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National Clothesline
Changes coming for care label rule
A year ago when the Federal Trade Commission asked if it should retain its Care Label Rule and, if so, what changes should be made, it got an earful. Respondents were nearly unanimous that the rule should be kept. On the question of what changes should be made, there were many suggestions. Last month the FTC said it is going forward with changes in four specific areas of the rule.
Those four changes include allowing the use of a “professionally wetclean” care instruction, letting manufacturers use care symbols approved by the American Society of Testing and Material (ASTM) or the International Organization for Standards (ISO) in place of written instructions, clarifying what constitutes a reasonable basis for care instructions, and updating the definition of drycleaning to reflect current practices and account for new cleaning solvents.
The commission is once again seeking comments, this time on its four specific proposals. Comments must be received by Nov. 16. Last year, 120 comments were received with at least 70 coming from sources that identified themselves as affiliated with the fabric care industry. Comments also came in from government agencies, industry standard-setting organizations, environmental advocacy groups, manufacturers and retailers and various trade associations.
Commenting on Care Labels Public comments on the Care Labeling
All but two of those commenters urged keeping the rule and the FTC agreed. About half of the commenters urged the FTC to permit or require a professional wetcleaning instruction on garments that can be wetcleaned.
The FTC had considered but rejected adding wetcleaning to the care instruction mix in 2000, saying then that it was “premature to permit such an instruction due to the absence of a suitable definition and appropriate test method.”
Now, the FTC says, “these conditions have been met,” citing the International Standards Organization which has included a definition of wetcleaning and test procedures for determining whether apparel can be wetcleaned professionally in its standard 3175-4:2003, “Textiles — Professional care, drycleaning and wetcleaning of fabrics and garments.”
The FTC also cited widespread support among commenters for including professional wetcleaning in the labeling rule, in particular the increased industry acceptance and use of wetcleaning. Not having a “wetcleaning” label available could place wetcleaners at a disadvantage, the commission said, thereby discouraging its use.
However, the FTC stopped short of requiring a wetcleaning label on garments that can be wetcleaned.
“None of the comments provided evidence that the absence of a wetcleaning instruction for products that can be wetcleaned would result in deception or unfairness under the FTC Act,” the commission said. “Nor did they provide evidence that the benefits of requiring a wetcleaning instruction would exceed the costs such a requirement would impose on manufacturers and importers.”
Thus the wetcleaning instruction would be optional. Wetcleaning would be defined according to the ISO standard:
“Wetclean means a commercial process for cleaning products or specimens in water carried out by professionals using special technology (cleaning, rinsing, and spinning), detergents, and additives to minimize adverse effects, followed by appropriate drying and restorative finishing procedures.”
Another of the proposed rules also reflects changes that have taken place in cleaning technology and practices over the years. The Care Label Rule’s definition of drycleaning would eliminate the mention of fluorocarbon solvent while adding new solvents that have been developed in the past few years. The old definition, which also listed perc and hydrocarbon as drycleaning solvents, might discourage the use of solvents not listed and curtail technological development, the FTC said.
Thus the new definition of drycleaning would be read as follows:
“Dryclean means a commercial process by which soil is removed from products or specimens in a machine which uses any solvent excluding water (e.g., petroleum, perchloroethylene, silicone, glycol ether, carbon dioxide, or aldehyde). The process also may involve adding moisture to the solvent, up to 75 percent relative humidity, hot tumble drying up to 160°F (71°C) and restoration by steam press or steam-air finishing.”
The FTC is also proposing to clarify what constitutes a “reasonable basis” for the care instructions provided on a label. Manufacturers and importers are supposed to support the label’s care instructions with evidence that the garment would not be harmed when the instructions are followed and, if a particular cleaning method is warned against, evidence that the method would harm the garment.
The FTC wants to refine that definition to state that the reliable evidence supporting the care instruction must apply to each component part of the garment as well as the garment as a whole. This would cover, for example, the color of one part of a garment bleeding onto another when the garment is washed or the garment has a dye that is known to bleed, or if it has beads, buttons, or sequins that are known to be damaged in drycleaning or if the garment contains several fibers, fabrics, or components not previously used together.
The fourth proposal concerns the use of care symbols, specifically amending the rule to reflect updated ASTM symbols and to also allow use of the ISO symbols. Because the two sets of symbols are similar but not identical, the label would have to indicate when the ISO symbols are being used.
The two systems differ slightly with respect to drying and ironing symbols. ASTM has more symbols for drying, and the ASTM symbol for “medium temperature drying” means “normal temperature drying” in the ISO system. The ASTM system includes a “no steam” symbol for ironing while the ISO symbol for low heat, unlike the ASTM symbol for low heat, indicates that steam ironing may cause irreversible damage.
The commission noted that the meaning of one ASTM drycleaning symbol changed significantly in the revised ASTM standard. The old symbol, a circle with the letter “P” inside, meant dryclean with any solvent except perc. Under the revised standard, the symbol means dryclean with perc or petroleum.
“Although potentially confusing, this change does not seem likely to harm consumers who understand the meaning of the symbol at the time they purchase the product,” the FTC said.
In any case, the FTC said, care symbols can be used in lieu of written instructions.

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