Submission Number: 00007
Received: 10/10/2012 4:12:33 PM
Commenter: Ryan Hames
Organization: Martinizing Dry Cleaning
Agency: Federal Trade Commission
Initiative: 16 CFR Part 423 - Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods (the “Care Labeling Rule”); Project No. R511915
Attachments: No Attachments
I'd like to offer a few comments on the new rule. My understanding is that the FTC is now recognizing GreenEarth as an alternative dry cleaning solvent to Perc and hydrocarbon. However, the ASTM's 2007 guidelines do not allow care instructions for any solvent except perc and hydrocarbon. These guidelines will need to be updated to reflect GreenEarth as a cleaning option for consumers.
Also, now that wet cleaning has become recognized under the new rule, I think the way the FTC wants to incorporate wet cleaning on labels could confuse consumers and potentially impact professional cleaning businesses. As written, the term "Professional" would not need to be used to describe "Wet Cleaning". This could create a case where the consumer, who has never heard of wet cleaning, thinks that they can now wash garments at home because the label is no longer clear about the risk. Consumers just don't understand professional cleaning (wet or dry), so the risks are not clear to them.
The new rule should clarify that wet cleaning is a professional cleaning process like dry cleaning and that it is not to be attempted at home. Thanks!