16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00066 

Submission Number:
00066 
Commenter:
Brad  Overmoe
Organization:
Red Hanger Cleaners
State:
Utah
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 rule is 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. Manufacturers often sell garments that are not cleanable by any method, thus leaving the drycleaner to deal with their problem. If care labels are not required, manufacturers will be relieved of any responsibility for cleaning the garment. As it stands, the manufacturer is required to give at least one method for cleaning the garment. 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. The care label should include both drycleaning and wetcleaning instructions. IE, whether both, or only one of these methods is acceptable for cleaning the garment. Symbols are OK as there are generally accepted symbols which everyone knows or should know.