16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00056 

Submission Number:
Matt Mendenhall
Old Town Dry Cleaners, Inc.
Initiative Name:
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915
We are a small family & veteran owned business with a 30 year history. We would like to address the following questions from the Federal Register and will add a few comments at the end: 1. Yes, there is a continuing need for the Rule. A small dry cleaning & laundry business must have clear, concise guidance immediately available in order to select the proper cleaning procedure. Otherwise, it would require extensive examination, testing, possibly require partial dis-assembly of the garment followed by re-assembly and, in the final analysis, guesswork on the part of the small independent operator. This would drive costs up for both the operator and the consumer. 2. Benefits of the rule include, but are not limited to, providing guidance on the prefered cleaning method, prohibited cleaning methods, and precautionary guidance. This saves both the cleaning establishment and the consumer time and money. Consumers need the confidence of knowing there is a high degree of probablility the garment they leave in our care can be sucessfully cleaned. Depending on the garment, and the designer label, some customers can get very emotional over a garment that could not be sucessfully cleaned. This is particulary true of garments with beads and sequins which, more often than not, are excluded from the care label and will not withstand cleaning in more aggressive solvents, such as PERC. 6. Modifications to the rule that would benefit and reduce costs to small business include: ensuring all garments sold in the United States have care labels in English using internationally recognized care label symbols, stating prohibited cleaning methods (i.e., some customers prefer dry cleaning but you seldom see a "dry cleaning prohibited" label), ensuring decorative items such as beads and sequins can withstand dry cleaning in all solvents, if that is the C/L instruction, particularly PERC and indicating any restrictions. Our experience has shown these garments (beaded and sequined) are often the most expensive garments we see in a typical day, they are sold almost exclusively to female consumers, they have the highest failure rate (80% in PERC), and put the small dry cleaning businesses in the position of either having to replace the garment,buy the garment, negotiate with the seller for replacement, and potentially losing a valuable customer--just because we followed the care label instructions. 9. As noted above, allowing garment manufacturers to make a garment with beads and sequins and then disclaim these items on the care label is misleading to the cleaning facility. The typical consumer has no idea this practice is occuring until they have the garment cleaned and the problem arises. This is unfair to both the consumer and the small business dry cleaner. If the consumer bought the garment "on sale", returns are sometimes refused, leaving the dry cleaner and the consumer in a face-off over responsiblity. The bottom line is beads and sequins and other decorative items placed on the garment prior to sale to the retailer need to meet cleaning specifications or the manufacturer needs to be held responsible. 10. It is time to define "wetcleaning" as the technology is advancing in this area to the point where manufacturers of cleaning machines are promoting equipment specifically for this process. Without a clearly defined rule, it is difficult to determine if the machine you are considering investing in will perform as advertised. General Comments: As a small independent business, we strive to deliver a quality product to our customers every day. Good, clear, complete cleaning instructions are vital to our business and they must be comprehensive so we do not accidently damage a garment while following the care label instructions. This is in the best interest of all concerned: the garment maker, the dry cleaner, and the consumer.