16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00073 

Submission Number:
Augustine Chang
Initiative Name:
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915
FTC 600 Pennsylvania Avenue Washington, D.C. 20580 Professional WetCleaners Associations, Inc. 1464 Cary Avenue San Mateo, CA 94401 August 18, 2011 Re: Garment Care Label Review To Whom It May Concern: We are writing to your office to express our strong supports of the recent review of garment care labeling specifically with respect to Professional Wet Cleaning. Professional Wet Cleaning methods for dry cleaning only garments have been successfully cleaned and finished by Professional Wet Cleaners for the past decade in the United States and around the world, with a stronger concentration of use in the State of California. Today, the success of well over 120 dedicated Wet Cleaners in California who clean an aggregated volume of over 75 million garment pieces annually speaks for itself. These conservative figures do not even include the dry cleaners that are currently mix-users of chemical solvents and are in the process of conversion or who are trying to emulate Wet Cleaning on their own methods somehow. Professional Wet Cleaners believe that the care label laws are unfair and deceptive to the consumers that wear Dry Clean Only garments when in fact these garments can also be Wet Cleaned just as well. The primary difference of dry cleaning and wet cleaning is that wet cleaning does not involve the usage of any toxic chemicals: all detergents are biodegradable. Now, consumers have an option of choosing whether to Dry Clean or Wet Clean their garments. As a current and veteran member of the Board of Directors, past President of the North Bay Chapter for Korean Drycleaners Association of Northern California and with twenty-eight (28) years of former chemical (Perc) dry cleaning experience, I personally advocate strongly the addition of a Professional Wet Cleaning Label. Currently there are many organizations that teach/train to be wet cleaners and some provide certifications. At many trade shows we see an abundance of manufacturers, equipment, drying cleaning machines, tensioning machines, biodegradable detergents and conditioners, including major wool manufacturers that are now part of this growing professional wet cleaning network. As an owner and operator, many landlords are increasingly aware of air, ground and water contaminations on their properties due to VOCs. And many small business owners are forced to close their doors, due to any possible litigation from the landlords or from any other agencies. The Professional Wet Cleaning technology that we use does not cause any such issues and it is truly eco-friendly. We also strongly believe that adding a Professional Wet Cleaning Label should be a part of the FTC ruling so that cleaners who face eviction notices from the landlords can convert to the Wet Cleaning technology and continue to serve the public and contribute to society by employing people and paying taxes. Many consumers avoid purchasing certain garments due to the restrictive Dry Clean Only label. This decision hinders not only the success of dry cleaning owners but also greatly restricts the growth of retail purchases. The major factor is that dry-cleaning chemicals cause allergic reactions to their skin and body. This includes skin redness, rashes, and sometimes headaches. Many consumers also state that they cannot tolerate the toxic odors that emanate from dry cleaned clothing. Rather than endure such physical irritations, more and more consumers avoid purchasing clothing with a Dry Clean Only label all together. The addition of a Professional Wet Cleaning Label would enable consumers to freely purchase and wear a wider range of clothing since wet cleaning would enable a safer and healthier alternative cleaning method. Many Wet Cleaners have cleaned couture garments such as Chanel, Versace, Dolce and Gabanna, Gucci, Vera Wang, Louis Vuitton, just to name a few. These brand name garments are cleaned on a regular basis by many Wet Cleaners throughout the United States and the world. It is clear that, indeed Professional Wet Cleaning does work with a tremendous array of manufactures behind this technology. The impact of earth contamination is almost non-existent, it is safer and healthier for Wet Cleaning owners, employees, and best of all the benefits to the consumers and our economy are tremendous. We believe that the Professional Wet Cleaning care label should be a part of the garment care label alongside of dry-cleaning. In doing so, the label provides an equal opportunity to professional wet cleaners to perform openly alongside traditional dry-cleaners and provide more choices to the consumer. In the National Clothesline Aug. 2011 Issue, the dry cleaning industry’s monthly magazine, an article that compares many different cleaning solvents, including wet-cleaning, concluded that the quality of professional wet cleaning is equal to dry-cleaning without causing any damage to the garments, in terms of its color, shape, or size. The motto of a prominent environmental company, 7th Generation, speaks of the importance of social responsibility: “In our every deliberation, we must consider the impact of our decisions on the next seven generations.” - From the Great Law of the Iroquois Confederacy. We all have a social responsibility to protect and inform the consumer population about what is true and correct. In addition, this great nation which has been a forerunner of innovation and success should lead the way for other nations to follow its exemplary decisions in ensuring the public well-being of its citizens as well as preserving Mother Nature and the environment that we as humans have been entrusted with. Sincerely, Gus Chang President