As a member of the fabricare industry 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 The care label should list all appropriate methods of care. If all methods of care are listed we can select the best method of cleaning based on the type of soils and the fabric. When a care label is missing we must examine the garment, quess as to what method is best for the garment, and request that the customer takes a risk with our recommendations, and in the end, hope for the best. If we guess incorrectly, the garment may get damages, thus resulting in an unahppy customer and a bad reputation for the business. That is bad for us. Oftentimes have to pay for the ruined garment even thought we were doing what we thought was best for the garmet and 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 with the approval of the customer. 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 or the advance of technology within the industry. The Care Label Rule conflicts with state laws that call for a ban on perchlorethylene, a common drycleaning solvent and by far the best cleaning solvent for certain garments. We often accept garments that have been purchased outside the U.S. It would be very helpful in the cleaning business if the care instructions found on foreign and domestic labels were in agreement. International care symbols should be utilized on all garments regardless of where they were sold or manufactured. We recently had a Dolce and cabanna coat that the customer purchased in Italy, the garment had no care label and no information as to what the material was made of. Based on our knowledge we recommened wet cleaning and were were able to clean the garment with no adverse risk. 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 thank you for the opportunity to be heard. We as small business need to be heard and we greatly appreciate your assistance in making our business easier to deal with by having proper international labels and proper cleaning instructions on garments. Thank You!
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00078
Executive Cleaners Inc
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915