Submission Number: 00015
Received: 2/2/2012 2:48:56 PM
Commenter: David Trumbull
Organization: National Textile Association
Agency: Federal Trade Commission
Initiative: 16 CFR Part 303: Rules and Regulations Under the Textile Fiber Products Identification Act; Project No. P948404
Attachments: No Attachments
Donald S. Clark, Secretary
Federal Trade Commission
600 Pennsylvania Ave., NW
Washington DC, 20580
RE: Textile Rules, 16 CFR Part 303, Project No. P948404
Dear Mr. Clark,
This is a response on behalf of the National Textile Association to the Federal Trade Commission’s Federal Register Notice published November 7, 2011 requesting comments for use in the Commission’s review of Rules and Regulations Under the Textile Fiber Products Identification Act (“Textile Fiber Rules”).
We respectfully submit the following comments for consideration by the Commission with regard to the questions (1), (2), (4), and (13) in the Federal Register Notice:
(1) Is there a continuing need for the Rules as currently promulgated?
Yes, there is a continuing need for the Rules as currently promulgated. The Rules implement the provisions of the Textile Fiber Products Identification Act (``Textile Act''), 15
U.S.C. 70-70k. The Rules have assisted American consumer in making informed choices regarding purchases of textile products by requiring accurate and concise fiber content labeling on such products.
(2) What benefits have the Rules provided to, or what significant costs have the Rules imposed on, consumers?
Amid all many, and sometime conflicting, marketing claims regarding textile product performance, the Rules assure that consumers have access to objective information regarding fiber content, which is one of the best indicators of product performance.
(4) What impact have the Rules had in promoting the flow of truthful information to consumers and preventing the flow of deceptive information to consumers?
As we saw when the Commission issued guidance a few years ago clarifying that rayon produced from bamboo is properly labeled "rayon" and that product performance and environmental claims regarding such "bamboo" products were fraudulent, the Rule are necessary if consumers are to have truthful information about products and if the flow of deceptive information in the form of marketing claims is the be prevented.
(13) Should the Commission modify Section 303.7 to address the development of ISO 2076: 2010, ``Textiles--Man-made fibres--Generic names,'' an updated version of ISO 2076: 1999(E), ``Textiles--Man-made fibres--Generic Names,'' referenced in Section 303.7?
We strongly recommend that the Commission modify Section 303.7 to address the development of ISO 2076: 2010 for the reasons detailed in joint industry comments that the National Textile Association has signed and that are being submitted separately from this submission.
In addition to our responses to the four questions posed by the Commission above, the National Textile Association also believes that Fiber performance related hang tags, and other non-permanently affixed point-of-sale information, should be held to “non-deceptive” requirements, but not to regulatory mandates requiring information unavailable to fiber producers. Our view on this matter is address in detail in joint industry comments being submitted separately from this submission.
Vice President, International Trade
National Textile Association