|Received:||7/1/2008 1:44:23 PM|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
Comments:The definition of RECYCLED CONTENT stated in 260.7 GUIDES FOR THE USE OF ENVIRONMENTAL MARKETING CLAIMS does not completely represent nor compensate for innovation in the textile industry. One aspect of our industry for many years has operated under lean manufacturing principles. The goal of zero waste in producing raw materials has resulted in nothing entering the solid waste stream. Down cycling is common practice. However, reuse of waste material or up cycling represents innovation and forward thinking in our industry. For example during synthetic yarn extrusion, the machinery creates yarn waste when switching from one product to another. This WASTE YARN would never enter the solid waste stream. It however would be sold and down cycled into a product less than its original value (i.e. fiber fill in toys). The challenge and innovation would be to create raw material of equal value from the waste product. The scope as stated does however represent innovation in closing the loop for consumer goods. Reclamation of textiles that are converted back into raw material is not a common practice. One example would be the carpet industry that has started to close the loop. Reclamation programs are in place to collect old commercial carpet. The old carpet is reprocessed and new raw materials manufactured. Another example would be an apparel manufacturer who takes back polar fleece jackets. The jacket fabric is reprocessed into new polar fleece and ultimately new jackets. Costs, transportation logics and other factors prevent closed loop processes to be common practice in the textile industry as a whole. We understand that the guidelines are for multiple industries. However the scope should be enlarged to cover new and immerging practices for the textile industry.