16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00102 

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16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915
Professional Wet Cleaners Associations, Inc. 1464 Cary Avenue San Mateo, CA 94401 August 29, 2011 Donald S. Clark Secretary of the Commission Federal Trade Commission 600 Pennsylvania Ave., NW Washington, DC 20580 Dear Commissioner Clark: The Professional Wet Cleaners Association (PWA) is writing to your office to express our strong support for a new ‘Professional Wet Clean’ care label. We recommend that all items which require professional cleaning or where professional cleaning is recommended be labeled ‘Professional Wet Clean’ if there is a reasonable basis for this new label. The Professional Wet Cleaners Association is a non-profit organization make up of cleaners exclusively using professional wet cleaning technologies. Our members are approaching 100 and growing rapidly, primarily located in California. Since the mid-1990s, professional wet cleaning, a process for cleaning and finishing delicate garments typically labeled ‘Dry Clean’ or ‘Dry Clean Only,’ has grown substantially around the world and in the United States. In California alone there are over 200 dedicated professional wet cleaners who are successfully wet cleaning garments they had previously dry cleaned. In addition to dedicated professional wet cleaning facilities, there are many dry cleaners in the United States who also have equipment that can be used for professional cleaning. As professional wet cleaning has grown, so has an infrastructure of equipment manufacturers, detergents manufactures, service technicians, and skilled trainers. PWCA believes that the current care label laws are unfair and deceptive to the consumers that wear garments labeled ‘Dry Clean Only’ or ‘Dry Clean’ when in fact these garments can also be successfully wet cleaned. The primary difference between dry cleaning and wet cleaning is that wet cleaning uses water as a cleaning solvents and biodegradable detergents as cleaning agents. Now, consumers have an option for how their delicate garments can be cleaned. The care label should be inform customers of these options. Most the PWA members converted to professional wet cleaning from perc dry cleaning and are now successfully wet cleaning the full range of garments they had previously dry cleaned. This includes traditional business apparel as well as couture garments such as Chanel, Versace, Dolce and Gabanna, Gucci, Vera Wang, Louis Vuitton, just to name a few. Therefore, garments labeled ‘Dry Clean’ or ‘Dry Clean Only’ that can be successfully wet cleaned is unfair to any professional wet cleaner by misinformation existing and potentially new customers about how the garment should be serviced. Customers come into professional wet cleaners every day and ask for their garments to be dry cleaned because the garments are labeled ‘Dry Clean’ or ‘Dry Clean Only’. If we tell them we will be wet cleaning their garments they may decide to go to a dry cleaner. If we say “yes” we are deceiving our customers. This dilemma of either lying to the customer or potential losing existing or new customers makes professional wet cleaning unappealing to many dry cleaners. This is especially true because most owners of dry cleaners are first generation immigrants. The lack of a ‘Professional Wet Clean’ care instruction is also unfair to professional wet cleaners because it does not provide us with information helpful in processing of the garment. The ‘Professional Wet Clean’ care label system developed by the International Standardization Organization (ISO) provides three variations of the wet clean label which would help inform the wet cleaner on best practices for processing the garment. Landlords are increasingly aware of the hazards associated with toxic dry cleaning solvents or dry clean solvents that are combustible. Many professional cleaners have been forced to close their doors because landlords are concerned about dry cleaning hazards and are unaware that there is a non-hazardous alternatives, namely professional wet cleaning. In this way, the current care label law is unfair and deceptive to landlords who are unaware of the professional wet cleaning option and unfair to cleaners who cannot obtain a lease renewal due to landlord ignorance about professional wet cleaning.. Many consumers avoid purchasing delicate garments labeled ‘Dry Clean’ or ‘Dry Clean Only’ in order to avoid health hazards associated with dry cleaning solvents. Customers have stated 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 odor from clothing that have been dry cleaned. A ‘Professional Wet Clean’ care 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 compared to perc dry cleaning. 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. If you have any questions, please contact with PWC President Gus Chang at 707-486-8934. We look forward to working with the FTC on this important public policy issue. Sincerely, LIST OF PWA MEMBERS – Ventura Marina Village Cleaners 2415 Harbor Boulevard Ventura, CA 93001-3904 Sun Choi (805) 642-0445 Plaza Cleaners 1730 E Ave De Los Arboles # F Thousand Oaks, CA 91362 Peter Jung 805) 493-2715 Los Angeles Point Dume Cleaners 29211 Heathercliff Road Malibu, California 90265 Michael Sunwo (310) 457-3606 Los Angeles Colony Cleaners 3872 Cross Creek Road Malibu, CA 90265 Mina Mallari (310) 456-6202 Sun Hill Cleaners 8846 Foothill Boulevard CA 91040-1925 Janet Kwon (818) 353-1808 Buckboard Cleaners 1465 East Valley Boulevard Alhambra, CA 91801-5239 Nam (626) 284-5450 JC's Cleaners 1331 East Carson Street Carson, CA 90745-1631 Brian Yu (310) 518-1064 Fay Cleaners 1168 East Artesia Boulevard Long Beach, CA 90805-1555 Lisa Tsan (562) 422-3061 OK Cleaners 2625 North Garey Avenue Pomona, CA 91767 Lawrence Lee (909) 392-3927 Orange Norton's Cleaners 204 East Yorba Linda Boulevard Placentia, CA 92870-3417 Jack Norton (714) 524-7130 One Day Cleaners 26012 Marguerite Pkwy # I Mission Viejo, CA 92692-3263 Sang Im (949) 582-5305 San Bernardino Clean 4 Less Cleaners 4028 Grand Ave # D Chino, CA 91710-5486 Davis Lee (909) 591-6378 Golden Hanger Cleaners 883 West Foothill Boulevard Upland, CA 91786-3727 Chong Kim (909) 982-1915 Natures Best Cleaners 8782 19th St. Rancho Cucamonga, CA 91701 Sung Park (909)989-4777 Riverside Palm Cleaners 10247 Magnolia Avenue Riverside, CA 92503-3440 Kyong Ha (951) 688-0450 Natures Best Cleaners 364 S. Indian Canyon Dr. Palm Springs, CA 92262 Jung Choi (760)320-8414 San Diego Sunny Fresh Cleaners 8849 Villa La Jolla Dr # 305 San Diego, CA 92037-1958 Hwa Lee (858) 455-0071 Boulder, CO Plaza Cleaners 2610 Broadway Street Boulder, CO 80304-3542 Seo Oh (303) 442-9247 Newcastle, WA Newcastle Cleaners 6920 Coal Creek Parkway SE Ste. 5. Newcastle, WA 98059 Glen Kim MENDOCINO MASTER CLEANERS 502 South State Street Ukiah, CA 95482-4911 Sung Kim 707-462-4129 SONOMA NATURES BEST CLEANERS 915 Lakeville St. Petaluma, CA 94952 Gus Chang 707-486-8934 TIP TOP CLEANERS 33 Henry Street Cotati, CA 94931-4232 Chong Lee 707-578-1626 LAKESIDE CLEANERS 4211 Montgomery Drive Santa Rosa, CA 95405-5306 Ho Choe 707-539-6525 MARIN PACIFIC HEIGHTS CLEANERS 2631 Bridgeway Sausalito, CA 94965-3402 KARL HUIE 415-331-3015 CLEAN LOOK CLEANERS 743 East Blithedale Avenue Mill Valley, CA 94941 YONG SIM 415-381-3447 FAIRFAX FRENCH CLEANERS 173 San Marin Drive Novato, CA 94945-1209 YONG CHONG 415-898-2040 SACRAMENTO COUNTRY CLUB CLEANERS 2612 Watt Avenue Sacramento, CA 95821 PAUL LEE 916-482-6166 FOLSOM CLEANERS 316 East Bidwell Street Folsom, CA 95630-3115 CHONG JIN LEE 916-983-2378 CONTRA COSTA BOB? CLEANERS 777 23rd Street Richmond, CA 94804-1465 SERGIO RIOS 510-236-3471 SAN FRANCISCO VERMONT CLEANERS 600 Vermont Street San Francisco, CA 94107-2636 BENSON XU 415-647-8080 BUDGET CLEANERS 536 Divisadero Street San Francisco, CA 94117 YAK LEE 415-552-3736 ALAMEDA HESPERIAN CLEANERS 15848 Hesperian Boulevard San Lorenzo, CA 94580 SUNG LEE 510-481-5825 MV HOLYDAY CLEANERS 40093 Mission Boulevard Fremont, CA 94539-3680 DALMO LEE 510-656-8818 SAN JOAQUIN A-1 CLEANERS 136 West Walnut Street Stockton, CA 95204-5730 MARSHA TAKEDA 209-463-4952 SAN MATEO PRESS ON CLEANERS 1464 Cary Avenue San Mateo, CA 94401 JULI ROH 650-342-2987 ABC CLEANERS 445 Old County Rd San Carlos, CA 94070 PHILIP CHEN 650-592-6328 SANTA CLARA NATURES BEST CLEANERS 1281 West El Camino Real Sunnyvale, CA 94087 PETER XU 650-969-0469 BL CLEANERS 171 Branham Ln # 4 San Jose, CA 95136-2339 JEAN CHA 408-224-4380 SAN FRANCISCO Pacific Heights Cleaners 2437 Fillmore Street San Francisco, CA 94115 KARL HUIE 415 567 5999 MARIN Pacific Heights Cleaners 2631 Bridgeway Sausalito, CA 94965 KARL HUIE 415 331 3015 OREGON Vanity Cleaners 1954 NE Highway 101 Lincoln City, OR 97367 Tae-Hwan Kim 541-829-1138 GLENDALE The Cleaning Store 1225 N. Pacific Ave. Glendale. CA 91202 KUN SONG (213)235-7277 Norvell Basscleaners 3323 State St. Santa Barbara, CA 93105 Sergio Castro (805) 687-8113