Sami Designs LLC et al., File No.0823194, Proposed Consent Agreement
Please see the attached file for my comments in their entirety. In conclusion, I suggest that there are steps that can be taken and information that can be found that will ensure a more honest and fair marketplace for consumers concerned about the environmental impact of their textile choices, and these should be addressed before the proposed orders are made final. While the environmental friendliness of a process or product will always be somewhat subjective, it seems clear that intuitive language, clear protocol and publicly accessible certifications--applicable to the whole end product or all parts of the product and the processes involved in their production--would help retailers to more clearly present the advantages of their products to consumers. Contrary to the Commission’s statements, there is apparently some evidence to support the idea that bamboo fabric is anti-microbial. Before finalizing the proposed orders, it seems appropriate that thorough testing of each brand of fiber from regenerated cellulose from bamboo be undertaken and the results analysed and published. In fact, it may have been more appropriate to do so before making the charges or publishing the alert in the first place. Finally, labelling the fiber in question as simply “bamboo” may be false by the FTC’s definition and is ambiguous given the multiple processes by which to get bamboo plants into a form usable in textiles, but it was not intended to be “deceptive” as is being charged, information as to the regenerated nature of the fibers in bamboo fabric was widely available to consumers and the initial fiber product is sold as simply “bamboo fiber” which affected the language used throughout the whole supply chain from yarn through finished goods. A more precise generic term would be welcome, such as to allow for differentiation between conventional rayon and the patented processes of the fiber manufacturers. I suggest that it is important to consider that the use of the word or variations of the word “bamboo” is appropriate in describing or naming a textile or textile product made with ‘bamboo fibers’ because the raw material from which the cellulose is derived can be an important defining feature of a product in any case. Please consider taking steps to bring clarity and trust into the increasingly environmentally conscious marketplace of textiles by helping businesses find the truth in their supplier’s claims with testing and certification and providing language and standards applicable to the as yet nameless processes used by Hebei Jigao and other suppliers instead of or before finalizing the proposed orders.