16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00054 

Submission Number:
Meagan Preece
Telluride Eco Cleaners
Initiative Name:
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915
Is there a continuing need for the Rule as currently promulgated? The rule is necessary to help me determine the best method of care for my customer’s clothing. Only the manufacturer has knowledge of clean-ability 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 (costs to the business) are needed to determine the safest method of care. We would have to require each customer to sign a release form, allowing us to clean the garment without being liable for any damage,this always creates some doubt in our ability to clean, however we can not be financially responsible for items that do not give us cleaning instructions. What modification should be made to the rule to increase the benefit small business? The care label should list all appropriate methods of care. If all methods of care are listed I can select the best method of cleaning based on the type of soils on the garment or my customer’s requests. When a care label is missing I must examine the garment, possibly take it apart (more costs), test all fabrics and trims (time and chemicals) and in the end, hope for the best. If I guess incorrectly, the customer is unhappy, I am unhappy as customers don’t pay for errors, I will oftentimes have to pay for the ruined garment and likely lose a 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. What modifications should be made to the Rule as to the results of impending changes in technology? 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. I would also like to see professional wet cleaning implemented more on garments, as wet cleaning is most often the only way to get out certain spots. Does the rule conflict with other federal or state laws or regulations? The Care Label Rule conflicts with state laws that call for a ban on perchlorethylene, a common drycleaning solvent. Are there any foreign or international laws, regulations or standards that should be enforced? Cleaning professionals often accept garments that have been purchased outside the U.S. It would be very helpful in this business if the care instructions found on foreign and domestic labels were in agreement. Should the Rule include Professional Wetcleaning? The rule should include Professional Wetcleaning. More of my customers want their dry cleanable garments washed, and for many reasons, including environmental impact, consumer demand and local regulations, I invested time and money in the equipment and staff training. However, I am accepting all responsibility for wetcleaning since the method is not recognized by the Care Label Rule. Certain spots, such as water soluble ones clean much better when using water. Also certain garments such as a white cotton blouse/shirt/pants clean much better when using water. High end designers (ie. Theory) often put one method of cleaning (dry cleaning) on these garments. I know that my customers would not be satisfied with the end result the garment was dry cleaned.I then take the risk by wetcleaning these items. Should the Rule address the development of ASTM care symbols? It would be very helpful if the rule addressed the development of ASTM care symbols. Thank you.