this labeling. Wet cleaning is not washing and drying with domestic equipment. The word "professional" must be added otherwise there will be a large number of garments destroyed by consumers who are trying to "wet clean" at home.