Please Send Your Comments to The Federal Trade Commission
Members can use these comments on the Federal Trade Commission’s proposed revisions to the 
Care Labeling Rule. The talking points below are meant to help guide your own comments, the more specific information you can provide about your business, the more weight those comments will have with the FTC.
Comments are due by September 6, 2011. You can submit your comments online at
https://ftcpublic.commentworks.com/ftc/carelabelinganpr/ or your can mail your comments to:
Federal Trade Commission
Office of the Secretary
Room H-113 (Annex A)
600 Pennsylvania Ave. NW
Washington, DC 20580
If you have any questions please do not hesitate to contact Lorraine Muir at 1-800-638-2627, or via e-mail.
Thank you for your support in this effort,
Mary Scalco, DLI Acting CEO
Talking Points
Re: Care Labeling of Textile Wearing Apparel and Certain Piece Goods as Amended
16 CFR Part 423 - Comment
As a member of the fabricare industry I am commenting on the FTC’s proposed amendments to16 CFR Part 423 and how they will affect my ability to operate a business and serve my customers.
Is there a continuing need for the Rule as currently promulgated? Benefits? Costs?
The rule is necessary to help me determine the best method of care for my customer’s clothing. Only the manufacturer has knowledge of cleanability of all components of a garment and uses a “reasonable basis” for care instructions on the label.
If a care label is not attached to a garment, extra time (costs to my business) and materials (also costs to the business) are needed to determine the safest method of care.
<Include any examples that would be relevant to this topic>
What modification should be made to the rule to increase the benefit small business?
The care label should list all appropriate methods of care. If all methods of care are listed I can select the best method of cleaning based on the type of soils on the garment or my customer’s requests. When a care label is missing I must examine the garment, possibly take it apart (more costs), test all fabrics and trims (time and chemicals) and in the end, hope for the best. If I guess incorrectly, the customer is unhappy, I am unhappy as customers don’t pay for errors, I will oftentimes have to pay for the ruined garment and likely lose a customer.
Listing all appropriate methods of care would be a benefit to the fabricare professional. As the care label rule is now I accept responsibility and liability for processing a garment in a method not listed on the care label.
<Include examples where you could have better helped your customer if all safe cleaning methods were listed on the label>
What modifications should be made to the Rule as to the results of impending changes in technology?
The current definition of drycleaning is very limiting and includes fluorocarbon, a solvent that was been regulated out of existence toward the end of the last century.
I want to change to a new solvent, which involves purchasing a costly new cleaning machine, but am hesitant knowing that the solvent or process is not recognized by the Care Label Rule. Testing and acceptance in labeling need to allow for updated technology. The Care Label Rule should not curtail technological advancement of the fabricare industry.
Does the rule conflict with other federal or state laws or regulations?
The Care Label Rule conflicts with state laws that call for a ban on perchlorethylene, a common drycleaning solvent.
<Give examples, especially if your business is located in California>
Are there any foreign or international laws, regulations or standards that should be enforced?
Cleaning professionals often accept garments that have been purchased outside the U.S. It would be very helpful in this business if the care instructions found on foreign and domestic labels were in agreement.
<Give examples where a garment purchased overseas could not be cleaned at your plant because of unusual care labeling>
Should the Rule include Professional Wetcleaning?
The rule should include Professional Wetcleaning. More of my customers want their drycleanable garments washed, and for many reasons, including environmental impact, consumer demand and local regulations, I invested time and money in the equipment and staff training. However, I am accepting all responsibility for wetcleaning since the method is not recognized by the Care Label Rule.
<Give examples if possible>
Should the Rule address the development of ASTM care symbols?
It would be very helpful if the rule addressed the development of ASTM care symbols. I have found a Wetcleaning symbol (Circle with W) on several garments but had to do some research to find a definition.
<Give examples if possible>
I appreciate the opportunity to share my concerns with the Care Label Rule as it is now and proposed amendments. Thank you for accepting my comments. If you have any questions or would like any additional information please contact me at <Business email or phone number>.
