The Proposed Exemption to the FTC's Care Labeling Rule...

Effort to reach more goals of NAFTA

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In an effort to harmonize American clothing labeling regulations with those of Canada and Mexico, the Federal Trade Commission today proposed to allow the use of certain care symbols, rather than words, on the care labels required to be permanently attached to garments. The proposed exemption to the FTC's Care Labeling Rule would be conditioned on the use of detachable explanatory hangtags to accompany the symbols for the first year of use. The request for comments will appear in the Federal Register on November 16. Comments will be accepted for 75 days, until January 31, 1996.

The Care Labeling Rule, enacted in 1971, requires clothing manufacturers and importers to attach care labels to garments, giving full instructions for at least one satisfactory method of care necessary for the ordinary use of the garment, or stating that the garment cannot be cleaned. The label also must warn against any part of the recommended care method that would harm the garment or other garments being cleaned with it. The rule provides that manufacturers and importers must have a reasonable basis to substantiate their instructions and warnings.

In June 1994, the Commission requested public comments on, among other things, whether the rule should be modified to allow the use of symbols instead of words. Most of the comments the Commission received discussed the use of symbols (65 out of 81) and 60 respondents favored using symbols. Supporters said using the symbols would make international trade easier.

Many comments focused on trade with Mexico and Canada, indicating that using symbols used by those countries would further the goals of the North American Free Trade Agreement (NAFTA) because companies could use the same care label on garments offered for sale in any or all of the NAFTA countries. Alternatively, companies could use one label with instructions in three languages (English, French and Spanish) but that would result in long labels. Many comments stated that the use of symbols would cause production costs to decline because the size of labels would be reduced and smaller labels are less expensive.

With respect to consumer benefits, several commenters said that savings from smaller labels could be passed on to consumers as reductions in the cost of clothing. Some comments noted that smaller labels may improve consumer comfort. Others said that symbols would not diminish (and actually might improve) consumer understanding of care instructions because they are simpler, more direct, and more concise than instructions in three languages. Several commenters said that the use of symbols would help consumers, whose primary language is not English, or who cannot read.

The FTC has tentatively approved the use of certain symbols, but now asks for additional comments on the specifics of the proposal. The Commission has tentatively decided to use a symbol system developed by the American Society for Testing and Materials (ASTM), with certain changes, because that system provides symbols for conveying virtually all necessary care information. Moreover, it is compatible with symbol systems used by Canada and Mexico. The Commission also considered the symbol system adopted by the International Standards Organization in 1991 as ISO Standard 3758. The FTC recognizes the desirability of harmonizing with this symbol system that is currently used in Europe. However, the ISO system is not comprehensive enough to convey all the necessary information, and is inconsistent, in some respects, with technology used in the U.S.

The Commission is seeking responses to the following questions regarding the use of symbols:

  1. Will the underlining of the washtub or the machine drying symbol be confusing to consumers? If so, should the Commission "except" this part of the ASTM system from the conditional exemption?
  2. Should the Commission specify the minimum size of the symbols, or are existing requirements of legibility sufficient?
  3. Should explanatory hangtags providing care information in language be required for more than one year?
  4. What types of consumer education should be planned and to what extent are industry members willing to participate in such campaigns?
  5. If the Commission were to grant a conditional exemption, when should it become effective?
  6. Does ASTM's copyright pose a barrier to the use of the ASTM system?

The Commission vote to seek public comments was 5-0. Comments on these questions should be identified as 16 CFR Part 423 -- Comment" and addressed to: Office of the Secretary, FTC, Room 159, 6th Street and Pennsylvania Avenue, N.W., Washington, D.C. 20580.

Copies of the Federal Register notice are available from the FTC's Public Reference Branch, Room 130, from the same address as above; 202-326-2222; TTY for the hearing impaired 1-866-653-4261. To find out the latest news as it is announced, call the FTC NewsPhone recording at 202-326-2710. FTC news releases and other materials also are available on the Internet at the FTC's World Wide Web site at:

(FTC Matter No. R511915)

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