16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00058 

Submission Number:
Philip Cote
French 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
As a member of America’s Best Cleaners I have had the opportunity to work with and visit clothing manufacturers in the US and abroad. There is a constant quest by the better manufacturers of textiles and the better operators of retail dry-cleaning to find a working middle ground and universally accepted method of garment care. Currently with the FTC having separate care labeling rules than those of ISO there is a state of confusion. Even though many of the symbols by both organizations do provide the same instructions many do not. We would first suggest a universal acceptance of ISO labeling by FTC. This would allow for the immediate adoption of the Wet-cleaning care label with accepted practical applications. Second regarding the influx of alternative dry-cleaning solutions to Perc (P) a framework of guidelines that would allow for specific solvent characteristics to be adopted allowing for easy testing on the manufacturing side while also protecting the development of eco-friendly alternatives on the garment care side. Specifically characteristics like, KB Value, Polarity, Water Solubility which would allow for certain classes of solvents to be ruled and designated under a pre-existing label with clear guidelines. This could then allow the developers of these alternative solutions to provide this label listing on a MSDS sheets as well as publicly available materials for ease of use and understanding by the textile manufacturers, dry-cleaners and end consumer. Currently large manufacturers disregard existing labeling laws and allow for the import of improperly labeled textiles that are then forced upon U.S. Small Business's to fight a never ending battle of David (the dry-cleaner and consumer together) vs. Goliath (the large textile manufactures and brand licensees). In the end the consumer still looses as large importers continue to flood our markets with inferior and improperly labeled goods to the detriment of our economy. The production of textiles in the U.S. is at an all time low and the U.S. drycleaners are service providers who are left holding the burden. If the FTC is serious about making modifications to the care labeling rules and assisting the United States move towards ecological and economic stability protecting American business and consumers should be the first priority. As it currently stands the labeling is dated, without true merit and enforcement and does not address the rapid developments on both the textile manufacturing and the textile care industries. We request that you take these requests into serious consideration before making any modifications.