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 #00095 

Submission Number:
00095 
Commenter:
woo park
Organization:
Frontier Cleaners
State:
California
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

My Family has been in the Dry Cleaning Industry for almost 40 years. In my experience, most of my customers don’t know the difference between dry cleaning and wet cleaning. Most of my customers assume that when a label says to wet clean the item, they can wash it at home. What they don’t understand is that a “Professional Wet Cleaner” adds extra components such as special soap and conditioners to the garment during the cleaning process so that the garment comes out looking the way the manufacturer and customer intended. After much consideration, I along with many of my fellow “Professional Dry Cleaners” would like to prevent our customers from confusion and dissatisfaction with the garment manufacturer by adding the word “Professional” before the words wet clean on the garment’s label. Today, many garment manufacturers are using and combining different types of fabrics into one garment that make caring for these garments more difficult. Therefore, the “reasonable basis” needs to be clarified to include a wider range of items that are known to be problematic. If the terms on the care label are going to be in symbols only, they need to be symbols with very clear definitions so they can be easily understood and recognized by the consumer and the “Professional Dry Cleaner”. Today, there are different types of dry cleaning solvents available and many do not even use Perchloroethylene (“perc”) anymore. The average consumer does not know how many solvents are available. I am a GreenEarth Cleaner and I see the need for a GreenEarth symbol on garment labels. GreenEarth is well-known to be a gentle solvent and I believe the label explaining that the garment needed to be cleaned in a gentle solvent like GreenEarth would help not only the consumer, but dry cleaners and manufacturers as well. Thank you for consideration.