16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00115 

Submission Number:
00115 
Commenter:
Dan Brunette
Organization:
City Cleaners & Laundry
State:
Wisconsin
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 to 16 CFR Part 423, and how they will affect my ability to operate a business and serve my customers. I run a small family owned drycleaning and laundry business that has been around for over 60 years. We look at care labels every day. We have to. Over the years, manufacturers have taken more and more short cuts in making garments. The old verbage - "they don't make 'em like they used to", is very true in the garment business. Manufacturers are also using a variety of trims to make a garment look more appealing to the prospective buyer. These trims can take a normally washed item and make it "dry clean only". Without these labels, it is almost impossible to determine acceptable care procedures. The care labels have also saved our business countless dollars in replacement costs. We usually get at least one garment a year that does not withstand the acceptable care instructions printed on the label. Whether it is due to mis-labeling a garment or perhaps a manufacturer did not take into account a specific type of trim, sometimes a garment is still damaged in the cleaning process. After independent analysis', we have never been liable for a manufacturer's mistake. With all the improvements in alternative solvents, I think an expanded rule to include additional solvents will be very benificial. Even in a small town in northern Wisconsin, we are looking forward to replacing our Perc drycleaning machine. Personally, we are looking and watching to see how a new solvent is going to perform. It has taken the market by storm and we think may be the solvent of the future and that would be the SolvonK4 solvent from Kreussler. At the recent Clean Show in Vegas, there was extensive coverage of this new solvent and you may want to look particularily close at this solvent. I can tell you we are watching it closely as this may be our choice of solvent in the future. I would also expand the rules to include more information on "wet cleaning". More and more drycleaners are expanding into this area as well as an alternative to drycleaning. We have also done washable garments over the past several years. Society is changing in that your don't see people wearing wool suits and drycleanable garments. More of the professional services (doctors, lawyers, etc.) are wearing casual garments more than anything. They are wearing more vivid colors and garments with trims. This have made the care label more of a necessity than anything when it comes to proper cleaning procedures. I must say, of all the labeling, the one that it the worst is the label that simply says, "Do not wash, Do not dryclean". We see this a lot on fancy dresses (prom dresses), where the manufacturer will take a dry clean only fabric and put plastic beading on it that will melt in dry cleaning. This effectively makes a garment unservicable. We always let the customer know when they bring one of these items in and we simply give it back to them with regrets and it is then that they realized that they bought a disposable garment. Unfortunately, that disposable dress or garment will usually cost several hundred dollars sometimes and the consumer is always hurt. If I could make one change, it would be that all garments must be service-able to some extent. Manufacturers should not be allowed to put a label on a garment that says "do not wash, do not dryclean". It is unfair to me - since I don't get any business out of it, and I become a bearer of bad news - and it is unfair to the consumer who gets stuck with a dirty garment after only wearing it once or twice. 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] Thank you, Dan Brunette