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 #00065 

Submission Number:
00065 
Commenter:
 Knox
Organization:
Johnson Cleaners UK Ltd
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

We file this comment on behalf of Johnson Cleaners 340 plus dry cleaning stores in the U.K. Care labels in the U.K. are not governed by FTC rules, nevertheless we believe Europe’s experience modifying its own care labeling system could be helpful to the Commission’s efforts to update its Care Labeling Rule. While regulatory oversight and solvent choices in Europe are different from the U.S., we wrestle with many of the same issues. There is no EU-wide mandatory regime for care instructions, but industry producers and retailers in EU Member States follow a voluntary regime (in some states, it is mandatory) using GINETEX symbols as a basis for the ISO standard applied across Europe. Like the U.S. the majority of dry cleaners in Europe continue to use perc, however that is changing. France has initiated a ban on perc and many countries are looking at tightening their regulatory stance. Hydrocarbon is not widely used in Europe. Johnson Cleaners uses GreenEarth silicone across approximately 90% of our estate, with a view to a complete roll out in 2013. In practice, Europe labels according to the ISO 3758:2012 Standard. Fashion is a globally interdependent business. We strongly urge the Commission to allow care labels derived from the ISO as well as the ASTM. Separately, we believe the ASTM and the ISO symbols need to be updated to improve their ability to ensure compliant, proper care of garments. First, neither standard recognises alternative solvents. We are the U.K.’s largest dry cleaning chain and we have using GreenEarth silicone for more than 10 years, because its non-organic characteristics are better for fabrics and the environment. Recognition of GreenEarth silicone is long overdue. The letters inside the “Professional Textile Cleaning” circle need updating as well. The current circle F, instructing against use of perc when aggressiveness is a concern, should include GreenEarth silicone (and any other appropriate solvent) in its definition. Circle P, currently signifying perc or petroleum, should be expanded to designate “Any Solvent”. Second, wet cleaning instructions need clarification. There is great controversy in Europe over the latest care labels for wet cleaning. Consumers do not understand what wet cleaning is and instructions for it have proven very confusing. The U.K. Fashion & Textile Association has chosen not to promote wet cleaning at this stage as a result of this risk. Wet cleaning recommendations need to include terms such as “Professional Wet Clean” and/or “Do Not Wash” to ensure that garments needing professional cleaning are not washed at home. We applaud the FTC’s effort to modernize its definition of dry cleaning by recognizing alternative solvents, but question the wisdom of lumping them together. Glycol ethers and aldehydes can be aggressive on fabrics and components, in some instances, more so than even perc. Recognizing them without a requirement for testing and symbol classification to prevent damage could harm rather than protect consumers and their garments. We support the Commission’s intention to clarify reasonable basis and would like to see the examples go even further. As the FTC itself has recognised, manufacturers low label to avoid risk. The Rule does not protect the cleaner from liability, but more explicit reasonable basis provides us important protection. We know from cleaning more than 200 million pounds of clothes with GreenEarth silicone that we can safely process virtually any fiber, component or finish. This is not true for other solvents we have tested. The Commission would be well served to further expand its proposed clarifications for reasonable basis beyond dye bleed/transfer, beads, sequins and buttons to include other commonly encountered problems. Specific examples would include elastics, vinyl, plasticizers, acetates, triacetates and certain sizings and finishes. Thank you for the opportunity to voice our views.