16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00063 

Submission Number:
00063 
Commenter:
Charles Enderlin
Organization:
Oak Forest Cleaners
State:
Arkansas
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. The care labeling rule is necessary for the consumer and the drycleaner to determine how to care for the garment. Care methods should be Dry Clean Only, Clean by Any Method, or Cannot be Cleaned. Dry clean only is necessary to for garments that would shrink if washed. Examples are wool, cotton, rayon, silk. The “Clean by any Method label would offer the consumer and the dry cleaner the option to select the best method to remove stains and dirt from the garment. I cannot think of any fabric that can be washed that cannot be dry cleaned. This classification would require the manufacture to select fabrics, dyes and components that are stable and benign to the environment. Perchlrorethylene is being regulated out of use. Most of the remaining solvents are similar in cleaning characteristics. An exception is now made for cleaning in Perc because it may dissolve certain trim, beads, and dyes. This exception may not be necessary in the future. I do not feel that wetcleaning is a viable alternative to dry cleaning. A designation for wetcleaning is too narrow a classification. This classification should be a consumer elective. Drying instruction appear to be directed at solving the problem of shrinkage in the manufacturers favor. I would question why a garment would need to be lined dry, dry flat, or do not wring if the garment were properly pre-shrunk I do feel that manufacturers should be responsible that a merchantable garment should be produced.