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 #00051 

Submission Number:
00051 
Commenter:
Martin Lee McNeese
Organization:
McNeese Customs & Commerce srl
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

11-14-2012 RE: ‘‘Care Labeling Rule, 16 CFR part 423, Project No. R511915’’ Dear Sir or Madam: These comments are submitted on behalf of McNeese Customs and Commerce, srl (“McNeese”) of Vicenza, Italy in response to a notice published by the Federal Trade Commission (“FTC”) in the September 20, 2012 Federal Register regarding amending the Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods. These comments are directed to question 13 in the notice of proposed rulemaking. McNeese specifically requests that the FTC amend the Rule to update the provision allowing the use of certain care symbols in lieu of written terms by permitting manufacturers and importers to use the symbol system set forth in either ASTM Standard D5489–07, ‘‘Standard Guide for Care Symbols for Care Instructions on Textile Products,’’ or ISO 3758:2005(E), ‘‘Textiles—Care labelling code using symbols.’’ Concerning question 13, McNeese advocates that US and foreign manufacturers can only benefit from the FTC allowing the use of the symbol system set forth in either ASTM Standard D5489-07 or ISO 3758:2005(E) since the two systems are similar, compatible and easily understood by consumers in the USA and in Europe. Allowing the use of either labeling system would shorten labels making them easier to read and understand. Shorter labels are less abrasive on the skin, are more aesthetically pleasing on a garment, and are therefore more likely to stay on the garment throughout its useful life, ensuring that the consumer’s need to care for the garment is served. Should the FTC have any questions regarding these comments, please contact the undersigned at info@mcneesesrl.com .