Submission Number: 00050
Received: 11/14/2012 4:11:58 PM
Commenter: Martin Lee McNeese
Organization: McNeese Customs & Commerce srl
State: Outside the United States
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
RE: ‘‘Care Labeling Rule, 16 CFR part 423, Project No. R511915’’
Dear Sir or Madam:
These comments are submitted on behalf of McNeese Customs and Commerce, srl (“McNeese”) of Vicenza, Italy in response to a notice published by the Federal Trade Commission (“FTC”) in the September 20, 2012 Federal Register regarding amending the Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods. These comments are directed to questions 8, 10 and 13 in the notice of proposed rulemaking. McNeese specifically requests that the FTC amend the Rule to update the provision allowing the use of certain care symbols in lieu of written terms by permitting manufacturers and importers to use the symbol system set forth in
either ASTM Standard D5489–07, ‘‘Standard Guide for Care Symbols for Care Instructions on Textile Products,’’ or ISO 3758:2005(E), ‘‘Textiles—Care labelling code using symbols.’’
McNeese is a company organized under the laws of Italy. To stay informed of US textile and labelling standards, McNeese is a member of ASTM Committee D13 on Textiles. McNeese advises European manufacturers, exporters and importers of luxury garments regarding the labeling requirements applicable to such merchandise that is sold in the European and US market.
In reference to question 8, McNeese notes that according to the FTC “Clothes Captioning, Complying with the Care Labeling Rule” guide, care labels often are a deciding factor when consumers shop for clothing. According to Textile Industry Affairs “LAUNDRY ESSENTIALS” CURRICULUM – J. Pullen, “a permanent care label is one that remains legible and attached to a textile product throughout its useful life. Care symbols convey care instructions in a simple, space-saving, and easily understood format.” Space-saving care instructions save manufacturers and by extension consumers time and money. In Europe, its is common to use care symbols alone on a care label. As per 16 CFR Part 423.8 Labeling Exemptions (g) The symbol system developed by the American Society for Testing and Materials (ASTM) and designated as ASTM Standard D5489-96c, Standard Guide for Care Symbols for Care Instructions on Textile Products may be used on care labels or care instructions in lieu of terms so long as the symbols fulfil the requirements of this regulation.
Forty-one years after the Care Labeling Rule was introduced most consumers are sufficiently familiar with the care symbols to be able to care for their garments without written instructions which duplicate the purpose of the symbols. On the other hand, the label should contain written warnings of procedures which consumers or professional cleaners could be reasonably expected to use that would harm the product others being cleaned with it.
In response to question 10, McNeese requests that the Commission amend the Rule since the revised ASTM symbol system causes less confusion and aligns itself with the ISO system which has greater usage in a global economy. Internationally, a circle with the letter “P” inside means “professional dry-cleaning in perc or petroleum. American manufacturers are penalized when their drycleaning labels are found to be non-compliant in overseas markets, or they have to make a duplicate set of labels at considerable expense.
In reference to question 13(A), McNeese would like to point out that according to the Environmental Protection Agency (EPA), wet cleaning is the safest professional method of garment cleaning. It does not use hazardous chemicals, it does not generate hazardous waste, nor create air pollution and reduced potential for water and soil contamination. The specialized detergents and conditioner used in the wet clean process are milder than home laundry products. All the products are disposed of down the drain and easily handled by the local waste water treatment facility