16 CFR Part 423; Public Roundtable Analyzing Proposed Changes to the Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods as Amended Project #00017

Submission Number:
Andy Lien
GreenEarth Cleaning
Initiative Name:
16 CFR Part 423; Public Roundtable Analyzing Proposed Changes to the Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods as Amended Project
Matter Number:


A number of issues are considered in the changes to the Care Label Rule. As a professional in the dry cleaning industry with over eight years experience, who started out by operating dry cleaning machines in a package plant, and now conducts training for cleaning staff around the world, I have opportunity to see how these rules affect work on a practical, day to day basis. The dangers of certain dry cleaning solvents to clothing, the operators who use it, and to the environment, has prompted the need for alternative solvents. Some of these alternatives are not organic, including GreenEarth Silicone. It is likely that in the future, other solvents will be introduced which are not organic. My feeling is that we should broaden the definition to include other common solvents which may or may not be organic. When we consider wet cleaning, it is important to understand that professional wet cleaning requires the proper type of washing machine (not consumer or domestic-level equipment), expert programming of the machine (temperatures, agitation, injection of multitudes of chemicals, etc), a supply of the needed chemicals (often three or four different types), and a moisture-controlling dryer. On top of these requirements, the training for staff who sort loads and perform the cleaning must be extensive. All of these is required for satisfactory results, and even then, there are some garments which do not clean well in true wet cleaning (such as structured garments like suit jackets and blazers). Finally, after the garments are clean and dry, they must be finished using tensioning equipment so that the pieces are ready to wear. The tensioning is required to give the clothing their shape and to slightly stretch them back into the proper size. The public does not realize the equipment and training needed and therefore wet cleaning instructions will be misunderstood for home laundry instructions. The awareness level of the public for professional wet cleaning is in an embryonic state and any discussion beyond a wet cleaning care symbol is a cause for confusion. Regarding the reasonable basis required for care instruction on problem items - the #1 problem in dry cleaning today is black cotton/polyester/spandex fabric bleeding onto adjacent white fabric. We know that the disperse dye is set and cleared with an alkaline process, however that does not set the dye into the spandex thread. When the garment is dry cleaned, the stained spandex, which does not have set dye, bleeds and makes the garment unwearable. The care label nearly always says Dry Clean Only. It is unbelievable that manufacturers are not required to test finished, completed garments prior to determining the care instructions. This is just one prominent example; there are others with various trims, polyurethane (a very common problem), leather, beads, etc that fail in dry cleaning despite the care label instructions. The severity is great with perc, less so with alternative solvents but the issues remain. It can be very difficult for anyone to accept responsibility, so often the dry cleaner is left to make it right for the customer (even though he followed the instructions as written). I feel there needs to be more extensive testing, and it must be done with other solvents as well, considering the diminishing prevalence of perc in our industry.