Submission Number: 00052
Received: 11/14/2012 11:13:19 PM
Commenter: Sally Ocampo
Organization: Eco-Logic Dry Cleaners
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
1) Although we are very pleased to see that Green Earth solvent is now recognized in the new Rule as an alternative to traditional solvents, we are concerned that the Rule advises manufacturers to use dry cleaning symbols from the 2007 ASTM guidelines only. We would like to see the ASTM guidelines updated so that manufacturers may advise consumers to choose environmentally friendly dry cleaning options as well, such as those offered by Green Earth cleaners.
2)We are excited to see that "Wet Cleaning" will be included on care labels under the new Rule, but we have two concerns regarding the new labels.
a) First, we understand that the new Rule allows the manufacturer to eliminate terms from the care label in favor of using symbols only. We feel that this change will unnecessarily complicate the consumer's process of choosing an appropriate cleaning method, and are therefore in favor of retaining the requirement of including written terminology such as "Dry Clean Only."
b) Secondly, we feel that the term "Professional" should modify "Wet Cleaning" on care labels. Although this request may seem pedantic, we are concerned that removing the term may mislead consumers. The processes involved in professional wet cleaning are significantly different from those involved in home cleaning, as professional dry cleaners have access to products, methods, and knowledge that the average consumer does not(even when wet cleaning is concerned). However, the differences between professional wet-cleaning and home cleaning are not well-known among consumers. We do not want consumers to expect their garments to be properly cleaned at home when professional methods (such as pre-washing treatments) are necessary to remove stains or maintain the garments' shape, structure, and color. Therefore, manufacturers should be required to include "Professional" in their instructions for wet cleaning.
We appreciate any consideration of our concerns, and are excited to see changes implemented that will more clearly define cleaning methods to consumers.