16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00061 

Submission Number:
00061 
Commenter:
Christa Hagearty
Organization:
Dependable Cleaners
State:
Massachusetts
Initiative Name:
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915

As a member of the fabricare industry I am commenting on the FTC’s proposed amendments to16 CFR Part 423 and how they will affect my ability to operate a business and serve my customers. Is there a continuing need for the Rule as currently promulgated? Yes, the rule is absolutely necessary to help me determine the best method of care for my customer’s clothing. Only the manufacturer has knowledge of cleanability of all components of a garment and uses a “reasonable basis” for care instructions on the label. If a care label is not attached to a garment, extra time (costs to my business) and materials (also costs to the business) are needed to determine the safest method of care. What modification should be made to the rule to increase the benefit small business? I beleive that the care label should list all appropriate methods of care. If all methods of care are listed I can select the best method of cleaning based on the type of soils on the garment or my customer’s requests. When a care label is missing I must examine the garment, possibly take it apart (more costs), test all fabrics and trims (time and chemicals) and in the end, hope for the best. If I guess incorrectly, the customer is unhappy, I am unhappy as customers don’t pay for errors, I will oftentimes have to pay for the ruined garment and likely lose a customer. Listing all appropriate methods of care would be a benefit to the fabricare professional. As the care label rule is now I accept responsibility and liability for processing a garment in a method not listed on the care label. What modifications should be made to the Rule as to the results of impending changes in technology? The current definition of drycleaning is very limiting and includes fluorocarbon, a solvent that was been regulated out of existence toward the end of the last century. I want to change to a new solvent, which involves purchasing a costly new cleaning machine, but am hesitant knowing that the solvent or process is not recognized by the Care Label Rule. Testing and acceptance in labeling need to allow for updated technology. The Care Label Rule should not curtail technological advancement of the fabricare industry. The rule should also include Professional Wetcleaning. More of my customers want their drycleanable garments washed, and for many reasons, including environmental impact, consumer demand and local regulations, I invested time and money in the equipment and staff training. However, I am accepting all responsibility for wetcleaning since the method is not recognized by the Care Label Rule. Thank you for your consideration. - Christa Hagearty