16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00067 

Submission Number:
00067 
Commenter:
Ben Evans
Organization:
Ben's Dry Clean Super Center
State:
Texas
Initiative Name:
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915

I am in the dry cleaning business and I am commenting on the FTC?s proposed amendments to 16 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. 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. There are so many new man-made fabrics and combination of other fabrics in today's garments that manufacturers are choosing to use that is is impossible for anyone but the manufacturer to know the best method of cleaning any particular 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 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. The labels should include more modern types of solvent. Cleaning professionals often accept garments that have been purchased outside the U.S. It would be very helpful in this business if the care instructions found on foreign and domestic labels were in agreement. The rule should 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. It would be very helpful if the rule addressed the development of ASTM care symbols. I have found a Wetcleaning symbol (Circle with W) on several garments but had to do some research to find a definition. I appreciate the opportunity to share my concerns with the Care Label Rule as it is now and proposed amendments. Thank you for accepting my comments. If you have any questions or would like any additional information please contact me at [redacted]. Sincerely, Ben Evans