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The Federal Trade Commission had received only four comments on its proposed care label rule revisions as of Oct. 16, a month before the comment period closes on Nov. 16.

The FTC announced in September a proposal that would revise the rule in four areas: allowing a “professionally wetclean” label; an updated definition of drycleaning; approving the use of care symbols from either the American Society of Testing and Material (ASTM) or the International Organization for Standards (ISO) in place of written instructions; and clarifying what constitutes a reasonable basis for care instructions.

Use of a wetcleaning label received widespread support from commenters last year after the FTC said it was reviewing the rules which were last revised in 2000. However, the wetcleaning instruction would be optional, thus the absence of a wetcleaning instruction would not necessarily mean that a garment can not be wetcleaned.

The FTC proposes to define wetcleaning 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.”

An updated definition of drycleaning would reflect changes that have taken place in cleaning technology and practices over the years. The FTC said it didn’t want to discourage the development and use of new cleaning technologies by retaining the definition in the current rule which lists perc, hydrocarbon and fluorocarbon as drycleaning solvents.

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 four comments received as of Oct. 16 were directed primarily at the use of care symbols. One commenter said she did not want to allow the use of symbols in place of written instructions because she finds the symbols confusing and difficult to remember.

In fact, the FTC is proposing to allow two different sets of symbols. The ASTM symbols which are now used would be updated to include the 2005 revisions. 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.

Symbols developed by ISO could also be used under the new rule. The ASTM and ISO symbols are similar but not identical, so the label would have to indicate if the ISO symbols are being used

The two systems differ 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 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.