Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, 58338-58352 [2012-22746]
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58338
Federal Register / Vol. 77, No. 183 / Thursday, September 20, 2012 / Proposed Rules
compliance times specified, unless the
actions have already been done.
(g) Inspection
At the later of the times specified in
paragraphs (g)(1) and (g)(2) of this AD:
Inspect to identify the part number and serial
number of the airplane’s forward and aft
cargo doors, as applicable to MSN, in
accordance with the Accomplishment
Instructions of Airbus Mandatory Service
Bulletin A330–52–3083, dated May 31, 2011
(for Model A330 airplanes); or Airbus
Mandatory Service Bulletin A340–52–4093,
dated May 31, 2011 (for Model A340
airplanes). A review of airplane maintenance
records is acceptable in lieu of this
inspection if the part number and serial
number of the door can be conclusively
determined from that review.
(1) Prior to the accumulation of 7,400 total
flight cycles, or 72 months after the airplane’s
first flight, whichever occurs first.
(2) Within 60 days after the effective date
of this AD.
(h) Replacement
If, during the inspection required by
paragraph (g) of this AD, the part number and
serial number of the airplane’s forward and/
or aft cargo doors, as applicable to airplane
MSN, are identified in Airbus Mandatory
Service Bulletin A330–52–3083, dated May
31, 2011 (for Model A330 airplanes); or
Airbus Mandatory Service Bulletin A340–52–
4093, dated May 31, 2011 (for Model A340
airplanes): Before further flight, replace the
affected door with a new or serviceable door,
in accordance with the Accomplishment
Instructions of Airbus Mandatory Service
Bulletin A330–52–3083, dated May 31, 2011;
or Airbus Mandatory Service Bulletin A340–
52–4093, dated May 31, 2011; as applicable.
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(i) Repair
If, during the inspection required by
paragraph (g) of this AD, there is any
discrepancy between the installed forward
and/or aft cargo doors part/serial number and
the airplane MSN, as that part/serial number
and MSN are identified in Airbus Mandatory
Service Bulletin A330–52–3083, dated May
31, 2011 (for Model A330 airplanes); or
Airbus Mandatory Service Bulletin A340–52–
4093, dated May 31, 2011 (for Model A340
airplanes): Within 10 days after
accomplishing the inspection, contact the
FAA, or the European Aviation Safety
Agency (EASA) (or its delegated agent), for
further instructions and time limits, and
accomplish those instructions within the
specified time limits.
(j) Parts Installation Prohibition
As of the effective date of this AD, no
person may install on any airplane a forward
or aft cargo door that was removed from any
airplane as required by paragraph (h) of this
AD.
(k) Other FAA AD Provisions
The following provisions also apply to this
AD:
(1) Alternative Methods of Compliance
(AMOCs): The Manager, International
Branch, ANM–116, Transport Airplane
Directorate, FAA, has the authority to
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approve AMOCs for this AD, if requested
using the procedures found in 14 CFR 39.19.
In accordance with 14 CFR 39.19, send your
request to your principal inspector or local
Flight Standards District Office, as
appropriate. If sending information directly
to the International Branch, send it to ATTN:
Vladimir Ulyanov, Aerospace Engineer,
International Branch, ANM–116, Transport
Airplane Directorate, FAA, 1601 Lind
Avenue SW., Renton, Washington 98057–
3356; telephone (425) 227–1138; fax (425)
227–1149. Information may be emailed to: 9ANM-116-AMOC-REQUESTS@faa.gov.
Before using any approved AMOC, notify
your appropriate principal inspector, or
lacking a principal inspector, the manager of
the local flight standards district office/
certificate holding district office. The AMOC
approval letter must specifically reference
this AD.
(2) Airworthy Product: For any requirement
in this AD to obtain corrective actions from
a manufacturer or other source, use these
actions if they are FAA-approved. Corrective
actions are considered FAA-approved if they
are approved by the State of Design Authority
(or their delegated agent). You are required
to assure the product is airworthy before it
is returned to service.
(l) Related Information
Refer to MCAI EASA Airworthiness
Directive 2011–0177, dated September 15,
2011 (corrected September 28, 2011), and the
service information identified in paragraphs
(l)(1) and (l)(2) of this AD, for related
information.
(1) Airbus Mandatory Service Bulletin
A330–52–3083, dated May 31, 2011.
(2) Airbus Mandatory Service Bulletin
A340–52–4093, dated May 31, 2011.
Issued in Renton, Washington, on
September 6, 2012.
Ali Bahrami,
Manager, Transport Airplane Directorate,
Aircraft Certification Service.
[FR Doc. 2012–23147 Filed 9–19–12; 8:45 am]
BILLING CODE 4910–13–P
FEDERAL TRADE COMMISSION
16 CFR Part 423
Trade Regulation Rule on Care
Labeling of Textile Wearing Apparel
and Certain Piece Goods
Federal Trade Commission.
Notice of proposed rulemaking.
AGENCY:
ACTION:
Based on comments received
in response to its Advance Notice of
Proposed Rulemaking (‘‘ANPR’’), the
Federal Trade Commission proposes to
amend its trade regulation rule on Care
Labeling of Textile Wearing Apparel
and Certain Piece Goods as Amended
(‘‘Rule’’) to: Allow garment
manufacturers and marketers to include
instructions for professional
wetcleaning on labels; permit the use of
SUMMARY:
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ASTM Standard D5489–07, ‘‘Standard
Guide for Care Symbols for Care
Instructions on Textile Products,’’ or
ISO 3758:2005(E), ‘‘Textiles—Care
labelling code using symbols,’’ in lieu of
terms; clarify what can constitute a
reasonable basis for care instructions;
and update the definition of ‘‘dryclean.’’
In addition, the Commission seeks
comment on several other issues.
DATES: Written comments must be
received on or before November 16,
2012. Parties interested in an
opportunity to present views orally
should submit a request to do so as
explained below, and such requests
must be received on or before November
16, 2012.
ADDRESSES: Interested parties may file a
comment online or on paper by
following the instructions in the
Request for Comment part of the
SUPPLEMENTARY INFORMATION section
below. Write ‘‘Care Labeling Rule, 16
CFR Part 423, Project No. R511915’’ on
your comment, and file your comment
online at https://
ftcpublic.commentworks.com/ftc/
carelabelingnprm by following the
instructions on the Web-based form. If
you prefer to file your comment on
paper, mail or deliver your comment to
the following address: Federal Trade
Commission, Office of the Secretary,
Room H–113 (Annex B), 600
Pennsylvania Avenue NW., Washington,
DC 20580.
FOR FURTHER INFORMATION CONTACT:
Robert M. Frisby, Attorney, Federal
Trade Commission, Division of
Enforcement, Bureau of Consumer
Protection, 600 Pennsylvania Avenue
NW., Washington, DC 20580, (202) 326–
2098.
SUPPLEMENTARY INFORMATION: The
Commission finds that using expedited
procedures in this rulemaking will serve
the public interest. Specifically, they
support the Commission’s goals of
clarifying and updating existing
regulations without undue expenditure
of resources, while ensuring that the
public has an opportunity to submit
data, views, and arguments on whether
the Commission should amend the Rule.
Because written comments should
adequately present the views of all
interested parties, the Commission is
not scheduling a public hearing or
workshop. However, if any person
would like to present views orally, he or
she should follow the procedures set
forth in the DATES, ADDRESSES, and
SUPPLEMENTARY INFORMATION sections of
this document. Pursuant to 16 CFR 1.20,
the Commission will use the procedures
set forth in this document, including: (1)
Publishing this Notice of Proposed
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Federal Register / Vol. 77, No. 183 / Thursday, September 20, 2012 / Proposed Rules
Rulemaking (‘‘NPRM’’); (2) soliciting
written comments on the Commission’s
proposals to amend the Rule; (3)
holding an informal hearing (such as a
workshop) if requested by interested
parties; (4) obtaining a final
recommendation from staff; and (5)
announcing final Commission action in
a document published in the Federal
Register. Any motions or petitions in
connection with this proceeding must
be filed with the Secretary of the
Commission.
I. Introduction
The Rule makes it an unfair or
deceptive act or practice for
manufacturers and importers of textile
wearing apparel and certain piece goods
to sell these items without attaching
labels stating the care needed for the
ordinary use of the product.1 The Rule
also requires that the manufacturer or
importer possess, prior to sale, a
reasonable basis for care instructions 2
and allows the use of approved care
symbols in lieu of words to disclose
those instructions.3
The Commission promulgated the
Rule in 1971 and has amended it three
times since.4 In 1983, the Commission
clarified its requirements regarding the
disclosure of washing and drycleaning
information.5 In 1997, the Commission
adopted a conditional exemption to
allow the use of symbols in lieu of
words.6 In 2000, the Commission
amended the Rule to clarify what
constitutes a reasonable basis for care
instructions and to change the Rule’s
definitions of ‘‘cold,’’ ‘‘warm,’’ and
‘‘hot’’ water.7
In 2000, the Commission rejected two
proposed amendments. First, the
Commission did not require labels with
instructions for home washing on items
that one can safely wash at home,
because the evidence was not
sufficiently compelling to justify this
change and the benefits of the proposed
change were highly uncertain.8 Second,
the Commission did not establish a
definition for ‘‘professional
wetcleaning’’ or permit manufacturers
to label a garment with a ‘‘Professionally
Wetclean’’ instruction.9 The
Commission stated that it was
premature to allow such an instruction
before the development of a suitable
definition and an appropriate test
method 10 and added that it would
consider such an instruction if a more
specific definition and/or test procedure
were developed.11
As part of its ongoing regulatory
review program, the Commission
published an Advance Notice of
Proposed Rulemaking (‘‘ANPR’’) in July
2011 seeking comment on the economic
impact of, and the continuing need for,
the Rule; the benefits of the Rule to
consumers; and the burdens the Rule
places on businesses.12 The ANPR also
sought comment on whether and how
the Rule should address professional
wetcleaning and updated industry
standards regarding the use of care
symbols, as well as whether the
Commission should address nonEnglish disclosures.
This NPRM summarizes the
comments received by the Commission,
explains the Commission’s decision to
retain the Rule, proposes several
amendments to the Rule, and explains
why the Commission has declined to
propose certain amendments.13 It also
8 Id.
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1 16
CFR 423.5 and 423.6(a) and (b).
2 16 CFR 423.6(c).
3 The Rule provides that the symbol system
developed by ASTM International, formerly the
American Society for Testing and Materials, and
designated as ASTM Standard D5489–96c ‘‘Guide
to Care Symbols for Care Instructions on Consumer
Textile Products’’ may be used on care labels or
care instructions in lieu of terms so long as the
symbols fulfill the requirements of Part 423. 16 CFR
423.8(g).
4 Federal Trade Commission: Care Labeling of
Textile Wearing Apparel: Promulgation of Trade
Rule and Statement of Basis and Purpose, 36 FR
23883 (Dec. 16, 1971).
5 Federal Trade Commission: Amendment to
Trade Regulation Rule Concerning Care Labeling of
Textile Wearing Apparel and Certain Piece Goods,
48 FR 22733 (May 20, 1983).
6 Federal Trade Commission: Concerning Trade
Regulation Rule on Care Labeling of Textile
Wearing Apparel and Certain Piece Goods;
Conditional Exemption from Terminology Section
of the Care Labeling Rule, 62 FR 5724 (Feb. 6,
1997).
7 Federal Trade Commission: Trade Regulation
Rule on Care Labeling of Textile Wearing Apparel
and Certain Piece Goods, Final Amended Rule, 65
FR 47261 (Aug. 2, 2000).
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at 47269.
Commission proposed a definition of
professional wetcleaning, stating, in part, that it is
‘‘a system of cleaning by means of equipment
consisting of a computer-controlled washer and
dryer, wet cleaning software, and biodegradable
chemicals specifically formulated to safely wet
clean wool, silk, rayon, and other natural and manmade fibers.’’ Id. at 47271 n. 99.
10 Id. at 47272. The Commission explained that
the definition must either describe all important
variables in the process, so that manufacturers can
determine that the process would not damage the
garment, or be coupled with a specific test
procedure that manufacturers can use to establish
a reasonable basis for the instruction. Id.
11 Id. at 47273.
12 Federal Trade Commission: Trade Regulation
Rule on Care Labeling of Textile Wearing Apparel
and Certain Piece Goods, Advance Notice of
Proposed Rulemaking; request for comment, 76 FR
41148 (July 13, 2011).
13 The Commission publishes this NPRM
pursuant to Section 18 of the Federal Trade
Commission Act (‘‘FTC Act’’), 15 U.S.C. 57a et seq.,
the provisions of Part 1, Subpart B of the
Commission’s Rules of Practice, 16 CFR 1.7, and 5
U.S.C. 551 et seq. This authority permits the
Commission to promulgate, modify, and repeal
trade regulation rules that define with specificity
9 The
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58339
poses questions soliciting additional
comment and provides a regulatory
analysis as well as analyses under the
Regulatory Flexibility Act and the
Paperwork Reduction Act. Finally, the
NPRM sets forth the Commission’s
proposed Rule language.
II. Summary of Comments
The Commission received 120
comments in response to the ANPR.14
Most were filed by individuals. At least
70 of these individuals identified
themselves as owning or operating a
cleaning business or working in the
drycleaning or wetcleaning industries.
The Commission also received
comments from government agencies,15
industry standard-setting
organizations,16 environmental
advocacy organizations,17
manufacturers and retailers,18 and trade
associations representing industries
affected by the Rule.19
All but two of the numerous
comments that addressed retention of
the Rule favored it.20 Comments from
acts or practices that are unfair or deceptive in or
affecting commerce within the meaning of Section
5(a)(1) of the FTC Act, 15 U.S.C. 45(a)(1).
14 The comments are posted at https://
www.ftc.gov/os/comments/carelabelinganpr/
index.shtm. The Commission has assigned each
comment a number appearing after the name of the
commenter and the date of submission. This notice
cites comments using the last name of the
individual submitter or the name of the
organization, followed by the number assigned by
the Commission.
15 Three California agencies filed comments: The
Air Resources Board (18), Department of Toxic
Substances Control (123), and the San Francisco
Department of the Environment (89).
16 ASTM International (‘‘ASTM’’) (111) and
GINETEX (83), which is responsible for the care
labeling system used in European countries.
17 The Coalition for Clean Air (119), the Toxic Use
Reduction Institute (86), and the UCLA Sustainable
Technology & Policy Program (84).
18 Miele (108), Miele & Cie. KG (110), The
Children’s Place (90), and The Clorox Company
(122).
19 The Association of Home Appliance
Manufacturers (‘‘AHAM’’) (114), American Apparel
& Footwear Association (113), Professional Wet
Cleaners Association (‘‘PWA’’) (73) and (102),
Association of Wedding Gown Specialists
(‘‘AWGS’’) (22), National Cleaners Association and
Drycleaning & Laundry Institute (124), Professional
Leather Cleaners Association (‘‘PLCA’’) (109),
International Drycleaners Congress (‘‘IDC’’) (47),
and Textile Industry Affairs (112).
20 GINETEX argued that the Rule should not be
mandatory for textile and apparel companies
because a voluntary scheme would adapt in a
timely manner to technical and environmental
developments as well as innovations, while
adjustments to mandatory rules are very
cumbersome to implement. It also argued that
national rules not in line with international
standards can create a nontariff barrier to trade, and
that the ASTM standard creates an unnecessary
obstacle to international trade. A retailer argued
that the time and effort spent on labels required by
the Rule does not really serve the ultimate goal of
educating consumers on laundering habits.
Kambam (4).
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the apparel manufacturing and cleaning
industries uniformly supported the
Rule. For example, the American
Apparel & Footwear Association
(‘‘AAFA’’) stated that the labels benefit
consumers, manufacturers, and business
in general, as they allow for the
necessary flow of information along the
commodity chain. Similarly, the
National Cleaners Association (‘‘NCA’’)
and the Drycleaning & Laundry Institute
(‘‘DLI’’) stated that the Rule provides
valuable guidance on care to consumers
and industry. Textile Industry Affairs
(‘‘TIA’’) noted that the Rule has
generated dramatic benefits to both
consumers and manufacturers, and that
no apparel manufacturers that have
complied with the Rule have ever
reported any negative consumer impact.
While the comments indicate
widespread support for the Rule, most
argued that the Commission should
update or expand it in various ways. In
particular, many comments urged the
Commission to address professional
wetcleaning by either requiring or
allowing manufacturers to disclose a
wetcleaning instruction. Still others
urged the Commission to update the
Rule’s provisions allowing the use of
care symbols by incorporating the latest
ASTM or International Organization for
Standardization (‘‘ISO’’) care symbol
standards, allowing manufacturers to
follow either standard, or adopting new
symbols for professional cleaning.
Several comments requested
clarification of the Rule’s reasonable
basis provisions or imposition of testing
requirements on manufacturers. Others
advocated updating the definition of
‘‘dryclean’’ and the Appendix to reflect
the development of new solvents and
cleaning technologies and practices.
Some comments urged the Commission
to require manufacturers to disclose all
appropriate methods of care on labels.
Further, some comments urged the
Commission to amend the Rule to
require the disclosure of additional
information such as fiber content or
more detailed care instructions, to
disallow certain instructions currently
permitted by the Rule, or to impose
additional obligations. Several
comments addressed disclosures made
in multiple languages.
A. Professional Wetcleaning
Slightly more than half of the 120
comments received by the Commission
stated or implied that the Commission
should permit, or require, a professional
wetcleaning instruction on garments
that can be wetcleaned. Wetcleaning is
an alternative to drycleaning and
involves professionals cleaning
products in water using special
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technology (cleaning, rinsing, and
spinning), detergents, and additives to
minimize adverse effects, followed by
appropriate drying and restorative
finishing procedures. Of the comments
addressing this issue, only three
expressed concerns.21 Comments
favoring a wetcleaning instruction made
several arguments in support of their
position.
First, they touted the economic,
health, and environmental benefits of
wetcleaning. For example, based on its
analysis of scientific literature on the
health and environmental impacts of
drycleaning solvents, and its review of
operational costs and compliancerelated impacts, the San Francisco
Department of the Environment
determined that professional
wetcleaning is the most
environmentally-preferable professional
cleaning option.22 The Toxic Use
Reduction Institute stated that the
benefits from professional wetcleaning
include decreased use of energy and
water, significant air quality
improvement in the shop, and improved
employee health and satisfaction.23 It
explained that over 80% of the U.S.
professional garment cleaning industry
uses perchloroethylene (‘‘perc’’), and
that studies have identified ecological
and human health hazards associated
with its use.24 It added that the National
Institute for Occupational Safety and
Health has recommended handling perc
as a human carcinogen, and the
Environmental Protection Agency has
classified it as a probable human
carcinogen.25 Two comments noted
that, starting in 2023, California
drycleaners can no longer use perc.26 A
number of others favored wetcleaning
due to concerns about using toxic or
unhealthy drycleaning solvents.27
Others noted that wetcleaning can
produce better results than drycleaning
in some circumstances.28
21 AHAM urged the Commission to gather data on
consumer knowledge and the availability of
wetcleaning before amending the Rule to address it.
AHAM (114). One commenter stated that
wetcleaning is not a viable alternative to
drycleaning. Enderlin (63). PLCA did not take a
position on wetcleaning, but noted that there are
not enough cleaners trained in wetcleaning. PLCA
(109).
22 San Francisco Department of the Environment
(89). This comment included a chart showing the
results of its analysis.
23 Toxic Use Reduction Institute (86).
24 Id.
25 Id. The California Department of Toxic
Substances Control also explained the
environmental problems caused by perc. (123).
26 Air Resources Board (18) and NCA and DLI
(24).
27 E.g., Addison (81); Bohnet (80); Chung (70); and
Xu (101).
28 One comment explained that the absence of
wetcleaning labels limits cleaners in offering the
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Second, several comments explained
that the number of cleaners providing
professional wetcleaning has increased
and that consumers increasingly use or
prefer it. Two trade associations
reported that professional wetcleaning
is now widespread in the industry.29
Another stated that wetcleaning has
been steadily growing in the United
States for over a decade.30 Yet another
explained that professional wetcleaning
has come a long way in the last few
years, and that many traditionally
drycleaned garments can be wetcleaned
with good results.31
Several comments provided data on
the number of cleaners providing
wetcleaning and the number of
garments they clean. For example, one
comment stated that over 200 perc
drycleaners in California have switched
to wetcleaning and successfully cleaned
the full range of garments they
previously drycleaned.32 Two
comments noted the success of well
over 120 professional wetcleaners in
California who clean over 75 million
garment pieces annually.33 Another
explained that there are hundreds of
professional wetcleaners in the United
States who use only water and soap to
clean all garments presented to them.34
This comment also indicated that there
are 80 Miele professional wetcleaners in
California, and that they process four
million articles of clothing a year.35
Other comments cited the experience
of individual cleaners that increasingly
replace drycleaning with wetcleaning.
For example, one comment from a
cleaning business stated that
wetcleaning is becoming common, and
that it wetcleans approximately 65%–
80% of the clothes it washes.36 Another
commenter stated that it wetcleans
100% of garments and that the
instruction ‘‘dryclean only’’ has lost its
meaning.37
Several comments noted the
development of industry standard care
best process when it comes to cleaning performance
(e.g., water-soluble stains) or fabric-related cleaning
processes (e.g., polyurethane). Miele & Cie. KG
(110). A comment from a cleaner noted that some
stains can be removed only with water. Kaplan (57).
Another comment stated that wetcleaning is a
necessary method for certain combinations of soil
and fabric. Riggs (53).
29 NCA and DLI (124).
30 Press on Cleaners (120).
31 Patterson (14).
32 Coalition for Clean Air (119).
33 Chang and PWA (73) and Sim (116). Another
comment stated that there are over 120 professional
wetcleaners in California that clean over 250,000
pieces of garments across the state daily. Press on
Cleaners (120).
34 Miele (108).
35 Id.
36 Peltier (43).
37 Behzadi (69).
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symbols for wetcleaning. Indeed, ASTM
and ISO have adopted consistent care
symbols for professional wetcleaning.38
ISO has also issued a standard on
testing garments to determine whether
they can be wetcleaned.39
Finally, several comments argued that
the Rule’s failure to address wetcleaning
places professional wetcleaners and
equipment vendors at a competitive
disadvantage and discourages greater
use of wetcleaning.40
The comments urging the
Commission to amend the Rule to
address wetcleaning differ on whether
the Commission should require a
wetcleaning instruction or merely
permit one. Moreover, many urge the
Commission to address wetcleaning
without specifying exactly how. Of
those comments taking a position, the
vast majority favored amending the Rule
to require a professional wetcleaning
instruction if the garment can be
wetcleaned.41 Comments argued that
requiring the instruction would provide
consumers and cleaners with more and
better options, and produce various
benefits as more consumers choose
wetcleaning.42 One comment expressed
concern that failing to require an
instruction might result in most
manufacturers choosing not to disclose
that wetcleaning is a viable option,
thereby deceiving customers and
treating wetcleaners unfairly.43
In addition, several commenters that
do not appear to manufacture or market
38 UCLA Sustainable Technology & Policy
Program (84); Toxic Use Reduction Institute (86);
and Riggs (53). See ASTM D5489–07, ‘‘Standard
Guide for Care Symbols for Care Instructions on
Textile Products,’’ and ISO 3758:2005(E),
‘‘Textiles—Care labelling code using symbols.’’
39 UCLA Sustainable Technology & Policy
Program (84); Toxic Use Reduction Institute (86);
and Riggs (53). ISO 3175–4:2003, ‘‘Textiles—
Professional care, drycleaning and wetcleaning of
fabrics and garments—Part 4: Procedure for testing
performance when cleaning and finishing using
simulated wetcleaning.’’
40 E.g., Miele (108) and San Francisco Department
of the Environment (89). Another comment argued
that labeling garments ‘‘Dry Clean’’ or ‘‘Dry Clean
Only’’ even though they can be successfully
wetcleaned is unfair to professional wetcleaners. If
a consumer prefers to dryclean such garments, the
wetcleaner faces the prospect of losing the business
or deceiving the consumer by wetcleaning instead
of drycleaning such garments. The dilemma of
either lying to the customer or potentially losing
business makes professional wetcleaning
unappealing to many drycleaners. PWA (102).
41 E.g., Anonymous (106); Bromagen (91); Draper
(100); Eldridge (46); Evans (67); Fox (107); Hagearty
(61); NCA and DLI (124); Overmoe (66); Preece (54);
Raggi (30); San Francisco Department of the
Environment (89); Tebbs (47); Toxic Use Reduction
Institute (86); UCLA Sustainable Technology &
Policy Program (84).
42 E.g., NCA and DLI (124) and San Francisco
Department of the Environment (89).
43 UCLA Sustainable Technology & Policy
Program (84).
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apparel argued that the benefits of
requiring a wetcleaning instruction
would exceed the added labeling and
testing costs to manufacturers. One
comment explained that the vast
majority of manufacturers use
experience and expertise to determine
the care label.44 It added that, because
experience and expertise are free or
virtually free, the economic impact of
requiring a wetclean label likely is de
minimus.45 It further explained that
most manufacturers test garments by
sending them to established cleaners
and use in-house staff to evaluate results
and that this method requires no capital
equipment cost and only a marginal
cost.46 DLI and NCA advised that they
currently provide care label guidance to
garment manufacturers and that the
average cost to provide appropriate and
comprehensive washing, drycleaning
and wetcleaning instructions would be
under $1,400.47 Another comment
noted that testing is not that expensive
and would not lead to a large increase
in the cost of an item and that any extra
costs would fall as universal testing
reduces testing costs per item.48
A smaller number of comments
indicated that they favored amending
the Rule to permit, but not require, a
wetcleaning instruction. One comment
argued that allowing the instruction on
labeling will reconfirm to the public
that this method is accepted and safe
and encourage manufacturers to
produce more garments that do not need
to be cleaned in a solvent.49 Another
supported permitting a wetcleaning
instruction by amending the symbol sets
to include wetcleaning because there
appears to be expert consensus that
clear testing protocols exist to verify its
safety, and stated that the consumer and
environmental benefits of wetcleaning
are worthy of consideration.50
Many comments simply urged the
Commission to address wetcleaning
without specifying how.51 For example,
one comment stated that the
Commission seriously should consider
adding wetcleaning because of its
consumer and environmental benefits.52
It also explained that, with the
development of ISO standards, there
now appear to be consensus testing
protocols to verify a safe care process.53
44 Id.
45 Id.
46 Id.
47 NCA
and DLI (124).
(53).
49 Huie (71).
50 Textile Industry Affairs (112).
51 E.g., Air Resources Board (18); Bosshard (13);
Chang (88); Santana (12); and Schoeplein (27).
52 The Clorox Company (122).
53 Id.
48 Riggs
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B. Use of Care Symbols
With a few exceptions, the comments
addressing the use of symbols to
provide care instructions favored their
continued use.54 One comment stated
that the current FTC-approved symbols
do a good job of covering most of the
home and professional care needs in the
United States.55 It therefore did not
advocate modifying any of the symbols,
as consumers are just now becoming
familiar with them.56 Several
comments, however, advocated
modifying the Rule to refer to the most
recent version of the ‘‘Standard Guide
for Care Symbols for Care Instructions
on Textile Products,’’ ASTM D5489,
instead of the older version of the
ASTM standard currently referenced.57
One comment urged the Commission to
exclude the standard’s date; it explained
that ASTM D5489–07 is the most recent
standard and that, by not designating
the year, the Commission can ensure
that the most recent standard is used.58
It added that D 5489–07 is an
international standard as defined by the
WTO TBT Agreement, and that, as a
signatory to this agreement, the United
States is pledged to use international
standards as the basis for technical
regulations when possible.59 Others
urged the Commission to address the
development of ASTM symbols without
indicating how it should do so.60
Another explained that it would be very
helpful if the care instructions on
foreign and domestic labels were in
agreement or, at a minimum, contained
ASTM symbols.61
A number of comments expressed
support for harmonizing the ASTM
symbols allowed under the Rule with
those used internationally.62 One
comment favoring harmonization
concluded that the Rule prevents a
global ISO Standard and that ISO
symbols should supplant ASTM
54 Two commenters stated that they do not like
the use of symbols. Charles (3) and Vlasits (6).
Other comments urged the Commission to require
care symbols on all textile products. Fox (107) and
Old Town Dry Cleaners (56).
55 Textile Industry Affairs (112).
56 Id.
57 ASTM (111); Evans (67); and The Children’s
Place (90). Another comment argued that the Rule
should keep pace with developments in the ASTM
system, and that the biggest challenge with symbols
is educating the consumer. NCA and DLI (124). It
advised that care symbols are not prevalent in the
United States. Id.
58 ASTM (111).
59 Id.
60 Preece (54) and Yazdani (78).
61 Professional Leather Cleaners Association
(109).
62 AHAM (114); American Apparel & Footwear
Association (113); Draper (100); GINETEX (83);
Johnson (50); O’Connor (20); Textile Industry
Affairs (112); and The Clorox Company (122).
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symbols.63 It explained that the ASTM
and the ISO symbols are similar but not
the same and that ISO symbols are used
in every country except South Korea,
Japan, and the United States (and that
Japan is working on harmonizing ISO
and the JIC standards that apply in
Japan).64 Another favored one set of
worldwide symbols and explained that
the ISO recommends a complete set of
care symbols, including washing,
bleaching, ironing, drying, and
professional care.65 It added that these
symbols are consistent with those
developed by ASTM.66 Some comments
argued that harmonizing symbols would
also address problems stemming from
label disclosures in multiple
languages.67 One of these comments
favored harmonization but argued that,
as an alternative, the Rule should allow
manufacturers to use either ASTM or
ISO symbols in the United States, to
relieve some of the burden and increase
the accessibility of global trade.68 It
stated that differences among the
symbol systems cause confusion and
limit the opportunities for trade
growth.69 Another comment proposed
that the Rule provide for or recognize
agreements between the United States
and other countries to accept
international and national care label
symbol systems currently in use in the
global marketplace.70
Still others favored acceptance of ISO
or internationally-accepted symbols
without addressing the ASTM
symbols.71 Three comments urged the
Commission to adopt or accept the ISO
standard.72 One supported adding to the
symbols in cases where there are clear
testing protocols to verify the safety of
a care process.73 It explained that, in the
case of wetcleaning, there appears to be
expert consensus that a new test does
just that.74
GreenEarth Cleaning (‘‘GreenEarth’’)
advocated a different approach to
disclosing professional cleaning
instructions. It argued that the ASTM
and ISO professional cleaning symbols
63 GINETEX
(83).
64 Id.
65 Riggs
(53).
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66 Id.
67 American Apparel & Footwear Association
(113) and The Children’s Place (90).
68 American Apparel & Footwear Association
(113).
69 Id.
70 The Children’s Place (90).
71 Cote (58); Horrigan (17); Thorsteinson (45); and
Yazdani (78).
72 UCLA Sustainable Technology & Policy
Program (84); White (15); and GINETEX (83). As
noted above, GINETEX argued that the ISO symbols
should supplant the ASTM symbols.
73 Textile Industry Affairs (112).
74 Id.
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are inadequate because they are based
on particular solvents rather than
solvent characteristics.75 It explained
that the increasing number of solvents
and advances in technology call for an
approach addressing solvent
aggressiveness (cleaning method) and
mechanical action (cycle); it proposed
that a Kauri-Butanol Value (‘‘KBV’’) of
35 or less be designated as ‘‘gentle’’ and
that a ‘‘fragile’’ or ‘‘very fragile’’
instruction be provided for items
needing minimized mechanical
action.76 It stated that the KBV is widely
recognized in the textile care industry as
having the greatest influence on the
processing of textiles.77 This comment
further argued that there is a direct
correlation between propensity for
garment damage and a higher solvent
KBV.78 GreenEarth proposed specific
cleaning method and cycle symbols to
replace the current ASTM and ISO
symbols and urged the Commission to
make every effort to implement simple,
consistent international symbols that
can be universally interpreted to ensure
the best care for garments.79 No other
comment favored this proposal.
In addition to proposing new
symbols, GreenEarth advocated parallel
changes to the ‘‘overarching
nomenclature and the guiding
principle’’ behind the Rule, to improve
the reliability and understandability of
care labels.80 Specifically, it proposed
replacing the instructions ‘‘dry clean,’’
‘‘do not dry clean,’’ ‘‘wetclean,’’ and ‘‘do
not wetclean’’ with simplified categories
of ‘‘cleaning method’’ and ‘‘cycle.’’ It
also proposed that ‘‘cleaning method’’
would encompass all types of
professional cleaning, including
wetcleaning, and ‘‘cycle’’ would address
the level of mechanical action.81 As
with its proposed symbols, GreenEarth
would classify cleaning methods based
on solvent aggressiveness rather than
solvent type.82 For the ‘‘cycle’’ category,
GreenEarth would replace ‘‘mild’’ and
‘‘very mild’’ with ‘‘fragile’’ and ‘‘very
fragile.’’ 83
Two comments addressed the
presentation of symbols. One argued
that the current system works well, but
that some uniformity regarding location,
size, composition, and font size would
greatly help the industry.84 Another
comment proposed attaching the
75 GreenEarth
Cleaning (98) at 2.
76 Id.
at 2–3.
77 Id. at 2.
78 Id. at 4.
79 Id. at 2–3.
80 Id. at 2.
81 Id.
82 Id.
83 Id. at 3.
84 Raggi (30).
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international care label symbols to the
garments in a small, removable brochure
or paper, or in an online link address for
such information.85
C. The Rule’s Reasonable Basis
Provisions
Four comments argued that the
Commission should clarify or
strengthen the Rule’s provision
requiring manufacturers to have a
reasonable basis for care instructions.
One urged the Commission to
strengthen the reasonable basis
requirements and hold manufacturers
accountable to individual consumers for
inappropriate care instructions.86 Two
argued that the Commission should
clarify the reasonable basis provisions
because some non-compliant parties
appear to be misinformed or to
misunderstand the requirement.87 They
suggested that the Commission request
fresh data from manufacturers regarding
their reasonable basis for their current
care instructions.88 One of them argued
that, given standardized testing (e.g.,
ASTM methodology) for colorfastness
and garment integrity (e.g., tensile
strength), the Commission should
require actual data to support care
instructions.89 Another comment
favored requiring manufacturers to test
products with all available processes,
including wetcleaning.90
D. Rule Definitions and Appendix
Several comments urged the
Commission to update the Rule’s
definition of ‘‘dryclean,’’ as well as the
Appendix. One comment urged the
Commission to adopt a broader
definition of ‘‘dryclean.’’ 91 It explained
that, 25 years ago, only two solvents
were widely used—perc and
petroleum.92 It added that now there are
many solvents, including high flash
hydrocarbons, silicones, glycol ethers,
carbon dioxide, aldehydes, and
wetcleaning.93 It also reported that:
fluorocarbon solvent, one of the solvents
listed in the definition, is no longer
used; new hydrocarbon drying
parameters are different from those of
early petroleum solvents; and not all
solvents are organically based.94
85 Santana
(12).
and DLI (124).
87 Textile Industry Affairs (112) and The Clorox
Company (122). They stated that disclosing an
instruction based on ‘‘unreasonable’’ and
‘‘possible’’ fabric impact is not an acceptable
instruction or warning.
88 Id.
89 The Clorox Company (122).
90 Behzadi (69).
91 NCA and DLI (124).
92 Id.
93 Id.
94 Id.
86 NCA
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Four comments from cleaners
similarly argued that the current
definition of drycleaning is very
limiting.95 The first reported that it
adopted a new solvent, but has concerns
because labels do not provide the
information needed.96 The second
reported that it hesitated to adopt a new
solvent because it is not recognized by
the Rule.97 The third reported that it
wanted to use a new solvent, which
involves purchasing a costly new
machine, but hesitated because the
solvent or process is not recognized by
the Rule.98 The comment argued that
the Rule should not curtail
technological advancement.99 The
fourth urged the Commission to expand
Rule to address other solvents, such as
SolvonK4 by Kreussler.100
Two comments urged the Commission
to revise Appendix A. One advised that
Appendix A of the Rule diverges from
ASTM D5489, although it did not
identify how or explain why
amendments are warranted.101 Another
urged the Commission to suggest that all
leather goods have a more specific care
label, such as ‘‘Leather Clean and
Refinish by Professional Leather Cleaner
Only,’’ and to expand the definition in
Appendix A.8 to read ‘‘Leather Clean
and Refinish by Professional Leather
Cleaner Only.’’ 102
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E. Instruction on All Appropriate
Methods of Care
Several comments from the cleaning
industry urged the Commission to
amend the Rule to require
manufacturers to include instructions
on all appropriate methods of care.103
As one comment explained, this would
empower consumers to decide whether
they want to care for the garment at
home or use a professional cleaner.104 It
added that, by listing all methods of
care, the label would eliminate
guesswork regarding whether a care
method is not listed because it will
cause damage.105 Others explained that
such a label would enable the cleaner to
select the best cleaning method based
95 Bromagen (91); Hagearty (61); Preece (54); and
Yazdani (78).
96 Bromagen (91).
97 Hagearty (61).
98 Preece (54).
99 Id.
100 Brunette (115).
101 ASTM (111).
102 Professional Leather Cleaners Association
(109).
103 E.g., Bromagen (91); Draper (100); Edwards
(97); Evans (67); Hagearty (61); Kudler (72); Maisel
(34); McKay (104); NCA and DLI (124); Overmoe
(66); Preece (54); Tebbs (47); Widmar (48); and
Yazdani (78).
104 NCA and DLI (124).
105 Id.
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on the type of soils on the garment or
the customer’s requests.106
F. Additional Issues
Some comments proposed amending
the Rule to require additional
disclosures, disallow certain care
instructions currently allowed by the
Rule, address the format or composition
of labels, expand the scope of the Rule,
or impose additional requirements.
Additionally, several comments
addressed the use of multiple languages
on care labels.
Five comments urged the Commission
to require disclosure of fiber, fabric, or
component content.107 One of them also
advocated requiring disclosure of the
content of all fabrics, linings, and trims,
including applied water repellant
coatings or sizing that may be removed
during processing.108
Other comments urged the
Commission to require more detailed
care instructions or disclosure of
additional information related to
care.109 For example, one comment
urged the Commission to address the
instruction ‘‘exclusive of trim’’ where
the trim is not removable.110 Another
urged the Commission to require
disclosure of the type of dye method
used to lessen the likelihood of
damaged garments.111 Another stated
that the Rule should require more
details, including how and which
drycleaning fluid can, or cannot, be
used for the garment.112 Yet another
argued that any care that the
manufacturer knows could harm the
garment should be specifically stated as
a ‘‘Do Not’’ warning.113
One comment proposed that the Rule
provide that the care instruction
indicate the maximum treatment that
can be applied to the item.114 The
comment explained that the Rule allows
a manufacturer to provide an
instruction, such as ‘‘dry flat’’ even if a
more severe method, such as ‘‘tumble
dry,’’ will not harm the garment. Under
the ISO standard the care instruction
provided is the most severe method that
can be used without damaging the
article.115 Another comment argued that
106 Overmoe
(66) and Preece (54).
(92); Hiebert (64); Professional
Leather Cleaners Association (109); Santana (12);
and Wilson (32).
108 Hiebert (64).
109 One comment advocated guidelines for
designating specific solvent characteristics, such as
KB value, polarity, and water solubility, on preexisting labels. Cote (58).
110 Chelsky (38).
111 King (19).
112 Momin (51).
113 NCA and DLI (124).
114 GINETEX (83).
115 Id.
107 Chambers
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the Rule should require that jobbers
who add trimming, ornaments or
feathers, etc., to an item must change or
add additional labels and add the
jobbers’ names and contact info.116
Another comment argued, among other
things, that labels should disclose a
serial number and an address for a Web
site providing several additional
categories of information and countries
of manufacture.117
Moreover, one comment argued that
care tags could be replaced or made
much smaller and simpler with the use
of a unique identifier for every garment,
such as a barcode, QR code, or an RFID
chip.118 It explained that the code
would include a manufacturer ID,
product ID, and serial number, and that
the manufacturer would input this
information into a centralized database
that could be accessed by consumers,
retailers, drycleaners, etc.119
Another comment addressed
disclosure of an item’s point of origin.
It urged the Commission to require
disclosure of the state for items allowed
a ‘‘made in the United States’’ label.120
Other comments argued that the
Commission should disallow certain
care instructions that they view as
providing little, if any, benefit to
consumers, or to otherwise limit care
instructions. One comment argued that
all garments should be serviceable, and
opposed ‘‘Do not wash. Do not
dryclean’’ labels.121 One stated that care
methods should be dryclean only, clean
by any method, and cannot be
cleaned.122 Another stated that too
many labels state ‘‘remove trim before
cleaning’’ where removing the trim
results in taking apart the garment.123
One stated that labels that specify ‘‘Spot
Clean’’ should be disallowed.124
Two comments addressed the format
or composition of the labels required by
the Rule. One argued that labels should
be a standard size, printed on white
material only, using stable black ink,
non-soluble in water and drycleaning
solvents.125 The other argued that care
labels need to be securely attached to
the garment, and not by a few stitches,
to avoid causing holes in the garments
after a few cleanings.126
Two comments addressed the scope
of the Rule. One argued that the Rule
116 Zeidel
(29).
(40).
118 Levy (99).
119 Id.
120 Fisher (24).
121 Brunette (115).
122 Enderlin (63).
123 O’Connor (20).
124 Shaw (33).
125 Horrigan (17).
126 Maknojia (87).
117 Winn
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should continue to exempt rental
garments, such as corporate uniforms,
because many of them require
professional care for health reasons.127
The other proposed requiring care labels
for household items such as comforters,
drapes, etc.128
Four comments favored imposing
additional obligations under the Rule
other than labeling. One urged the
establishment of an electronic database
for reporting insufficient or incorrect
labeling so consumers can research
problems.129 Another urged the
Commission to add provisions holding
manufacturers accountable to individual
consumers for inappropriate care
instructions.130 A third advocated
providing that a consumer can return a
failed garment to the place of purchase
for a refund, that the place of purchase
must keep a record of the garment, and
that the point of sale vendor will be able
to get refunds from its vendor.131 A
fourth urged the creation of guidelines
for specific solvent characteristics, such
as KB value, polarity, and water
solubility, to allow for easy testing on
the manufacturing side and to
encourage eco-friendly alternatives on
the care side.132 It added that solvent
developers could provide MSDS sheets
(material safety data sheets) and
publicly-available materials for ease of
use by manufacturers, dry-cleaners and
consumers.133
Finally, several comments argued that
the Rule should not require multiple
language disclosures.134 One stated that
labels should be only in English, and
another stated that English is the only
language needed on labels.135 One
added that English is a must but other
languages can be an option.136 Another
argued that labels for clothes to be
purchased in the United States should
be in English, and for clothes available
for purchase in multiple countries, the
label should be in multiple
languages.137 Yet another stated that
labels should be in English and that
symbols should eliminate the need for
additional languages.138 Another argued
that the label should be in English with
127 American Apparel & Footwear Association
(113).
128 Kudler (72).
129 Bosshard (13).
130 NCA and DLI (124).
131 Sabo (23).
132 White (15).
133 Id.
134 One commenter, a consumer who does not
indicate any affiliation with an organization, stated
that she does not like having so many language
translations. Charles (3).
135 Branfuhr (42) and Childers (49).
136 Maknojia (87).
137 Vlasits (6).
138 Hurley (60).
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internationally-accepted symbols and
that those cleaners who do not speak or
read English well should contact their
own association for a translation of the
international symbols.139 None of the
comments proposed amending the Rule
to address the format for presenting care
instructions in more than one language,
other than to note that using symbols
would address problems stemming from
disclosures in multiple languages.140
III. The Commission Retains the Rule
The record shows wide support for
the Rule from all the major industries
affected by its provisions as well as from
consumers. Among other things,
comments supporting the Rule
explained that it benefits consumers,
manufacturers, and businesses in
general and provides valuable guidance
on care to consumers and the fabricare
industry.
Two comments opposing the Rule,
one filed by GINETEX and the other by
a retailer, failed to provide any tangible
evidence to support their assertions.141
There is no evidence in the record
showing that a voluntary scheme would
work better than the Rule, that the
ASTM care symbols permitted by the
Rule create an unnecessary obstacle to
international trade, or that the time and
effort spent on the labels required by the
Rule do not serve the goal of educating
consumers about how to care for their
garments.
In light of the many stakeholder
comments expressing support for the
Rule, the Commission concludes that a
continuing need exists for the Rule and
that the Rule imposes reasonable costs
on the industry. The Commission
therefore concludes that the weight of
the record evidence clearly supports
retention of the Rule.
IV. Proposed Amendments
Many of the comments supporting the
Rule also advocated various
amendments. Accordingly, based on the
comments and the evidence discussed
herein, the Commission proposes to
amend the Rule in the following four
ways.142 First, the Commission proposes
139 Thorsteinson
(45).
Apparel & Footwear Association
(113) and Hurley (60).
141 See footnote 20 for more details about these
comments.
142 The Commission can issue a NPRM under the
FTC Act if it has ‘‘reason to believe that the unfair
or deceptive acts or practices which are the subject
of the proposed rulemaking are prevalent.’’ 15
U.S.C. 57a(b)(3). The Commission can find ‘‘unfair
or deceptive acts or practices are prevalent’’ where:
‘‘(A) it has issued cease and desist orders regarding
such acts or practices, or (B) any other information
available to the Commission indicates a widespread
pattern of unfair or deceptive acts or practices.’’ Id.
140 American
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to permit manufacturers and importers
to provide a care instruction for
professional wetcleaning on labels if the
garment can be professionally
wetcleaned. Second, the Commission
proposes to permit manufacturers and
importers to use the symbol system set
forth in either ASTM Standard D5489–
07, ‘‘Standard Guide for Care Symbols
for Care Instructions on Textile
Products,’’ or ISO 3758:2005(E),
‘‘Textiles C Care labelling code using
symbols.’’ Third, the Commission
proposes to clarify what constitutes a
reasonable basis for care instructions.
Finally, the Commission proposes to
update the definition of ‘‘dryclean’’ to
reflect current practices and
technology.143
A. Professional Wetcleaning
As noted above, in 2000, the
Commission declined to amend the Rule
to permit a ‘‘Professionally Wetclean’’
instruction on labels. The Commission
stated that it would consider permitting
such an instruction if a more specific
definition and/or test procedure were
developed that provided manufacturers
with a reasonable basis for a
wetcleaning instruction.144 The
Commission explained at the time that
it was premature to permit such an
instruction due to the absence of a
suitable definition and appropriate test
method.
The record now shows that these
conditions have been met. ISO has
developed ISO 3175–4:2003, ‘‘Textiles—
Professional care, drycleaning and
wetcleaning of fabrics and garments—
Part 4: Procedure for testing
performance when cleaning and
finishing using simulated wetcleaning.’’
This standard includes a definition of
wetcleaning and test procedures for
determining whether apparel can be
wetcleaned professionally. Several
comments favoring a wetcleaning
instruction cited this standard
approvingly.145 None of the comments
at 57a(b)(3)(A)–(B). The Commission has ‘‘wide
latitude’’ in fashioning a remedy and need only
show a ‘‘reasonable relationship’’ between the
unfair or deceptive act or practice and the remedy.
American Fin. Servs. Ass’n v. FTC, 767 F.2d 957,
988 (DC Cir. 1985) (quoting Jacob Siegel Co. v. FTC,
327 U.S. 608, 612–13 (1946)).
143 The Commission also proposes to delete the
words ‘‘As Amended’’ from the Rule’s title. These
words do not serve any purpose, and none of the
other titles of Commission rules that have been
amended include these words.
144 Federal Trade Commission: Trade Regulation
Rule on Care Labeling of Textile Wearing Apparel
and Certain Piece Goods, Final Amended Rule, 65
FR 47261, 47273 (Aug. 2, 2000).
145 UCLA Sustainable Technology & Policy
Program (84); Toxic Use Reduction Institute (86);
and Riggs (53).
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argued that the ISO standard is
inadequate.146
As described in Section II.A, the
record shows widespread support for
amending the Rule to include
professional wetcleaning. Many
comments explained the economic,
environmental, and health benefits of
wetcleaning. They also noted the
increasing industry acceptance and use
of wetcleaning, the inclusion of
wetcleaning symbols in both the ASTM
and ISO care symbol systems, and the
risk that failing to allow an instruction
could place wetcleaners at a
disadvantage, thereby discouraging its
use despite its advantages. The
increasing industry acceptance and use
of wetcleaning and the inclusion of
wetcleaning symbols in both the ASTM
and ISO systems establish the
prevalence of wetcleaning. Only three
comments expressed reservations, and
none of them provided evidence that
amending the Rule would harm
consumers or that the cost of doing so
would exceed the benefits.
While the record supports permitting
a professional wetcleaning instruction,
it does not warrant requiring such an
instruction. 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. 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.147 Thus,
the Commission declines to propose
amending the Rule to require a
wetcleaning instruction. If consumers
prefer wetcleaning to drycleaning and
make their purchase decisions
accordingly, manufacturers and
importers will have an incentive to
provide a wetcleaning instruction either
in addition to, or in lieu of, a
drycleaning instruction. Furthermore,
by treating drycleaning and wetcleaning
in a similar fashion—as care procedures
that manufacturers and importers can
disclose to comply with the Rule—the
Rule as proposed would help level the
playing field for the drycleaning and
wetcleaning industries.
146 The standard ISO 3758:2005(E), ‘‘Textiles—
Care labelling code using symbols’’ also defines
wetcleaning.
147 Also, the comments stating that the benefits of
requiring a wetcleaning instruction would exceed
the added testing and labeling costs were not
submitted by entities that would purportedly incur
the added costs that would result if the Commission
amends the Rule to require a wetcleaning
instruction. See UCLA Sustainable Technology &
Policy Program (84); NCA and DLI (124); and Riggs
(53).
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Based on this record, the Commission
concludes that permitting a professional
wetcleaning instruction would provide
consumers with useful information
regarding the care of the apparel they
purchase. Therefore, the Commission
proposes adding a definition of
‘‘wetclean’’ based on the definition of
‘‘professional wet cleaning’’ set forth in
ISO 3758:2005(E). Specifically,
proposed section 423.1(h) would state
that ‘‘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.
This definition closely tracks the
definition in a widely-used
international standard cited approvingly
in comments. Thus, the Commission
concludes that the definition would
provide manufacturers and importers
with sufficient guidance to distinguish
wetcleaning from other cleaning
processes, thereby helping them to
determine whether they have enough
evidence to provide a wetcleaning
instruction or a warning not to
wetclean, if they choose to do so. The
Commission also proposes to amend
Appendix A by including this definition
as set forth in the proposed amendment
in the last section of this Notice of
Proposed Rulemaking.
In addition to defining ‘‘wetclean,’’
the Commission proposes amending
section 423.6(b) to add a wetcleaning
subsection, as set forth in the proposed
amendment in the last section of this
Notice of Proposed Rulemaking. To
harmonize with international standards,
the proposed subsection states that any
wetcleaning instruction must indicate
whether to use a normal, mild or very
mild process and disclose fiber content
if needed to select the appropriate
wetcleaning process. These
amendments bring the Rule in line with
both the ASTM and ISO symbol
systems, and ISO 3758:2005(E)’s fiber
disclosure.
This proposed amendment would not
impose any new obligations on
manufacturers or importers. They could
choose to provide a wetcleaning
instruction if they have a reasonable
basis for it and wish to do so. They also
could provide a different instruction,
such as a drycleaning or washing
instruction.
The proposal, however, would require
manufacturers and importers currently
labeling items with a ‘‘dryclean only’’
instruction either to substantiate that
wetcleaning is an inappropriate method
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of care or to revise their labels. Revised
labels stating ‘‘dryclean’’ would comply
with the Rule. Manufacturers and
importers who wished to convey to
consumers that home laundering would
damage the garment could, if they
wished, label the garment as ‘‘dryclean/
do not home wash,’’ but would comply
with the Rule if they disclosed just the
cleaning method (in this example,
drycleaning) known to produce safe
results. Manufacturers and importers
could continue to use the ‘‘dryclean
only’’ label only if they could
substantiate that both home laundering
and professional wetcleaning were
inappropriate methods for cleaning the
garment.
B. Use of Care Symbols
The Rule permits manufacturers and
importers to use care symbols set forth
in ASTM Standard 5489–96c, ‘‘Guide to
Care Symbols for Care Instructions on
Consumer Textile Products.’’ Since the
Commission last amended the Rule in
2000, ASTM has updated this standard
to ASTM D5489–07, ‘‘Standard Guide
for Care Symbols for Care Instructions
on Textile Products.’’ The Rule
currently does not permit the use of this
updated, or any other non-ASTM
symbol system in lieu of terms.
Nearly all of the comments addressing
the issue favored allowing the use of
symbols in lieu of terms. Some favored
amending the Rule to reference ASTM
D5489–07, the most recent version of
the ASTM standard, or ASTM D5489
without designating the year so that the
Rule would automatically reference the
latest version of the standard. Still
others favored allowing the use of the
symbol system developed by ISO.
Several urged the Commission to amend
the Rule to harmonize the ASTM
symbols permitted by the Rule with
those set forth in the ISO standard or to
allow manufacturers and importers to
use either symbol system. None of the
comments expressed a preference for
the ASTM symbol system currently
referenced in the Rule. Nor did any of
the comments oppose the
harmonization of the ASTM and ISO
symbols.
The record supports: (1) Continuing to
allow the use of ASTM care symbols in
lieu of terms, (2) updating the Rule to
reference the 2007 version of the ASTM
standard, and (3) permitting the use of
the ASTM and ISO symbols. The
Commission concludes that permitting
the use of the symbol system in either
the updated ASTM standard, ASTM
D5489–07, or ISO 3758:2005(E) would
ensure that manufacturers and
importers that choose to use symbols in
lieu of terms will use them consistent
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with the latest industry standards.148 It
also would provide them with the
flexibility to use either symbol system,
resulting in less cluttered labels if
manufacturers opt to use one set of
symbols.149
Because the ASTM and ISO symbol
systems are not identical, consumers
may need to know which system
appears on the label so that they can
ascertain or confirm the meaning of a
particular symbol. Furthermore,
permitting the use of two symbol
systems could increase the risk of
consumer confusion. Therefore, the
Commission proposes requiring that
manufacturers or importers opting to
disclose care instructions using the ISO
symbols disclose that they are using ISO
symbols. The Commission does not
propose requiring a similar disclosure
on labels using the ASTM symbols
because the Rule already permits the
use of ASTM symbols without requiring
any such disclosure. For example,
consumers might have a greater
familiarity with the ASTM symbols than
with the ISO symbols because the Rule
started permitting them in 1997. On the
other hand, that may not be the case.
The Commission seeks comment on this
issue, including on the extent to which
care labels currently include ASTM and
ISO symbols.
Permitting the use of either symbol
system should not confuse or deceive
consumers because the symbol systems
are nearly identical. Although the
ASTM system includes more symbols
than the ISO system,150 the two systems
use virtually identical symbols for
washing, bleaching, and professional
care such as drycleaning and
wetcleaning. Manufacturers and
importers that prefer to use the ISO
148 Manufacturers would need to purchase and
follow only one of the two standards to disclose
care instructions using symbols, thereby reducing
compliance costs. E.g., manufacturers already using
ISO symbols in lieu of written terms would not
need to incur the expense of adding ASTM symbols
or written terms to their labels so that they can
market their garments in the United States.
149 Both the ASTM and ISO standards are subject
to copyrights and can be purchased from the
organizations that issued them. In addition, the ISO
symbols are protected by trademarks and their use
is dependent on a contract with GINETEX. See
www.ginetex.net. Consumers can find the symbols
and explanations of their meaning on the Internet,
including the ISO symbols on the GINETEX Web
site and the currently approved ASTM symbols on
the FTC Web site at https://www.ftc.gov/opa/1996/
12/label.pdf. Consumers can find the professional
care symbols in the 2007 version of the ASTM
standard on page three of the GreenEarth comment
(mistakenly described as the ‘‘current FTC Symbol
Chart’’) located at https://www.ftc.gov/os/comments/
carelabelinganpr/00098-80529.pdf.
150 E.g., the ISO system has fewer symbols for
drying. ISO has normal and low temperature
symbols while ASTM has symbols for any heat,
high, medium, low, and no heat/air.
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system can supplement the ISO symbols
with written instructions as appropriate.
Both symbol systems lack symbols for
certain instructions and acknowledge
the need to supplement their symbols
with written instructions as
appropriate.151
Although the two systems differ
slightly with respect to drying and
ironing symbols, the differences do not
appear substantial. 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. If a manufacturer or
importer concludes that one of the
systems has symbols that more
effectively convey the proper care
instructions, it can choose to use that
system.152
The Commission notes 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, means 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.153
However, even if consumers
understand the symbol at the time of
purchase, confusion could result with
respect to: (1) Products labeled before,
but sold after, the symbol system
change; and (2) situations where the
consumer does not remember whether
he or she purchased the product before
or after the symbol change. The change
in the symbol’s meaning could also
cause confusion if drycleaners do not
know whether the garment was labeled
before the change. Of course,
notwithstanding the change in symbol
meaning, consumers and drycleaners
can avoid any risk of using an
inappropriate solvent by using
petroleum rather than perc to dryclean
the product (under both the old and
151 E.g., both the ASTM and ISO systems list
written instructions, including ‘‘wash separately’’
and ‘‘remove promptly.’’
152 E.g., if a manufacturer or importer determines
that it needs to use one of the ASTM drying
symbols not available in the ISO system to convey
drying instructions properly, it can opt to use the
ASTM symbol system. If both systems have a drying
symbol that suffices, it can opt to use either system.
153 As noted in footnote 149, consumers can find
the symbols and explanations of their meaning on
the Internet.
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new meaning, the symbol indicates that
petroleum can be used). The
Commission seeks comment on these
issues.
As explained above, a comment from
GreenEarth urged the Commission to
replace the ASTM and ISO symbols
with new symbols based on a solvent’s
aggressiveness rather than type.154
GreenEarth did not submit any evidence
on consumer perception of its proposed
symbols or establish that any resulting
benefits would exceed the cost to
business.155 Moreover, none of the other
comments proposed anything similar to
GreenEarth’s proposal. The record,
therefore, does not indicate that
GreenEarth’s approach to care
instructions would be superior to the
current one. Moreover, it would
represent a significant departure from
the symbol system currently permitted
by the Rule as well as from the updated
ASTM and ISO symbol systems widely
used by apparel manufacturers and
importers and favored by nearly all of
the other comments that addressed the
use of symbols. Therefore, the
Commission declines to adopt
GreenEarth’s proposal.156
Finally, Section 423.8(g) states that,
for the 18-month period beginning on
July 1, 1997, symbols may be used in
lieu of terms only if an explanation of
the symbols is attached to, or provided
with, the product. This provision has
expired; therefore, the Commission
proposes to remove it from the Rule.
To implement the revisions described
above, the Commission proposes
amending Section 423.8(g) as set forth
in the proposed amendment in the last
section of this Notice of Proposed
Rulemaking.
One of the comments urged the
Commission to update the Rule by
referring to the ASTM standard without
identifying the year or version of the
standard. The comment argued that, if
the Commission amended the Rule in
this way, the Rule would always
incorporate the most recent ASTM
standard. The Commission declines to
follow this approach because it would,
in effect, grant ASTM the power to
revise a Commission Rule. If ASTM
154 GreenEarth’s arguments and proposal are
summarized in Section II.C.
155 GreenEarth argued that its proposal would
encourage the substitution of less aggressive
solvents for more aggressive ones in the cleaning
process, thereby measurably reducing claims for
damaged garments. However, it did not address
whether its proposal would increase the cost of
providing care instructions or submit any evidence
showing that its proposal would actually reduce the
use of more aggressive solvents.
156 GreenEarth may wish to submit its proposal to
ASTM and ISO for their consideration if it has not
already done so.
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revises the standard, the Commission
can consider whether to revise the Rule
to incorporate the revised standard. Any
interested party can petition the
Commission to amend the Rule at any
time, particularly if the failure to
incorporate the revised standard would
have an adverse effect on consumers or
commerce.157
C. Clarification of Reasonable Basis
Requirements
As noted above, the Rule requires that
manufacturers and importers possess a
reasonable basis for the care instructions
they provide prior to sale. Under the
Rule, a reasonable basis must consist of
reliable evidence supporting the
instructions on the label.158
Specifically, a reasonable basis can
consist of: (1) Reliable evidence that the
product was not harmed when cleaned
reasonably often according to the
instructions; (2) reliable evidence that
the product or a fair sample of the
product was harmed when cleaned by
methods warned against on the label; (3)
reliable evidence, like that described in
(1) or (2), for each component part of the
product in conjunction with reliable
evidence for the garment as a whole; (4)
reliable evidence that the product or a
fair sample of the product was
successfully tested; (5) reliable evidence
of current technical literature, past
experience, or industry expertise
supporting the care information on the
label; or (6) other reliable evidence.159
Several comments summarized in
Section II.C above urged the
Commission to impose more rigorous
testing requirements or to clarify the
Rule’s reasonable basis requirements.
These comments explained that some
manufacturers and importers appear not
to understand the Rule’s reasonable
basis requirements. No comment
provided specific suggestions.
The record is devoid of evidence
showing that any manufacturers or
importers improperly relied on evidence
other than testing, that particular testing
was inadequate or flawed, or that the
benefits of requiring additional or more
rigorous testing to ensure better care
instructions would exceed the costs to
manufacturers and importers. The mere
assertion that some manufacturers or
importers violate the Rule does not
prove that the Commission needs to
amend the Rule. Therefore, the
Commission declines to propose more
rigorous testing requirements.
However, the comments suggest a
need to clarify the Rule’s reasonable
157 See
158 16
16 CFR 1.9.
CFR 423.6(c).
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D. Revised Definition of Dryclean
Several comments urged the
Commission to update and expand the
Rule’s definition of ‘‘dryclean’’ to
include new solvents in the list of
examples and to cover solvents that are
not organically-based. One comment
noted the introduction of new solvents
over the last 25 years, such as high flash
hydrocarbons, silicones, glycol ethers,
carbon dioxide, and aldehydes. It also
explained that one solvent listed in the
definition, fluorocarbon, is no longer
used, and that not all solvents are
organically-based. Additionally, several
comments argued that the definition
discourages the use of solvents not
recognized by the Rule and, therefore,
risks curtailing technological
advancement.
The record shows that the
Commission needs to modernize the
Rule’s definition of ‘‘dryclean.’’
Although the definition technically
includes all common organic solvents, it
only lists three examples, one of which
is no longer used. To address the
concerns raised by comments, the
Commission proposes to broaden the
definition to cover any solvent
excluding water. In addition, the
Commission proposes to drop the
reference to fluorocarbon and add new
solvents identified in the record to the
list of examples. The Commission does
not propose to delete perchloroethylene
from the list because drycleaners
continue to use it and may do so at least
160 The Commission also proposes to correct an
error in Section 423.6(c) by replacing the word
‘‘processing’’ with ‘‘possessing.’’
159 Id.
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basis requirements to aid compliance
without increasing or decreasing the
burden imposed on industry.
Specifically, providing examples of
situations where testing an entire
garment may be needed to determine
care instructions, as well as examples
where such testing is not needed, may
help clarify the Rule’s requirements.
Accordingly, the Commission proposes
to incorporate advice from its business
education materials and include
examples in Section 423.6(c)(3) and (5)
as set forth in the proposed amendment
in the last section of this Notice of
Proposed Rulemaking.
Because the Commission does not
intend to impose new requirements on
manufacturers or importers, it views
these proposed revisions as nonsubstantive.160 Nonetheless, the
Commission seeks comment regarding
whether these proposed additions
would be helpful and whether the
Commission should provide any
additional clarification.
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until California’s ban takes effect in
2023. Accordingly, the Commission
proposes amending Section 423.1(c) as
set forth in the proposed amendment in
the last section of this Notice of
Proposed Rulemaking.
The Commission also proposes to
amend Appendix A.7.a in the same way
and to amend Appendix 7.c to include
the solvent examples from the revised
definition.
V. Other Amendments the Commission
Declines To Propose
A number of comments proposed
amendments to the Rule other than
those discussed above. Some suggested
that the Commission require
manufacturers and importers to disclose
all appropriate care procedures. Others
proposed requiring additional
disclosures, disallowing certain care
instructions, addressing the format or
composition of labels, expanding the
scope of the Rule, or imposing
additional requirements such as making
manufacturers or importers accountable
to consumers if they provide inaccurate
care instructions. One commenter
proposed changing the ‘‘overarching
nomenclature and the guiding
principle’’ behind the Rule to improve
the reliability and understandability of
care labels. The Commission declines to
propose any of these amendments for
the reasons explained below.
Additionally, the comments did not
suggest amending the Rule to address
the presentation of instructions in
multiple languages, and the
Commission declines to propose any
amendments addressing this issue.
Several comments from the cleaning
industry urged the Commission to
require manufacturers and importers to
disclose all appropriate methods of care.
None of the comments from other
affected industries supported this
proposal. The Commission issued the
Rule to protect consumers from unfair
and deceptive trade practices. In issuing
the Rule, the Commission determined,
based on the record in the proceeding,
that it was unfair or deceptive for
manufacturers and importers to fail to
disclose a regular care procedure
necessary for the ordinary use and
enjoyment of the product (or to warn the
consumer that the product cannot be
cleaned without being harmed). It did
not conclude that manufacturers and
importers must disclose multiple care
procedures. None of the comments
included evidence demonstrating that
the failure to disclose all appropriate
care methods would result in deception
or unfairness under the FTC Act. Nor
did they submit evidence that the
benefits of requiring such a disclosure
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would exceed the costs such a
requirement would impose on
manufacturers and retailers. The
Commission, therefore, has no reason to
believe that it is either unfair or
deceptive for a manufacturer or
importer to fail to disclose all
appropriate methods of care.
Similarly, the other comments
proposing that the Commission impose
additional disclosure or other
obligations on manufacturers and
importers, summarized in Section II.F
above, failed to show that imposing
these obligations is necessary to prevent
deception or unfairness. Nor did they
show that the benefits of the proposals
would exceed their costs. Thus, the
Commission declines to propose any of
these amendments.
Some comments urged the
Commission to require manufacturers
and importers to disclose fiber content
on care labels even though the
Commission’s Rules and Regulations
Under the Textile Fiber Products
Identification Act (‘‘Textile Rules’’)
already require disclosure of fiber
content.161 The comments did not
provide evidence addressing the need
for this amendment or the costs it would
impose. While it is true that the Textile
Rules do not require this disclosure in
a form that can be referred to by the
consumer throughout the useful life of
the product, the Commission has
anecdotal evidence that some
manufacturers and importers often
include the fiber content disclosure
required by the Textile Rules on the
same ‘‘permanent’’ label that provides
care instructions. In addition, as
explained above, the Commission
proposes to require that any wetcleaning
instruction disclose fiber content if
needed to select the appropriate
wetcleaning process. The Commission
seeks comment on the extent to which
care labels already disclose fiber content
and the need for fiber content
information on ‘‘permanent’’ labels but,
at this time, declines to propose
amending the Rule to address this issue.
GreenEarth proposed changing the
‘‘overarching nomenclature and the
guiding principle’’ behind the Rule to
improve the reliability and
understandability of care labels (e.g., by
replacing instructions such as
‘‘dryclean’’ and ‘‘do not dryclean’’ with
simplified categories of ‘‘cleaning
method’’ and ‘‘cycle’’).162 GreenEarth,
however, did not submit any evidence
on consumer perception of its proposed
nomenclature for care instructions or
161 16
CFR part 303.
discussion of GreenEarth’s comment in
Section II.B.
162 See
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whether the benefits of replacing the
Rule’s existing nomenclature and
guiding principles would exceed the
cost to business.163 None of the other
comments made similar proposals or
addressed GreenEarth’s proposal. The
record does not establish that
GreenEarth’s approach would be
superior to the current one. In addition,
it would represent a significant
departure from the Rule’s longstanding
approach to and industry practice for
providing care instructions. The
Commission, therefore, declines to
propose amending the Rule as proposed
by GreenEarth.164
Finally, the ANPR sought comments
on whether the Commission should
amend the Rule to address care
instructions in multiple languages.
None of the comments proposed
amending the Rule to address the format
for presenting instructions in more than
one language, although two comments
noted that using or harmonizing
symbols would address problems
stemming from disclosures in multiple
languages. Because none of the
comments proposed any amendments
directly addressing the presentation of
multiple languages on care labels, the
Commission declines to propose any
amendments on this issue. The
Commission, however, seeks additional
comment on whether any of the
proposed amendments to the Rule affect
the need to address this issue.
VI. Request for Comments
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
before November 16, 2012. Write ‘‘Care
Labeling Rule, 16 CFR part 423, Project
No. R511915’’ on your comment. Your
comment—including your name and
your state—will be placed on the public
record of this proceeding, including, to
the extent practicable, on the public
Commission Web site, at https://
www.ftc.gov/os/publiccomments.shtm.
As a matter of discretion, the
Commission tries to remove individuals’
home contact information from
comments before placing them on the
Commission Web site.
Because your comment will be made
public, you are solely responsible for
163 GreenEarth argued that its proposal would
encourage the substitution of less aggressive
solvents for more aggressive ones in the cleaning
process, thereby measurably reducing claims for
damaged garments. However, it did not address
whether its proposal would increase the cost of
providing care instructions, or submit any evidence
showing that its proposal would actually reduce the
use of more aggressive solvents.
164 The Commission rejects GreenEarth’s proposal
regarding care symbols for similar reasons. See
discussion in Section IV.B.
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making sure that your comment doesn’t
include any sensitive personal
information, such as anyone’s Social
Security number, date of birth, driver’s
license number or other state
identification number or foreign country
equivalent, passport number, financial
account number, or credit or debit card
number. You are also solely responsible
for making sure that your comment
doesn’t include any sensitive health
information, such as medical records or
other individually identifiable health
information. In addition, don’t include
any ‘[t]rade secret or any commercial or
financial information which is obtained
from any person and which is privileged
or confidential,’’ as provided in Section
6(f) of the FTC Act, 15 U.S.C. 46(f), and
FTC Rule 4.10(a)(2), 16 CFR 4.10(a)(2).
In particular, don’t include
competitively sensitive information
such as costs, sales statistics,
inventories, formulas, patterns, devices,
manufacturing processes, or customer
names.
If you want the Commission to give
your comment confidential treatment,
you must file it in paper form, with a
request for confidential treatment, and
you have to follow the procedure
explained in FTC Rule 4.9(c), 16 CFR
4.9(c).165 Your comment will be kept
confidential only if the FTC General
Counsel, in his or her sole discretion,
grants your request in accordance with
the law and the public interest.
Postal mail addressed to the
Commission is subject to delay due to
heightened security screening. As a
result, we encourage you to submit your
comments online. To make sure that the
Commission considers your online
comment, you must file it at https://
ftcpublic.commentworks.com/ftc/
CareLabelingNPRM, by following the
instruction on the web-based form. If
this Notice appears at https://
www.regulations.gov/#!home, you also
may file a comment through that Web
site.
If you file your comment on paper,
write ‘‘Care Labeling Rule, 16 CFR Part
423, Project No. R511915’’ on your
comment and on the envelope, and mail
or deliver it to the following address:
Federal Trade Commission, Office of the
Secretary, Room H–113 (Annex B), 600
Pennsylvania Avenue NW., Washington,
DC 20580. If possible, submit your
paper comment to the Commission by
courier or overnight service.
165 In particular, the written request for
confidential treatment that accompanies the
comment must include the factual and legal basis
for the request, and must identify the specific
portions of the comment to be withheld from the
public record. See FTC Rule 4.9(c), 16 CFR 4.9(c).
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Visit the Commission Web site at
https://www.ftc.gov to read this NPRM
and the news release describing it. The
FTC Act and other laws that the
Commission administers permit the
collection of public comments to
consider and use in this proceeding as
appropriate. The Commission will
consider all timely and responsive
public comments that it receives on or
before November 16, 2012. You can find
more information, including routine
uses permitted by the Privacy Act, in
the Commission’s privacy policy, at
https://www.ftc.gov/ftc/privacy.htm.
The Commission invites members of
the public to comment on any issues or
concerns they believe are relevant or
appropriate to the Commission’s
consideration of proposed amendments
to the Care Labeling Rule. The
Commission requests that comments
provide factual data upon which they
are based. In addition to the issues
raised above, the Commission solicits
public comment on the costs and
benefits to industry members and
consumers of each of the proposals as
well as the specific questions identified
below. These questions are designed to
assist the public and should not be
construed as a limitation on the issues
on which public comment may be
submitted.
Questions
1. Is there empirical evidence
regarding whether consumers interpret a
‘‘dryclean’’ instruction to mean that a
garment cannot be washed? If so, please
submit such evidence.
2. How many domestic businesses
provide professional wetcleaning to the
public on a regular basis? To what
extent do domestic businesses provide
both drycleaning and wetcleaning?
What evidence supports your answers?
3. To what extent do consumers have
access to and use professional
wetcleaning services? To what extent
are wetcleaning services widely
available geographically? What evidence
supports your answers?
4. To what extent are consumers
aware of the attributes and availability
of professional wetcleaning services?
What evidence supports your answer?
5. Assuming the Commission amends
the Rule to permit a wetcleaning
instruction, should the Commission also
amend Section 423.8(d) of the Rule,
which exempts products that can be
cleaned safely under the harshest
procedures from the requirement of a
permanent care label? If so, how? What
evidence supports your answer? For
example, should the Commission
amend this section to add professional
wetcleaning to the list of procedures
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that safely can be used for a product to
fall under this exemption?
6. To what extent do drycleaners use
solvents other than petroleum and perc?
To what extent do they use each of these
drycleaning solvents? How do these
other solvents compare to perc with
respect to performance and
environmental effects? To what extent
do they use multiple solvents? What
evidence supports your answers?
7. To what extent do manufactures
and importers disclose fiber content
information on labels providing care
instructions? What evidence supports
your answer?
8. To what extent do manufacturers
and importers use care symbols to
provide care instructions for garments
and piece goods sold in the United
States? To what extent do they use
symbols alone? To what extent do they
use symbols in conjunction with written
instructions? To what extent do they use
ASTM symbols without using ISO
symbols, ISO symbols without using
ASTM symbols, or both ASTM and ISO
symbols? What evidence supports your
answer?
9. Is there empirical evidence
regarding the extent to which
consumers understand or rely on care
symbols or find labels using multiple
symbol systems, such as both the ASTM
and ISO symbol systems, confusing? If
so, please submit such evidence.
10. The meaning of one drycleaning
symbol in the ASTM symbol system
currently permitted by the Rule, a circle
with the letter ‘‘P’’ inside, changed
significantly in the revised ASTM
symbol system. The currently permitted
symbol means dryclean with any
solvent except perc. In contrast, the
symbol under the revised system means
dryclean with perc or petroleum.
Should the Commission amend the Rule
to address this issue? If so, how? What
evidence supports your answer?
11. Do the proposed amendments to
the Rule’s reasonable basis provisions
clarify them adequately? Is any
additional clarification needed? If so,
what? If not, why not? What evidence
supports your answers?
12. The record did not establish a
need to amend the Rule to address care
labels in multiple languages. Do any of
the proposed amendments to the Rule
affect the need to address this issue? If
so, how? What evidence supports your
answer?
13. Would the following amendments
impose costs or confer benefits on
consumers? Would they impose costs or
confer benefits on apparel and piece
good manufacturers and importers,
especially small businesses? Would they
impose costs or confer benefits on
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58349
businesses that clean apparel, especially
small businesses? Would they impose
costs or confer benefits on businesses
that sell apparel or piece goods to
consumers, especially small businesses?
If so, how? If not, why not? What
evidence supports your answers?
(A) Amending the Rule to permit
manufacturers and importers to provide
a professional wetcleaning instruction
for garments or piece goods that can be
professionally wetcleaned;
(B) Amending the Rule to update the
provision allowing the use of certain
care symbols in lieu of written terms by
permitting manufacturers and importers
to use the symbol system set forth in
either ASTM Standard D5489–07,
‘‘Standard Guide for Care Symbols for
Care Instructions on Textile Products,’’
or ISO 3758:2005(E), ‘‘Textiles—Care
labelling code using symbols’’;
(C) Amending the Rule to clarify the
Rule’s reasonable basis requirements;
and
(D) Amending the Rule’s definition of
‘‘dryclean.’’
14. General Questions: To maximize
the benefits and minimize the costs for
buyers and sellers (including
specifically small businesses), the
Commission seeks views and data on
the following general questions for all
the proposed changes described in this
document:
(A) What benefits would the proposed
changes confer, and on whom?
(B) What costs or burdens would the
proposed changes impose, and on
whom?
(C) What regulatory alternatives to the
proposed changes are available that
would reduce the burdens of the
proposed changes while providing the
same benefits?
VII. Communications to Commissioners
and Commissioner Advisors by Outside
Parties
Pursuant to Commission Rule
1.18(c)(1), the Commission has
determined that communications with
respect to the merits of this proceeding
from any outside party to any
Commissioner or Commissioner advisor
shall be subject to the following
treatment. Written communications and
summaries or transcripts of oral
communications shall be placed on the
rulemaking record if the communication
is received before the end of the
comment period on the staff report.
They shall be placed on the public
record if the communication is received
later. Unless the outside party making
an oral communication is a member of
Congress, such communications are
permitted only if advance notice is
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published in the Weekly Calendar and
Notice of ‘‘Sunshine’’ Meetings.166
VIII. Preliminary Regulatory Analysis
and Regulatory Flexibility Act
Requirements
Under Section 22 of the FTC Act, 15
U.S.C. 57b, the Commission must issue
a preliminary regulatory analysis for a
proceeding to amend a rule only when
it: (1) Estimates that the amendment
will have an annual effect on the
national economy of $100 million or
more; (2) estimates that the amendment
will cause a substantial change in the
cost or price of certain categories of
goods or services; or (3) otherwise
determines that the amendment will
have a significant effect upon covered
entities or upon consumers. The
Commission has preliminarily
determined that the proposed
amendments will not have such effects
on the national economy; on the cost of
labeling apparel and piece goods; or on
covered parties or consumers.
The proposed amendments provide
manufacturers and importers with
additional options for disclosing care
instructions, clarify the Rule, and
update the definition of ‘‘dryclean’’ to
reflect current practices and technology,
so the proposed amendments would not
require manufacturers or importers to
alter their behavior and would not
impose additional costs on them. The
Commission, however, requests
comment on the economic effects of the
proposed amendments.
The Regulatory Flexibility Act
(‘‘RFA’’), 5 U.S.C. 601–612, requires that
the Commission conduct an analysis of
the anticipated economic impact of the
proposed amendments on small entities.
The purpose of a regulatory flexibility
analysis is to ensure that an agency
considers the impacts on small entities
and examines regulatory alternatives
that could achieve the regulatory
purpose while minimizing burdens on
small entities. Section 605 of the RFA,
5 U.S.C. 605, provides that such an
analysis is not required if the agency
head certifies that the regulatory action
will not have a significant economic
impact on a substantial number of small
entities. The Commission believes that
the proposed amendments would not
have a significant economic impact
upon small entities, although it may
affect a substantial number of small
businesses. Specifically, the
Commission proposes a few limited
amendments designed to provide
manufacturers and importers with more
options for disclosing care instructions,
clarify the Rule, and update the
166
See 15 U.S.C. 57a(i)(2)(A); 16 CFR 1.18(c).
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definition of ‘‘dryclean.’’ In the
Commission’s view, the proposed
amendments should not have a
significant or disproportionate impact
on the costs of small entities that
manufacture or import apparel or piece
goods. Therefore, based on available
information, the Commission certifies
that amending the Rule as proposed will
not have a significant economic impact
on a substantial number of small
businesses.
Although the Commission certifies
under the RFA that the proposed
amendments would not, if promulgated,
have a significant impact on a
substantial number of small entities, the
Commission has determined,
nonetheless, that it is appropriate to
publish an Initial Regulatory Flexibility
Analysis to inquire into the impact of
the proposed amendments on small
entities. Therefore, the Commission has
prepared the following analysis:
A. Description of the Reasons That
Action by the Agency is Being Taken
In response to public comments, the
Commission proposes amending the
Rule to respond to the development of
new technologies, changed commercial
practices, and updated industry
standards.
B. Statement of the Objectives of, and
Legal Basis for, the Proposed
Amendments
The objective of the proposed
amendments is to provide
manufacturers and importers of apparel
and certain piece goods with additional
options for disclosing care instructions,
clarify the Rule’s reasonable basis
provisions, and update the definition of
‘‘dryclean’’ to reflect current practices
and technology. The Commission
promulgated the Rule pursuant to
Section 18 of the FTC Act, 15 U.S.C.
57a. As noted earlier, the Commission
has wide latitude in fashioning a
remedy and need only show a
‘‘reasonable relationship’’ between the
unfair or deceptive act at issue and the
remedy.167 The Rule as modified by the
proposed amendments would
reasonably relate to the practices that
led the Commission to promulgate the
Rule. It would provide covered entities
with additional options for complying
with the Rule’s disclosure requirements
without imposing new burdens or
additional costs.
167 American
Fin. Servs. Ass’n v. FTC, 767 F.2d
957, 988 (D.C. Cir. 1985) (quoting Jacob Siegel Co.
v. FTC, 327 U.S. 608, 612–13 (1946)).
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C. Small Entities to Which the Proposed
Amendments Will Apply
Under the Small Business Size
Standards issued by the Small Business
Administration, textile apparel and
some fabric manufacturers qualify as
small businesses if they have 500 or
fewer employees. Clothing and piece
good wholesalers qualify as small
businesses if they have 100 or fewer
employees. The Commission’s staff has
estimated that approximately 22,218
manufacturers or importers of textile
apparel are covered by the Rule’s
disclosure requirements.168 A
substantial number of these entities
likely qualify as small businesses. The
Commission estimates that the proposed
amendments will not have a significant
impact on small businesses because it
does not impose any new obligations on
them. The Commission seeks comment
and information with regard to the
estimated number or nature of small
business entities for which the proposed
amendments would have a significant
impact.
D. Projected Reporting, Recordkeeping,
and Other Compliance Requirements,
Including Classes of Covered Small
Entities and Professional Skills Needed
to Comply
As explained earlier in this document,
the proposed amendments will provide
apparel manufacturers and importers
with additional options for disclosing
care instructions, clarify the Rule’s
reasonable basis requirements, and
update the definition of ‘‘dryclean’’ to
reflect current practices and technology.
The small entities potentially covered
by these proposed amendments will
include all such entities subject to the
Rule. The professional skills necessary
for compliance with the Rule as
modified by the proposed amendments
would include office and administrative
support supervisors to determine label
content and clerical personnel to draft
and obtain labels. The Commission
invites comment and information on
these issues.
E. Duplicative, Overlapping, or
Conflicting Federal Rules
The Commission has not identified
any other federal statutes, rules, or
policies that would duplicate, overlap,
or conflict with the proposed
amendments. The Commission invites
comment and information on this issue.
168 Federal Trade Commission: Agency
Information Collection Activities; Proposed
Collection; Comment Request, 76 FR 77230 (Dec.
12, 2011).
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F. Significant Alternatives to the
Proposed Amendments
The Commission has not proposed
any specific small entity exemption or
other significant alternatives, as the
proposed amendments simply provide
additional options for disclosing care
instructions, clarify the Rule’s
reasonable basis provisions, and update
the definition of ‘‘dryclean’’ to reflect
current practices and technology. Under
these limited circumstances, the
Commission does not believe a special
exemption for small entities or
significant compliance alternatives are
necessary or appropriate to minimize
the compliance burden, if any, on small
entities while achieving the intended
purposes of the proposed amendments.
Nonetheless, the Commission seeks
comment and information on the need,
if any, for alternative compliance
methods that would reduce the
economic impact of the Rule on small
entities. If the comments filed in
response to this NPRM identify small
entities that would be affected by the
proposed amendments, as well as
alternative methods of compliance that
would reduce the economic impact of
the proposed amendments on such
entities, the Commission will consider
the feasibility of such alternatives and
determine whether they should be
incorporated into the final Rule. As
explained above, the Commission
considered a number of alternative
amendments advocated by commenters
and decided not to propose any of them.
wreier-aviles on DSK5TPTVN1PROD with PROPOSALS
IX. Paperwork Reduction Act
The Rule contains various ‘‘collection
of information’’ (e.g., disclosure)
requirements for which the Commission
has obtained OMB clearance under the
Paperwork Reduction Act (‘‘PRA’’), 44
U.S.C. 3501 et seq.169 As discussed
above, the Commission proposes
amendments to: (a) Clarify the Rule; (b)
update the definition of ‘‘dryclean’’ to
reflect current technology and practices;
and (c) provide manufacturers and
importers with added options for
disclosing care instructions. These
proposed amendments do not impose
any additional collection of information
requirements. For example, businesses
169 The Commission recently published its PRA
burden estimates for the current information
collection requirements under the Rule. See Federal
Trade Commission: Agency Information Collection
Activities; Proposed Collection; Comment Request,
76 FR 77230 (Dec. 12, 2011) and Federal Trade
Commission: Agency Information Collection
Activities; Submission for OMB Review; Comment
Request, 77 FR 10744 (Feb. 23, 2012). On March 26,
2012, OMB granted clearance through March 31,
2015, for these requirements and the associated
PRA burden estimates. The OMB control number is
3084–0103.
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that prefer not to provide a wetcleaning
instruction or use symbols need not do
so. Depending on the disclosure option
selected for disclosing care instructions,
the associated PRA burden might even
be reduced.
List of Subjects in 16 CFR Part 423
Clothing, Labeling, Textiles, Trade
practices.
For the reasons set out in the
preamble, the Commission proposes to
amend 16 CFR part 423 as follows:
PART 423—CARE LABELING OF
TEXTILE WEARING APPAREL AND
CERTAIN PIECE GOODS
1. The authority citation for part 423
continues to read as follows:
Authority: 15 U.S.C. 57a.
2. Revise the heading of part 423 to
read as set forth above.
3. Amend § 423.1 by revising
paragraph (c) and adding paragraph (h)
to read as follows:
§ 423.1
Definitions.
*
*
*
*
*
(c) 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% relative humidity, hot tumble
drying up to 160 degrees F (71 degrees
C) and restoration by steam press or
steam-air finishing.
*
*
*
*
*
(h) 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.
4. Amend § 423.6 by revising
paragraph (b) introductory text, adding
paragraph (b)(3), and revising
paragraphs (c) introductory text, (c)(3),
and (c)(5) to read as follows:
§ 423.6
Textile wearing apparel.
*
*
*
*
*
(b) Care labels must state what regular
care is needed for the ordinary use of
the product. In general, labels for textile
wearing apparel must have either a
washing instruction, a drycleaning
instruction, or a wetcleaning
instruction. If a washing instruction is
included, it must comply with the
requirements set forth in paragraph
(b)(1) of this section. If a drycleaning
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58351
instruction is included, it must comply
with the requirements set forth in
paragraph (b)(2) of this section. If a
wetcleaning instruction is included, it
must comply with the requirements set
forth in paragraph (b)(3) of this section.
If washing, drycleaning, or wetcleaning
can be used, the label need have only
one of these instructions. If the product
cannot be cleaned by any available
cleaning method without being harmed,
the label must so state. [For example, if
a product would be harmed by washing,
drycleaning, and wetcleaning, the label
might say, ‘‘Do not wash—do not
dryclean or wetclean,’’ or ‘‘Cannot be
successfully cleaned.’’] The instructions
for washing, drycleaning, and
wetcleaning are as follows:
*
*
*
*
*
(3) Wetcleaning—(i) General. If a
wetcleaning instruction is included on
the label, and a mild or very mild
process should be used, the label must
state the process that must be used. If a
normal process will not harm the
product, the label need not mention any
type of process. If the product’s fiber
content is needed to determine how to
select the appropriate wetcleaning
process, the label must state the fiber
content.
(ii) Warnings. (A) If there is any part
of the wetcleaning procedure which
consumers or wetcleaners reasonably
can be expected to use that would harm
the product or others being cleaned with
it, the label must contain a warning to
this effect. The warning must use the
words ‘‘Do not,’’ ‘‘No,’’ ‘‘Only,’’ or some
other clear wording.
(B) Warnings are not necessary for any
procedure which is an alternative to the
procedure prescribed on the label. [For
example, if an instruction states
‘‘Professionally wetclean, very mild
process,’’ it is not necessary to give the
warning ‘‘Do not use normal process.’’]
(c) A manufacturer or importer must
establish a reasonable basis for care
information by possessing prior to sale:
*
*
*
*
*
(3) Reliable evidence, like that
described in paragraph (c)(1) or (2) of
this section, for each component part of
the product in conjunction with reliable
evidence for the garment as a whole;
provided that test results showing that
a whole garment can be cleaned as
recommended may be required where,
for example:
(i) The color of one part often bleeds
onto another when the finished garment
is washed;
(ii) A dye that is known to bleed, or
beads, buttons, or sequins that are
known to be damaged often in
drycleaning are used; or
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(iii) A garment contains several fibers,
fabrics, or components not previously
used together; or
*
*
*
*
*
(5) Reliable evidence of current
technical literature, past experience, or
industry expertise supporting the care
information on the label [For example,
if past experience with particular dyes
and fabrics indicates that a particular
red trim does not bleed onto
surrounding fabric, testing the entire
garment might not be necessary]; or
*
*
*
*
*
5. Amend § 423.8 by revising
paragraph (g) as follows:
§ 423.8
Exemptions.
wreier-aviles on DSK5TPTVN1PROD with PROPOSALS
*
*
*
*
*
(g) The symbol systems developed by
ASTM International (ASTM) and
designated as ASTM D5489–07,
‘‘Standard Guide for Care Symbols for
Care Instructions on Textile Products’’
and by the International Organization
for Standardization (ISO) and
designated as 3758:2005(E), ‘‘Textiles—
Care labelling code using symbols,’’ may
be used on care labels or care
instructions in lieu of terms so long as
the symbols fulfill the requirements of
this part. If the ISO symbols are used,
the label should disclose this fact. In
addition, symbols from either one of the
two symbol systems above may be
combined with terms so long as the
symbols and terms used fulfill the
requirements of this part. This
incorporation by reference was
approved by the Director of the Federal
Register in accordance with 5 U.S.C.
552(a) and 1 CFR part 51. Copies of
ASTM D5489–07, ‘‘Standard Guide for
Care Symbols for Care Instructions on
Textile Products,’’ may be obtained from
ASTM, 100 Barr Harbor Drive, West
Conshohocken, PA 19428. Copies of ISO
3758:2005(E), ‘‘Textiles—Care labelling
code using symbols,’’ may be obtained
from American National Standards
Institute, 11 West 42nd Street, 13th
Floor, New York, NY 10036. Both
ASTM D5489–07 and ISO 3758:2005(E)
may be inspected at the Federal Trade
Commission, room 130, 600
Pennsylvania Avenue NW., Washington,
DC or at the National Archives and
Records Administration (NARA). For
information on the availability of this
material at NARA, call 202–741–6030,
or go to https://www.archives.gov/
federal_register/
code_of_federal_regulations/
ibr_locations.html.
*
*
*
*
*
6. Amend Appendix A by revising
paragraph 7.a and c, and by adding a
new paragraph 9.a, to read as follows:
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Appendix A to Part 423—Glossary of
Standard Terms
*
*
*
*
*
7. Drycleaning; All Procedures:
a. ‘‘Dryclean’’—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% relative humidity, hot
tumble drying up to 160 degrees F (71
degrees C) and restoration by steam press or
steam-air finishing.
*
*
*
*
*
c. ‘‘Petroleum,’’ ‘‘Perchloroethylene,’’
‘‘Silicone,’’ ‘‘Glycol Ether,’’ ‘‘Carbon
Dioxide,’’ or ‘‘Aldehyde’’—employ solvent(s)
specified to dryclean the item.
*
*
*
*
*
9. Professional Wetcleaning:
a. ‘‘Wetclean’’—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.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2012–22746 Filed 9–19–12; 8:45 am]
BILLING CODE 6750–01–P
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 52
[EPA–R07–OAR–2012–0596; FRL 9731–2]
Approval and Promulgation of
Implementation Plans; State of
Missouri
Environmental Protection
Agency (EPA).
ACTION: Proposed rule.
AGENCY:
EPA proposes to approve the
State Implementation Plan (SIP)
revision submitted by the state of
Missouri on September 21, 2010. This
revision proposes to amend the ambient
air quality standards table to reflect
revised National Ambient Air Quality
Standards (NAAQS), update reference
methods associated with the revised
NAAQS, and update the breakpoint
values for the Air Quality Index. These
revisions would make Missouri’s rules
consistent with Federal regulations and
improve the clarity of the rules.
DATES: Comments on this proposed
action must be received in writing by
October 22, 2012.
ADDRESSES: Submit your comments,
identified by Docket ID No. EPA–R07–
SUMMARY:
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OAR–2012–0596, by mail to Amy
Bhesania, Environmental Protection
Agency, Air Planning and Development
Branch, 901 North 5th Street, Kansas
City, Kansas 66101. Comments may also
be submitted electronically or through
hand delivery/courier by following the
detailed instructions in the ADDRESSES
section of the direct final rule located in
the rules section of this Federal
Register.
FOR FURTHER INFORMATION CONTACT:
Amy Bhesania at (913) 551–7147, or by
email at bhesania.amy@epa.gov.
SUPPLEMENTARY INFORMATION: In the
final rules section of the Federal
Register, EPA is approving the state’s
SIP revision as a direct final rule
without prior proposal because the
Agency views this as a noncontroversial
revision amendment and anticipates no
relevant adverse comments to this
action. A detailed rationale for the
approval is set forth in the direct final
rule. If no relevant adverse comments
are received in response to this action,
no further activity is contemplated in
relation to this action. If EPA receives
relevant adverse comments, the direct
final rule will be withdrawn and all
public comments received will be
addressed in a subsequent final rule
based on this proposed action. EPA will
not institute a second comment period
on this action. Any parties interested in
commenting on this action should do so
at this time. Please note that if EPA
receives adverse comment on part of
this rule and if that part can be severed
from the remainder of the rule, EPA may
adopt as final those parts of the rule that
are not the subject of an adverse
comment. For additional information,
see the direct final rule which is located
in the rules section of this Federal
Register.
Dated: September 11, 2012.
Karl Brooks,
Regional Administrator, Region 7.
[FR Doc. 2012–23133 Filed 9–19–12; 8:45 am]
BILLING CODE 6560–50–P
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 52
[EPA–R09–OAR–2012–0550; FRL–9718–2]
Revisions to the California State
Implementation Plan, San Diego
County, Antelope Valley and Monterey
Bay Unified Air Pollution Agencies
Environmental Protection
Agency (EPA).
ACTION: Proposed rule.
AGENCY:
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Agencies
[Federal Register Volume 77, Number 183 (Thursday, September 20, 2012)]
[Proposed Rules]
[Pages 58338-58352]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-22746]
=======================================================================
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
16 CFR Part 423
Trade Regulation Rule on Care Labeling of Textile Wearing Apparel
and Certain Piece Goods
AGENCY: Federal Trade Commission.
ACTION: Notice of proposed rulemaking.
-----------------------------------------------------------------------
SUMMARY: Based on comments received in response to its Advance Notice
of Proposed Rulemaking (``ANPR''), the Federal Trade Commission
proposes to amend its trade regulation rule on Care Labeling of Textile
Wearing Apparel and Certain Piece Goods as Amended (``Rule'') to: Allow
garment manufacturers and marketers to include instructions for
professional wetcleaning on labels; permit the use of ASTM Standard
D5489-07, ``Standard Guide for Care Symbols for Care Instructions on
Textile Products,'' or ISO 3758:2005(E), ``Textiles--Care labelling
code using symbols,'' in lieu of terms; clarify what can constitute a
reasonable basis for care instructions; and update the definition of
``dryclean.'' In addition, the Commission seeks comment on several
other issues.
DATES: Written comments must be received on or before November 16,
2012. Parties interested in an opportunity to present views orally
should submit a request to do so as explained below, and such requests
must be received on or before November 16, 2012.
ADDRESSES: Interested parties may file a comment online or on paper by
following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Write ``Care Labeling Rule, 16
CFR Part 423, Project No. R511915'' on your comment, and file your
comment online at https://ftcpublic.commentworks.com/ftc/carelabelingnprm by following the instructions on the Web-based form.
If you prefer to file your comment on paper, mail or deliver your
comment to the following address: Federal Trade Commission, Office of
the Secretary, Room H-113 (Annex B), 600 Pennsylvania Avenue NW.,
Washington, DC 20580.
FOR FURTHER INFORMATION CONTACT: Robert M. Frisby, Attorney, Federal
Trade Commission, Division of Enforcement, Bureau of Consumer
Protection, 600 Pennsylvania Avenue NW., Washington, DC 20580, (202)
326-2098.
SUPPLEMENTARY INFORMATION: The Commission finds that using expedited
procedures in this rulemaking will serve the public interest.
Specifically, they support the Commission's goals of clarifying and
updating existing regulations without undue expenditure of resources,
while ensuring that the public has an opportunity to submit data,
views, and arguments on whether the Commission should amend the Rule.
Because written comments should adequately present the views of all
interested parties, the Commission is not scheduling a public hearing
or workshop. However, if any person would like to present views orally,
he or she should follow the procedures set forth in the DATES,
ADDRESSES, and SUPPLEMENTARY INFORMATION sections of this document.
Pursuant to 16 CFR 1.20, the Commission will use the procedures set
forth in this document, including: (1) Publishing this Notice of
Proposed
[[Page 58339]]
Rulemaking (``NPRM''); (2) soliciting written comments on the
Commission's proposals to amend the Rule; (3) holding an informal
hearing (such as a workshop) if requested by interested parties; (4)
obtaining a final recommendation from staff; and (5) announcing final
Commission action in a document published in the Federal Register. Any
motions or petitions in connection with this proceeding must be filed
with the Secretary of the Commission.
I. Introduction
The Rule makes it an unfair or deceptive act or practice for
manufacturers and importers of textile wearing apparel and certain
piece goods to sell these items without attaching labels stating the
care needed for the ordinary use of the product.\1\ The Rule also
requires that the manufacturer or importer possess, prior to sale, a
reasonable basis for care instructions \2\ and allows the use of
approved care symbols in lieu of words to disclose those
instructions.\3\
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\1\ 16 CFR 423.5 and 423.6(a) and (b).
\2\ 16 CFR 423.6(c).
\3\ The Rule provides that the symbol system developed by ASTM
International, formerly the American Society for Testing and
Materials, and designated as ASTM Standard D5489-96c ``Guide to Care
Symbols for Care Instructions on Consumer Textile Products'' may be
used on care labels or care instructions in lieu of terms so long as
the symbols fulfill the requirements of Part 423. 16 CFR 423.8(g).
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The Commission promulgated the Rule in 1971 and has amended it
three times since.\4\ In 1983, the Commission clarified its
requirements regarding the disclosure of washing and drycleaning
information.\5\ In 1997, the Commission adopted a conditional exemption
to allow the use of symbols in lieu of words.\6\ In 2000, the
Commission amended the Rule to clarify what constitutes a reasonable
basis for care instructions and to change the Rule's definitions of
``cold,'' ``warm,'' and ``hot'' water.\7\
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\4\ Federal Trade Commission: Care Labeling of Textile Wearing
Apparel: Promulgation of Trade Rule and Statement of Basis and
Purpose, 36 FR 23883 (Dec. 16, 1971).
\5\ Federal Trade Commission: Amendment to Trade Regulation Rule
Concerning Care Labeling of Textile Wearing Apparel and Certain
Piece Goods, 48 FR 22733 (May 20, 1983).
\6\ Federal Trade Commission: Concerning Trade Regulation Rule
on Care Labeling of Textile Wearing Apparel and Certain Piece Goods;
Conditional Exemption from Terminology Section of the Care Labeling
Rule, 62 FR 5724 (Feb. 6, 1997).
\7\ Federal Trade Commission: Trade Regulation Rule on Care
Labeling of Textile Wearing Apparel and Certain Piece Goods, Final
Amended Rule, 65 FR 47261 (Aug. 2, 2000).
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In 2000, the Commission rejected two proposed amendments. First,
the Commission did not require labels with instructions for home
washing on items that one can safely wash at home, because the evidence
was not sufficiently compelling to justify this change and the benefits
of the proposed change were highly uncertain.\8\ Second, the Commission
did not establish a definition for ``professional wetcleaning'' or
permit manufacturers to label a garment with a ``Professionally
Wetclean'' instruction.\9\ The Commission stated that it was premature
to allow such an instruction before the development of a suitable
definition and an appropriate test method \10\ and added that it would
consider such an instruction if a more specific definition and/or test
procedure were developed.\11\
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\8\ Id. at 47269.
\9\ The Commission proposed a definition of professional
wetcleaning, stating, in part, that it is ``a system of cleaning by
means of equipment consisting of a computer-controlled washer and
dryer, wet cleaning software, and biodegradable chemicals
specifically formulated to safely wet clean wool, silk, rayon, and
other natural and man-made fibers.'' Id. at 47271 n. 99.
\10\ Id. at 47272. The Commission explained that the definition
must either describe all important variables in the process, so that
manufacturers can determine that the process would not damage the
garment, or be coupled with a specific test procedure that
manufacturers can use to establish a reasonable basis for the
instruction. Id.
\11\ Id. at 47273.
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As part of its ongoing regulatory review program, the Commission
published an Advance Notice of Proposed Rulemaking (``ANPR'') in July
2011 seeking comment on the economic impact of, and the continuing need
for, the Rule; the benefits of the Rule to consumers; and the burdens
the Rule places on businesses.\12\ The ANPR also sought comment on
whether and how the Rule should address professional wetcleaning and
updated industry standards regarding the use of care symbols, as well
as whether the Commission should address non-English disclosures.
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\12\ Federal Trade Commission: Trade Regulation Rule on Care
Labeling of Textile Wearing Apparel and Certain Piece Goods, Advance
Notice of Proposed Rulemaking; request for comment, 76 FR 41148
(July 13, 2011).
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This NPRM summarizes the comments received by the Commission,
explains the Commission's decision to retain the Rule, proposes several
amendments to the Rule, and explains why the Commission has declined to
propose certain amendments.\13\ It also poses questions soliciting
additional comment and provides a regulatory analysis as well as
analyses under the Regulatory Flexibility Act and the Paperwork
Reduction Act. Finally, the NPRM sets forth the Commission's proposed
Rule language.
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\13\ The Commission publishes this NPRM pursuant to Section 18
of the Federal Trade Commission Act (``FTC Act''), 15 U.S.C. 57a et
seq., the provisions of Part 1, Subpart B of the Commission's Rules
of Practice, 16 CFR 1.7, and 5 U.S.C. 551 et seq. This authority
permits the Commission to promulgate, modify, and repeal trade
regulation rules that define with specificity acts or practices that
are unfair or deceptive in or affecting commerce within the meaning
of Section 5(a)(1) of the FTC Act, 15 U.S.C. 45(a)(1).
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II. Summary of Comments
The Commission received 120 comments in response to the ANPR.\14\
Most were filed by individuals. At least 70 of these individuals
identified themselves as owning or operating a cleaning business or
working in the drycleaning or wetcleaning industries. The Commission
also received comments from government agencies,\15\ industry standard-
setting organizations,\16\ environmental advocacy organizations,\17\
manufacturers and retailers,\18\ and trade associations representing
industries affected by the Rule.\19\
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\14\ The comments are posted at https://www.ftc.gov/os/comments/carelabelinganpr/index.shtm. The Commission has assigned each
comment a number appearing after the name of the commenter and the
date of submission. This notice cites comments using the last name
of the individual submitter or the name of the organization,
followed by the number assigned by the Commission.
\15\ Three California agencies filed comments: The Air Resources
Board (18), Department of Toxic Substances Control (123), and the
San Francisco Department of the Environment (89).
\16\ ASTM International (``ASTM'') (111) and GINETEX (83), which
is responsible for the care labeling system used in European
countries.
\17\ The Coalition for Clean Air (119), the Toxic Use Reduction
Institute (86), and the UCLA Sustainable Technology & Policy Program
(84).
\18\ Miele (108), Miele & Cie. KG (110), The Children's Place
(90), and The Clorox Company (122).
\19\ The Association of Home Appliance Manufacturers (``AHAM'')
(114), American Apparel & Footwear Association (113), Professional
Wet Cleaners Association (``PWA'') (73) and (102), Association of
Wedding Gown Specialists (``AWGS'') (22), National Cleaners
Association and Drycleaning & Laundry Institute (124), Professional
Leather Cleaners Association (``PLCA'') (109), International
Drycleaners Congress (``IDC'') (47), and Textile Industry Affairs
(112).
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All but two of the numerous comments that addressed retention of
the Rule favored it.\20\ Comments from
[[Page 58340]]
the apparel manufacturing and cleaning industries uniformly supported
the Rule. For example, the American Apparel & Footwear Association
(``AAFA'') stated that the labels benefit consumers, manufacturers, and
business in general, as they allow for the necessary flow of
information along the commodity chain. Similarly, the National Cleaners
Association (``NCA'') and the Drycleaning & Laundry Institute (``DLI'')
stated that the Rule provides valuable guidance on care to consumers
and industry. Textile Industry Affairs (``TIA'') noted that the Rule
has generated dramatic benefits to both consumers and manufacturers,
and that no apparel manufacturers that have complied with the Rule have
ever reported any negative consumer impact.
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\20\ GINETEX argued that the Rule should not be mandatory for
textile and apparel companies because a voluntary scheme would adapt
in a timely manner to technical and environmental developments as
well as innovations, while adjustments to mandatory rules are very
cumbersome to implement. It also argued that national rules not in
line with international standards can create a nontariff barrier to
trade, and that the ASTM standard creates an unnecessary obstacle to
international trade. A retailer argued that the time and effort
spent on labels required by the Rule does not really serve the
ultimate goal of educating consumers on laundering habits. Kambam
(4).
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While the comments indicate widespread support for the Rule, most
argued that the Commission should update or expand it in various ways.
In particular, many comments urged the Commission to address
professional wetcleaning by either requiring or allowing manufacturers
to disclose a wetcleaning instruction. Still others urged the
Commission to update the Rule's provisions allowing the use of care
symbols by incorporating the latest ASTM or International Organization
for Standardization (``ISO'') care symbol standards, allowing
manufacturers to follow either standard, or adopting new symbols for
professional cleaning. Several comments requested clarification of the
Rule's reasonable basis provisions or imposition of testing
requirements on manufacturers. Others advocated updating the definition
of ``dryclean'' and the Appendix to reflect the development of new
solvents and cleaning technologies and practices. Some comments urged
the Commission to require manufacturers to disclose all appropriate
methods of care on labels. Further, some comments urged the Commission
to amend the Rule to require the disclosure of additional information
such as fiber content or more detailed care instructions, to disallow
certain instructions currently permitted by the Rule, or to impose
additional obligations. Several comments addressed disclosures made in
multiple languages.
A. Professional Wetcleaning
Slightly more than half of the 120 comments received by the
Commission stated or implied that the Commission should permit, or
require, a professional wetcleaning instruction on garments that can be
wetcleaned. Wetcleaning is an alternative to drycleaning and involves
professionals cleaning products in water using special technology
(cleaning, rinsing, and spinning), detergents, and additives to
minimize adverse effects, followed by appropriate drying and
restorative finishing procedures. Of the comments addressing this
issue, only three expressed concerns.\21\ Comments favoring a
wetcleaning instruction made several arguments in support of their
position.
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\21\ AHAM urged the Commission to gather data on consumer
knowledge and the availability of wetcleaning before amending the
Rule to address it. AHAM (114). One commenter stated that
wetcleaning is not a viable alternative to drycleaning. Enderlin
(63). PLCA did not take a position on wetcleaning, but noted that
there are not enough cleaners trained in wetcleaning. PLCA (109).
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First, they touted the economic, health, and environmental benefits
of wetcleaning. For example, based on its analysis of scientific
literature on the health and environmental impacts of drycleaning
solvents, and its review of operational costs and compliance-related
impacts, the San Francisco Department of the Environment determined
that professional wetcleaning is the most environmentally-preferable
professional cleaning option.\22\ The Toxic Use Reduction Institute
stated that the benefits from professional wetcleaning include
decreased use of energy and water, significant air quality improvement
in the shop, and improved employee health and satisfaction.\23\ It
explained that over 80% of the U.S. professional garment cleaning
industry uses perchloroethylene (``perc''), and that studies have
identified ecological and human health hazards associated with its
use.\24\ It added that the National Institute for Occupational Safety
and Health has recommended handling perc as a human carcinogen, and the
Environmental Protection Agency has classified it as a probable human
carcinogen.\25\ Two comments noted that, starting in 2023, California
drycleaners can no longer use perc.\26\ A number of others favored
wetcleaning due to concerns about using toxic or unhealthy drycleaning
solvents.\27\ Others noted that wetcleaning can produce better results
than drycleaning in some circumstances.\28\
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\22\ San Francisco Department of the Environment (89). This
comment included a chart showing the results of its analysis.
\23\ Toxic Use Reduction Institute (86).
\24\ Id.
\25\ Id. The California Department of Toxic Substances Control
also explained the environmental problems caused by perc. (123).
\26\ Air Resources Board (18) and NCA and DLI (24).
\27\ E.g., Addison (81); Bohnet (80); Chung (70); and Xu (101).
\28\ One comment explained that the absence of wetcleaning
labels limits cleaners in offering the best process when it comes to
cleaning performance (e.g., water-soluble stains) or fabric-related
cleaning processes (e.g., polyurethane). Miele & Cie. KG (110). A
comment from a cleaner noted that some stains can be removed only
with water. Kaplan (57). Another comment stated that wetcleaning is
a necessary method for certain combinations of soil and fabric.
Riggs (53).
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Second, several comments explained that the number of cleaners
providing professional wetcleaning has increased and that consumers
increasingly use or prefer it. Two trade associations reported that
professional wetcleaning is now widespread in the industry.\29\ Another
stated that wetcleaning has been steadily growing in the United States
for over a decade.\30\ Yet another explained that professional
wetcleaning has come a long way in the last few years, and that many
traditionally drycleaned garments can be wetcleaned with good
results.\31\
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\29\ NCA and DLI (124).
\30\ Press on Cleaners (120).
\31\ Patterson (14).
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Several comments provided data on the number of cleaners providing
wetcleaning and the number of garments they clean. For example, one
comment stated that over 200 perc drycleaners in California have
switched to wetcleaning and successfully cleaned the full range of
garments they previously drycleaned.\32\ Two comments noted the success
of well over 120 professional wetcleaners in California who clean over
75 million garment pieces annually.\33\ Another explained that there
are hundreds of professional wetcleaners in the United States who use
only water and soap to clean all garments presented to them.\34\ This
comment also indicated that there are 80 Miele professional wetcleaners
in California, and that they process four million articles of clothing
a year.\35\
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\32\ Coalition for Clean Air (119).
\33\ Chang and PWA (73) and Sim (116). Another comment stated
that there are over 120 professional wetcleaners in California that
clean over 250,000 pieces of garments across the state daily. Press
on Cleaners (120).
\34\ Miele (108).
\35\ Id.
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Other comments cited the experience of individual cleaners that
increasingly replace drycleaning with wetcleaning. For example, one
comment from a cleaning business stated that wetcleaning is becoming
common, and that it wetcleans approximately 65%-80% of the clothes it
washes.\36\ Another commenter stated that it wetcleans 100% of garments
and that the instruction ``dryclean only'' has lost its meaning.\37\
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\36\ Peltier (43).
\37\ Behzadi (69).
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Several comments noted the development of industry standard care
[[Page 58341]]
symbols for wetcleaning. Indeed, ASTM and ISO have adopted consistent
care symbols for professional wetcleaning.\38\ ISO has also issued a
standard on testing garments to determine whether they can be
wetcleaned.\39\
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\38\ UCLA Sustainable Technology & Policy Program (84); Toxic
Use Reduction Institute (86); and Riggs (53). See ASTM D5489-07,
``Standard Guide for Care Symbols for Care Instructions on Textile
Products,'' and ISO 3758:2005(E), ``Textiles--Care labelling code
using symbols.''
\39\ UCLA Sustainable Technology & Policy Program (84); Toxic
Use Reduction Institute (86); and Riggs (53). ISO 3175-4:2003,
``Textiles--Professional care, drycleaning and wetcleaning of
fabrics and garments--Part 4: Procedure for testing performance when
cleaning and finishing using simulated wetcleaning.''
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Finally, several comments argued that the Rule's failure to address
wetcleaning places professional wetcleaners and equipment vendors at a
competitive disadvantage and discourages greater use of
wetcleaning.\40\
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\40\ E.g., Miele (108) and San Francisco Department of the
Environment (89). Another comment argued that labeling garments
``Dry Clean'' or ``Dry Clean Only'' even though they can be
successfully wetcleaned is unfair to professional wetcleaners. If a
consumer prefers to dryclean such garments, the wetcleaner faces the
prospect of losing the business or deceiving the consumer by
wetcleaning instead of drycleaning such garments. The dilemma of
either lying to the customer or potentially losing business makes
professional wetcleaning unappealing to many drycleaners. PWA (102).
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The comments urging the Commission to amend the Rule to address
wetcleaning differ on whether the Commission should require a
wetcleaning instruction or merely permit one. Moreover, many urge the
Commission to address wetcleaning without specifying exactly how. Of
those comments taking a position, the vast majority favored amending
the Rule to require a professional wetcleaning instruction if the
garment can be wetcleaned.\41\ Comments argued that requiring the
instruction would provide consumers and cleaners with more and better
options, and produce various benefits as more consumers choose
wetcleaning.\42\ One comment expressed concern that failing to require
an instruction might result in most manufacturers choosing not to
disclose that wetcleaning is a viable option, thereby deceiving
customers and treating wetcleaners unfairly.\43\
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\41\ E.g., Anonymous (106); Bromagen (91); Draper (100);
Eldridge (46); Evans (67); Fox (107); Hagearty (61); NCA and DLI
(124); Overmoe (66); Preece (54); Raggi (30); San Francisco
Department of the Environment (89); Tebbs (47); Toxic Use Reduction
Institute (86); UCLA Sustainable Technology & Policy Program (84).
\42\ E.g., NCA and DLI (124) and San Francisco Department of the
Environment (89).
\43\ UCLA Sustainable Technology & Policy Program (84).
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In addition, several commenters that do not appear to manufacture
or market apparel argued that the benefits of requiring a wetcleaning
instruction would exceed the added labeling and testing costs to
manufacturers. One comment explained that the vast majority of
manufacturers use experience and expertise to determine the care
label.\44\ It added that, because experience and expertise are free or
virtually free, the economic impact of requiring a wetclean label
likely is de minimus.\45\ It further explained that most manufacturers
test garments by sending them to established cleaners and use in-house
staff to evaluate results and that this method requires no capital
equipment cost and only a marginal cost.\46\ DLI and NCA advised that
they currently provide care label guidance to garment manufacturers and
that the average cost to provide appropriate and comprehensive washing,
drycleaning and wetcleaning instructions would be under $1,400.\47\
Another comment noted that testing is not that expensive and would not
lead to a large increase in the cost of an item and that any extra
costs would fall as universal testing reduces testing costs per
item.\48\
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\44\ Id.
\45\ Id.
\46\ Id.
\47\ NCA and DLI (124).
\48\ Riggs (53).
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A smaller number of comments indicated that they favored amending
the Rule to permit, but not require, a wetcleaning instruction. One
comment argued that allowing the instruction on labeling will reconfirm
to the public that this method is accepted and safe and encourage
manufacturers to produce more garments that do not need to be cleaned
in a solvent.\49\ Another supported permitting a wetcleaning
instruction by amending the symbol sets to include wetcleaning because
there appears to be expert consensus that clear testing protocols exist
to verify its safety, and stated that the consumer and environmental
benefits of wetcleaning are worthy of consideration.\50\
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\49\ Huie (71).
\50\ Textile Industry Affairs (112).
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Many comments simply urged the Commission to address wetcleaning
without specifying how.\51\ For example, one comment stated that the
Commission seriously should consider adding wetcleaning because of its
consumer and environmental benefits.\52\ It also explained that, with
the development of ISO standards, there now appear to be consensus
testing protocols to verify a safe care process.\53\
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\51\ E.g., Air Resources Board (18); Bosshard (13); Chang (88);
Santana (12); and Schoeplein (27).
\52\ The Clorox Company (122).
\53\ Id.
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B. Use of Care Symbols
With a few exceptions, the comments addressing the use of symbols
to provide care instructions favored their continued use.\54\ One
comment stated that the current FTC-approved symbols do a good job of
covering most of the home and professional care needs in the United
States.\55\ It therefore did not advocate modifying any of the symbols,
as consumers are just now becoming familiar with them.\56\ Several
comments, however, advocated modifying the Rule to refer to the most
recent version of the ``Standard Guide for Care Symbols for Care
Instructions on Textile Products,'' ASTM D5489, instead of the older
version of the ASTM standard currently referenced.\57\ One comment
urged the Commission to exclude the standard's date; it explained that
ASTM D5489-07 is the most recent standard and that, by not designating
the year, the Commission can ensure that the most recent standard is
used.\58\ It added that D 5489-07 is an international standard as
defined by the WTO TBT Agreement, and that, as a signatory to this
agreement, the United States is pledged to use international standards
as the basis for technical regulations when possible.\59\ Others urged
the Commission to address the development of ASTM symbols without
indicating how it should do so.\60\ Another explained that it would be
very helpful if the care instructions on foreign and domestic labels
were in agreement or, at a minimum, contained ASTM symbols.\61\
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\54\ Two commenters stated that they do not like the use of
symbols. Charles (3) and Vlasits (6). Other comments urged the
Commission to require care symbols on all textile products. Fox
(107) and Old Town Dry Cleaners (56).
\55\ Textile Industry Affairs (112).
\56\ Id.
\57\ ASTM (111); Evans (67); and The Children's Place (90).
Another comment argued that the Rule should keep pace with
developments in the ASTM system, and that the biggest challenge with
symbols is educating the consumer. NCA and DLI (124). It advised
that care symbols are not prevalent in the United States. Id.
\58\ ASTM (111).
\59\ Id.
\60\ Preece (54) and Yazdani (78).
\61\ Professional Leather Cleaners Association (109).
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A number of comments expressed support for harmonizing the ASTM
symbols allowed under the Rule with those used internationally.\62\ One
comment favoring harmonization concluded that the Rule prevents a
global ISO Standard and that ISO symbols should supplant ASTM
[[Page 58342]]
symbols.\63\ It explained that the ASTM and the ISO symbols are similar
but not the same and that ISO symbols are used in every country except
South Korea, Japan, and the United States (and that Japan is working on
harmonizing ISO and the JIC standards that apply in Japan).\64\ Another
favored one set of worldwide symbols and explained that the ISO
recommends a complete set of care symbols, including washing,
bleaching, ironing, drying, and professional care.\65\ It added that
these symbols are consistent with those developed by ASTM.\66\ Some
comments argued that harmonizing symbols would also address problems
stemming from label disclosures in multiple languages.\67\ One of these
comments favored harmonization but argued that, as an alternative, the
Rule should allow manufacturers to use either ASTM or ISO symbols in
the United States, to relieve some of the burden and increase the
accessibility of global trade.\68\ It stated that differences among the
symbol systems cause confusion and limit the opportunities for trade
growth.\69\ Another comment proposed that the Rule provide for or
recognize agreements between the United States and other countries to
accept international and national care label symbol systems currently
in use in the global marketplace.\70\
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\62\ AHAM (114); American Apparel & Footwear Association (113);
Draper (100); GINETEX (83); Johnson (50); O'Connor (20); Textile
Industry Affairs (112); and The Clorox Company (122).
\63\ GINETEX (83).
\64\ Id.
\65\ Riggs (53).
\66\ Id.
\67\ American Apparel & Footwear Association (113) and The
Children's Place (90).
\68\ American Apparel & Footwear Association (113).
\69\ Id.
\70\ The Children's Place (90).
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Still others favored acceptance of ISO or internationally-accepted
symbols without addressing the ASTM symbols.\71\ Three comments urged
the Commission to adopt or accept the ISO standard.\72\ One supported
adding to the symbols in cases where there are clear testing protocols
to verify the safety of a care process.\73\ It explained that, in the
case of wetcleaning, there appears to be expert consensus that a new
test does just that.\74\
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\71\ Cote (58); Horrigan (17); Thorsteinson (45); and Yazdani
(78).
\72\ UCLA Sustainable Technology & Policy Program (84); White
(15); and GINETEX (83). As noted above, GINETEX argued that the ISO
symbols should supplant the ASTM symbols.
\73\ Textile Industry Affairs (112).
\74\ Id.
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GreenEarth Cleaning (``GreenEarth'') advocated a different approach
to disclosing professional cleaning instructions. It argued that the
ASTM and ISO professional cleaning symbols are inadequate because they
are based on particular solvents rather than solvent
characteristics.\75\ It explained that the increasing number of
solvents and advances in technology call for an approach addressing
solvent aggressiveness (cleaning method) and mechanical action (cycle);
it proposed that a Kauri-Butanol Value (``KBV'') of 35 or less be
designated as ``gentle'' and that a ``fragile'' or ``very fragile''
instruction be provided for items needing minimized mechanical
action.\76\ It stated that the KBV is widely recognized in the textile
care industry as having the greatest influence on the processing of
textiles.\77\ This comment further argued that there is a direct
correlation between propensity for garment damage and a higher solvent
KBV.\78\ GreenEarth proposed specific cleaning method and cycle symbols
to replace the current ASTM and ISO symbols and urged the Commission to
make every effort to implement simple, consistent international symbols
that can be universally interpreted to ensure the best care for
garments.\79\ No other comment favored this proposal.
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\75\ GreenEarth Cleaning (98) at 2.
\76\ Id. at 2-3.
\77\ Id. at 2.
\78\ Id. at 4.
\79\ Id. at 2-3.
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In addition to proposing new symbols, GreenEarth advocated parallel
changes to the ``overarching nomenclature and the guiding principle''
behind the Rule, to improve the reliability and understandability of
care labels.\80\ Specifically, it proposed replacing the instructions
``dry clean,'' ``do not dry clean,'' ``wetclean,'' and ``do not
wetclean'' with simplified categories of ``cleaning method'' and
``cycle.'' It also proposed that ``cleaning method'' would encompass
all types of professional cleaning, including wetcleaning, and
``cycle'' would address the level of mechanical action.\81\ As with its
proposed symbols, GreenEarth would classify cleaning methods based on
solvent aggressiveness rather than solvent type.\82\ For the ``cycle''
category, GreenEarth would replace ``mild'' and ``very mild'' with
``fragile'' and ``very fragile.'' \83\
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\80\ Id. at 2.
\81\ Id.
\82\ Id.
\83\ Id. at 3.
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Two comments addressed the presentation of symbols. One argued that
the current system works well, but that some uniformity regarding
location, size, composition, and font size would greatly help the
industry.\84\ Another comment proposed attaching the international care
label symbols to the garments in a small, removable brochure or paper,
or in an online link address for such information.\85\
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\84\ Raggi (30).
\85\ Santana (12).
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C. The Rule's Reasonable Basis Provisions
Four comments argued that the Commission should clarify or
strengthen the Rule's provision requiring manufacturers to have a
reasonable basis for care instructions. One urged the Commission to
strengthen the reasonable basis requirements and hold manufacturers
accountable to individual consumers for inappropriate care
instructions.\86\ Two argued that the Commission should clarify the
reasonable basis provisions because some non-compliant parties appear
to be misinformed or to misunderstand the requirement.\87\ They
suggested that the Commission request fresh data from manufacturers
regarding their reasonable basis for their current care
instructions.\88\ One of them argued that, given standardized testing
(e.g., ASTM methodology) for colorfastness and garment integrity (e.g.,
tensile strength), the Commission should require actual data to support
care instructions.\89\ Another comment favored requiring manufacturers
to test products with all available processes, including
wetcleaning.\90\
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\86\ NCA and DLI (124).
\87\ Textile Industry Affairs (112) and The Clorox Company
(122). They stated that disclosing an instruction based on
``unreasonable'' and ``possible'' fabric impact is not an acceptable
instruction or warning.
\88\ Id.
\89\ The Clorox Company (122).
\90\ Behzadi (69).
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D. Rule Definitions and Appendix
Several comments urged the Commission to update the Rule's
definition of ``dryclean,'' as well as the Appendix. One comment urged
the Commission to adopt a broader definition of ``dryclean.'' \91\ It
explained that, 25 years ago, only two solvents were widely used--perc
and petroleum.\92\ It added that now there are many solvents, including
high flash hydrocarbons, silicones, glycol ethers, carbon dioxide,
aldehydes, and wetcleaning.\93\ It also reported that: fluorocarbon
solvent, one of the solvents listed in the definition, is no longer
used; new hydrocarbon drying parameters are different from those of
early petroleum solvents; and not all solvents are organically
based.\94\
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\91\ NCA and DLI (124).
\92\ Id.
\93\ Id.
\94\ Id.
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[[Page 58343]]
Four comments from cleaners similarly argued that the current
definition of drycleaning is very limiting.\95\ The first reported that
it adopted a new solvent, but has concerns because labels do not
provide the information needed.\96\ The second reported that it
hesitated to adopt a new solvent because it is not recognized by the
Rule.\97\ The third reported that it wanted to use a new solvent, which
involves purchasing a costly new machine, but hesitated because the
solvent or process is not recognized by the Rule.\98\ The comment
argued that the Rule should not curtail technological advancement.\99\
The fourth urged the Commission to expand Rule to address other
solvents, such as SolvonK4 by Kreussler.\100\
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\95\ Bromagen (91); Hagearty (61); Preece (54); and Yazdani
(78).
\96\ Bromagen (91).
\97\ Hagearty (61).
\98\ Preece (54).
\99\ Id.
\100\ Brunette (115).
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Two comments urged the Commission to revise Appendix A. One advised
that Appendix A of the Rule diverges from ASTM D5489, although it did
not identify how or explain why amendments are warranted.\101\ Another
urged the Commission to suggest that all leather goods have a more
specific care label, such as ``Leather Clean and Refinish by
Professional Leather Cleaner Only,'' and to expand the definition in
Appendix A.8 to read ``Leather Clean and Refinish by Professional
Leather Cleaner Only.'' \102\
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\101\ ASTM (111).
\102\ Professional Leather Cleaners Association (109).
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E. Instruction on All Appropriate Methods of Care
Several comments from the cleaning industry urged the Commission to
amend the Rule to require manufacturers to include instructions on all
appropriate methods of care.\103\ As one comment explained, this would
empower consumers to decide whether they want to care for the garment
at home or use a professional cleaner.\104\ It added that, by listing
all methods of care, the label would eliminate guesswork regarding
whether a care method is not listed because it will cause damage.\105\
Others explained that such a label would enable the cleaner to select
the best cleaning method based on the type of soils on the garment or
the customer's requests.\106\
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\103\ E.g., Bromagen (91); Draper (100); Edwards (97); Evans
(67); Hagearty (61); Kudler (72); Maisel (34); McKay (104); NCA and
DLI (124); Overmoe (66); Preece (54); Tebbs (47); Widmar (48); and
Yazdani (78).
\104\ NCA and DLI (124).
\105\ Id.
\106\ Overmoe (66) and Preece (54).
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F. Additional Issues
Some comments proposed amending the Rule to require additional
disclosures, disallow certain care instructions currently allowed by
the Rule, address the format or composition of labels, expand the scope
of the Rule, or impose additional requirements. Additionally, several
comments addressed the use of multiple languages on care labels.
Five comments urged the Commission to require disclosure of fiber,
fabric, or component content.\107\ One of them also advocated requiring
disclosure of the content of all fabrics, linings, and trims, including
applied water repellant coatings or sizing that may be removed during
processing.\108\
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\107\ Chambers (92); Hiebert (64); Professional Leather Cleaners
Association (109); Santana (12); and Wilson (32).
\108\ Hiebert (64).
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Other comments urged the Commission to require more detailed care
instructions or disclosure of additional information related to
care.\109\ For example, one comment urged the Commission to address the
instruction ``exclusive of trim'' where the trim is not removable.\110\
Another urged the Commission to require disclosure of the type of dye
method used to lessen the likelihood of damaged garments.\111\ Another
stated that the Rule should require more details, including how and
which drycleaning fluid can, or cannot, be used for the garment.\112\
Yet another argued that any care that the manufacturer knows could harm
the garment should be specifically stated as a ``Do Not'' warning.\113\
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\109\ One comment advocated guidelines for designating specific
solvent characteristics, such as KB value, polarity, and water
solubility, on pre-existing labels. Cote (58).
\110\ Chelsky (38).
\111\ King (19).
\112\ Momin (51).
\113\ NCA and DLI (124).
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One comment proposed that the Rule provide that the care
instruction indicate the maximum treatment that can be applied to the
item.\114\ The comment explained that the Rule allows a manufacturer to
provide an instruction, such as ``dry flat'' even if a more severe
method, such as ``tumble dry,'' will not harm the garment. Under the
ISO standard the care instruction provided is the most severe method
that can be used without damaging the article.\115\ Another comment
argued that the Rule should require that jobbers who add trimming,
ornaments or feathers, etc., to an item must change or add additional
labels and add the jobbers' names and contact info.\116\ Another
comment argued, among other things, that labels should disclose a
serial number and an address for a Web site providing several
additional categories of information and countries of manufacture.\117\
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\114\ GINETEX (83).
\115\ Id.
\116\ Zeidel (29).
\117\ Winn (40).
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Moreover, one comment argued that care tags could be replaced or
made much smaller and simpler with the use of a unique identifier for
every garment, such as a barcode, QR code, or an RFID chip.\118\ It
explained that the code would include a manufacturer ID, product ID,
and serial number, and that the manufacturer would input this
information into a centralized database that could be accessed by
consumers, retailers, drycleaners, etc.\119\
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\118\ Levy (99).
\119\ Id.
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Another comment addressed disclosure of an item's point of origin.
It urged the Commission to require disclosure of the state for items
allowed a ``made in the United States'' label.\120\
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\120\ Fisher (24).
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Other comments argued that the Commission should disallow certain
care instructions that they view as providing little, if any, benefit
to consumers, or to otherwise limit care instructions. One comment
argued that all garments should be serviceable, and opposed ``Do not
wash. Do not dryclean'' labels.\121\ One stated that care methods
should be dryclean only, clean by any method, and cannot be
cleaned.\122\ Another stated that too many labels state ``remove trim
before cleaning'' where removing the trim results in taking apart the
garment.\123\ One stated that labels that specify ``Spot Clean'' should
be disallowed.\124\
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\121\ Brunette (115).
\122\ Enderlin (63).
\123\ O'Connor (20).
\124\ Shaw (33).
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Two comments addressed the format or composition of the labels
required by the Rule. One argued that labels should be a standard size,
printed on white material only, using stable black ink, non-soluble in
water and drycleaning solvents.\125\ The other argued that care labels
need to be securely attached to the garment, and not by a few stitches,
to avoid causing holes in the garments after a few cleanings.\126\
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\125\ Horrigan (17).
\126\ Maknojia (87).
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Two comments addressed the scope of the Rule. One argued that the
Rule
[[Page 58344]]
should continue to exempt rental garments, such as corporate uniforms,
because many of them require professional care for health reasons.\127\
The other proposed requiring care labels for household items such as
comforters, drapes, etc.\128\
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\127\ American Apparel & Footwear Association (113).
\128\ Kudler (72).
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Four comments favored imposing additional obligations under the
Rule other than labeling. One urged the establishment of an electronic
database for reporting insufficient or incorrect labeling so consumers
can research problems.\129\ Another urged the Commission to add
provisions holding manufacturers accountable to individual consumers
for inappropriate care instructions.\130\ A third advocated providing
that a consumer can return a failed garment to the place of purchase
for a refund, that the place of purchase must keep a record of the
garment, and that the point of sale vendor will be able to get refunds
from its vendor.\131\ A fourth urged the creation of guidelines for
specific solvent characteristics, such as KB value, polarity, and water
solubility, to allow for easy testing on the manufacturing side and to
encourage eco-friendly alternatives on the care side.\132\ It added
that solvent developers could provide MSDS sheets (material safety data
sheets) and publicly-available materials for ease of use by
manufacturers, dry-cleaners and consumers.\133\
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\129\ Bosshard (13).
\130\ NCA and DLI (124).
\131\ Sabo (23).
\132\ White (15).
\133\ Id.
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Finally, several comments argued that the Rule should not require
multiple language disclosures.\134\ One stated that labels should be
only in English, and another stated that English is the only language
needed on labels.\135\ One added that English is a must but other
languages can be an option.\136\ Another argued that labels for clothes
to be purchased in the United States should be in English, and for
clothes available for purchase in multiple countries, the label should
be in multiple languages.\137\ Yet another stated that labels should be
in English and that symbols should eliminate the need for additional
languages.\138\ Another argued that the label should be in English with
internationally-accepted symbols and that those cleaners who do not
speak or read English well should contact their own association for a
translation of the international symbols.\139\ None of the comments
proposed amending the Rule to address the format for presenting care
instructions in more than one language, other than to note that using
symbols would address problems stemming from disclosures in multiple
languages.\140\
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\134\ One commenter, a consumer who does not indicate any
affiliation with an organization, stated that she does not like
having so many language translations. Charles (3).
\135\ Branfuhr (42) and Childers (49).
\136\ Maknojia (87).
\137\ Vlasits (6).
\138\ Hurley (60).
\139\ Thorsteinson (45).
\140\ American Apparel & Footwear Association (113) and Hurley
(60).
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III. The Commission Retains the Rule
The record shows wide support for the Rule from all the major
industries affected by its provisions as well as from consumers. Among
other things, comments supporting the Rule explained that it benefits
consumers, manufacturers, and businesses in general and provides
valuable guidance on care to consumers and the fabricare industry.
Two comments opposing the Rule, one filed by GINETEX and the other
by a retailer, failed to provide any tangible evidence to support their
assertions.\141\ There is no evidence in the record showing that a
voluntary scheme would work better than the Rule, that the ASTM care
symbols permitted by the Rule create an unnecessary obstacle to
international trade, or that the time and effort spent on the labels
required by the Rule do not serve the goal of educating consumers about
how to care for their garments.
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\141\ See footnote 20 for more details about these comments.
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In light of the many stakeholder comments expressing support for
the Rule, the Commission concludes that a continuing need exists for
the Rule and that the Rule imposes reasonable costs on the industry.
The Commission therefore concludes that the weight of the record
evidence clearly supports retention of the Rule.
IV. Proposed Amendments
Many of the comments supporting the Rule also advocated various
amendments. Accordingly, based on the comments and the evidence
discussed herein, the Commission proposes to amend the Rule in the
following four ways.\142\ First, the Commission proposes to permit
manufacturers and importers to provide a care instruction for
professional wetcleaning on labels if the garment can be professionally
wetcleaned. Second, the Commission proposes to permit manufacturers and
importers to use the symbol system set forth in either ASTM Standard
D5489-07, ``Standard Guide for Care Symbols for Care Instructions on
Textile Products,'' or ISO 3758:2005(E), ``Textiles C Care labelling
code using symbols.'' Third, the Commission proposes to clarify what
constitutes a reasonable basis for care instructions. Finally, the
Commission proposes to update the definition of ``dryclean'' to reflect
current practices and technology.\143\
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\142\ The Commission can issue a NPRM under the FTC Act if it
has ``reason to believe that the unfair or deceptive acts or
practices which are the subject of the proposed rulemaking are
prevalent.'' 15 U.S.C. 57a(b)(3). The Commission can find ``unfair
or deceptive acts or practices are prevalent'' where: ``(A) it has
issued cease and desist orders regarding such acts or practices, or
(B) any other information available to the Commission indicates a
widespread pattern of unfair or deceptive acts or practices.'' Id.
at 57a(b)(3)(A)-(B). The Commission has ``wide latitude'' in
fashioning a remedy and need only show a ``reasonable relationship''
between the unfair or deceptive act or practice and the remedy.
American Fin. Servs. Ass'n v. FTC, 767 F.2d 957, 988 (DC Cir. 1985)
(quoting Jacob Siegel Co. v. FTC, 327 U.S. 608, 612-13 (1946)).
\143\ The Commission also proposes to delete the words ``As
Amended'' from the Rule's title. These words do not serve any
purpose, and none of the other titles of Commission rules that have
been amended include these words.
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A. Professional Wetcleaning
As noted above, in 2000, the Commission declined to amend the Rule
to permit a ``Professionally Wetclean'' instruction on labels. The
Commission stated that it would consider permitting such an instruction
if a more specific definition and/or test procedure were developed that
provided manufacturers with a reasonable basis for a wetcleaning
instruction.\144\ The Commission explained at the time that it was
premature to permit such an instruction due to the absence of a
suitable definition and appropriate test method.
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\144\ Federal Trade Commission: Trade Regulation Rule on Care
Labeling of Textile Wearing Apparel and Certain Piece Goods, Final
Amended Rule, 65 FR 47261, 47273 (Aug. 2, 2000).
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The record now shows that these conditions have been met. ISO has
developed ISO 3175-4:2003, ``Textiles--Professional care, drycleaning
and wetcleaning of fabrics and garments--Part 4: Procedure for testing
performance when cleaning and finishing using simulated wetcleaning.''
This standard includes a definition of wetcleaning and test procedures
for determining whether apparel can be wetcleaned professionally.
Several comments favoring a wetcleaning instruction cited this standard
approvingly.\145\ None of the comments
[[Page 58345]]
argued that the ISO standard is inadequate.\146\
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\145\ UCLA Sustainable Technology & Policy Program (84); Toxic
Use Reduction Institute (86); and Riggs (53).
\146\ The standard ISO 3758:2005(E), ``Textiles--Care labelling
code using symbols'' also defines wetcleaning.
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As described in Section II.A, the record shows widespread support
for amending the Rule to include professional wetcleaning. Many
comments explained the economic, environmental, and health benefits of
wetcleaning. They also noted the increasing industry acceptance and use
of wetcleaning, the inclusion of wetcleaning symbols in both the ASTM
and ISO care symbol systems, and the risk that failing to allow an
instruction could place wetcleaners at a disadvantage, thereby
discouraging its use despite its advantages. The increasing industry
acceptance and use of wetcleaning and the inclusion of wetcleaning
symbols in both the ASTM and ISO systems establish the prevalence of
wetcleaning. Only three comments expressed reservations, and none of
them provided evidence that amending the Rule would harm consumers or
that the cost of doing so would exceed the benefits.
While the record supports permitting a professional wetcleaning
instruction, it does not warrant requiring such an instruction. 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. 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.\147\ Thus, the Commission declines to propose amending the
Rule to require a wetcleaning instruction. If consumers prefer
wetcleaning to drycleaning and make their purchase decisions
accordingly, manufacturers and importers will have an incentive to
provide a wetcleaning instruction either in addition to, or in lieu of,
a drycleaning instruction. Furthermore, by treating drycleaning and
wetcleaning in a similar fashion--as care procedures that manufacturers
and importers can disclose to comply with the Rule--the Rule as
proposed would help level the playing field for the drycleaning and
wetcleaning industries.
---------------------------------------------------------------------------
\147\ Also, the comments stating that the benefits of requiring
a wetcleaning instruction would exceed the added testing and
labeling costs were not submitted by entities that would purportedly
incur the added costs that would result if the Commission amends the
Rule to require a wetcleaning instruction. See UCLA Sustainable
Technology & Policy Program (84); NCA and DLI (124); and Riggs (53).
---------------------------------------------------------------------------
Based on this record, the Commission concludes that permitting a
professional wetcleaning instruction would provide consumers with
useful information regarding the care of the apparel they purchase.
Therefore, the Commission proposes adding a definition of ``wetclean''
based on the definition of ``professional wet cleaning'' set forth in
ISO 3758:2005(E). Specifically, proposed section 423.1(h) would state
that ``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.
This definition closely tracks the definition in a widely-used
international standard cited approvingly in comments. Thus, the
Commission concludes that the definition would provide manufacturers
and importers with sufficient guidance to distinguish wetcleaning from
other cleaning processes, thereby helping them to determine whether
they have enough evidence to provide a wetcleaning instruction or a
warning not to wetclean, if they choose to do so. The Commission also
proposes to amend Appendix A by including this definition as set forth
in the proposed amendment in the last section of this Notice of
Proposed Rulemaking.
In addition to defining ``wetclean,'' the Commission proposes
amending section 423.6(b) to add a wetcleaning subsection, as set forth
in the proposed amendment in the last section of this Notice of
Proposed Rulemaking. To harmonize with international standards, the
proposed subsection states that any wetcleaning instruction must
indicate whether to use a normal, mild or very mild process and
disclose fiber content if needed to select the appropriate wetcleaning
process. These amendments bring the Rule in line with both the ASTM and
ISO symbol systems, and ISO 3758:2005(E)'s fiber disclosure.
This proposed amendment would not impose any new obligations on
manufacturers or importers. They could choose to provide a wetcleaning
instruction if they have a reasonable basis for it and wish to do so.
They also could provide a different instruction, such as a drycleaning
or washing instruction.
The proposal, however, would require manufacturers and importers
currently labeling items with a ``dryclean only'' instruction either to
substantiate that wetcleaning is an inappropriate method of care or to
revise their labels. Revised labels stating ``dryclean'' would comply
with the Rule. Manufacturers and importers who wished to convey to
consumers that home laundering would damage the garment could, if they
wished, label the garment as ``dryclean/do not home wash,'' but would
comply with the Rule if they disclosed just the cleaning method (in
this example, drycleaning) known to produce safe results. Manufacturers
and importers could continue to use the ``dryclean only'' label only if
they could substantiate that both home laundering and professional
wetcleaning were inappropriate methods for cleaning the garment.
B. Use of Care Symbols
The Rule permits manufacturers and importers to use care symbols
set forth in ASTM Standard 5489-96c, ``Guide to Care Symbols for Care
Instructions on Consumer Textile Products.'' Since the Commission last
amended the Rule in 2000, ASTM has updated this standard to ASTM D5489-
07, ``Standard Guide for Care Symbols for Care Instructions on Textile
Products.'' The Rule currently does not permit the use of this updated,
or any other non-ASTM symbol system in lieu of terms.
Nearly all of the comments addressing the issue favored allowing
the use of symbols in lieu of terms. Some favored amending the Rule to
reference ASTM D5489-07, the most recent version of the ASTM standard,
or ASTM D5489 without designating the year so that the Rule would
automatically reference the latest version of the standard. Still
others favored allowing the use of the symbol system developed by ISO.
Several urged the Commission to amend the Rule to harmonize the ASTM
symbols permitted by the Rule with those set forth in the ISO standard
or to allow manufacturers and importers to use either symbol system.
None of the comments expressed a preference for the ASTM symbol system
currently referenced in the Rule. Nor did any of the comments oppose
the harmonization of the ASTM and ISO symbols.
The record supports: (1) Continuing to allow the use of ASTM care
symbols in lieu of terms, (2) updating the Rule to reference the 2007
version of the ASTM standard, and (3) permitting the use of the ASTM
and ISO symbols. The Commission concludes that permitting the use of
the symbol system in either the updated ASTM standard, ASTM D5489-07,
or ISO 3758:2005(E) would ensure that manufacturers and importers that
choose to use symbols in lieu of terms will use them consistent
[[Page 58346]]
with the latest industry standards.\148\ It also would provide them
with the flexibility to use either symbol system, resulting in less
cluttered labels if manufacturers opt to use one set of symbols.\149\
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\148\ Manufacturers would need to purchase and follow only one
of the two standards to disclose care instructions using symbols,
thereby reducing compliance costs. E.g., manufacturers already using
ISO symbols in lieu of written terms would not need to incur the
expense of adding ASTM symbols or written terms to their labels so
that they can market their garments in the United States.
\149\ Both the ASTM and ISO standards are subject to copyrights
and can be purchased from the organizations that issued them. In
addition, the ISO symbols are protected by trademarks and their use
is dependent on a contract with GINETEX. See www.ginetex.net.
Consumers can find the symbols and explanations of their meaning on
the Internet, including the ISO symbols on the GINETEX Web site and
the currently approved ASTM symbols on the FTC Web site at https://www.ftc.gov/opa/1996/12/label.pdf. Consumers can find the
professional care symbols in the 2007 version of the ASTM standard
on page three of the GreenEarth comment (mistakenly described as the
``current FTC Symbol Chart'') located at https://www.ftc.gov/os/comments/carelabelinganpr/00098-80529.pdf.
---------------------------------------------------------------------------
Because the ASTM and ISO symbol systems are not identical,
consumers may need to know which system appears on the label so that
they can ascertain or confirm the meaning of a particular symbol.
Furthermore, permitting the use of two symbol systems could increase
the risk of consumer confusion. Therefore, the Commission proposes
requiring that manufacturers or importers opting to disclose care
instructions using the ISO symbols disclose that they are using ISO
symbols. The Commission does not propose requiring a similar disclosure
on labels using the ASTM symbols because the Rule already permits the
use of ASTM symbols without requiring any such disclosure. For example,
consumers might have a greater familiarity with the ASTM symbols than
with the ISO symbols because the Rule started permitting them in 1997.
On the other hand, that may not be the case. The Commission seeks
comment on this issue, including on the extent to which care labels
currently include ASTM and ISO symbols.
Permitting the use of either symbol system should not confuse or
deceive consumers because the symbol systems are nearly identical.
Although the ASTM system includes more symbols than the ISO
system,\150\ the two systems use virtually identical symbols for
washing, bleaching, and professional care such as drycleaning and
wetcleaning. Manufacturers and importers that prefer to use the ISO
system can supplement the ISO symbols with written instructions as
appropriate. Both symbol systems lack symbols for certain instructions
and acknowledge the need to supplement their symbols with written
instructions as appropriate.\151\
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\150\ E.g., the ISO system has fewer symbols for drying. ISO has
normal and low temperature symbols while ASTM has symbols for any
heat, high, medium, low, and no heat/air.
\151\ E.g., both the ASTM and ISO systems list written
instructions, including ``wash separately'' and ``remove promptly.''
---------------------------------------------------------------------------
Although the two systems differ slightly with respect to drying and
ironing symbols, the differences do not appear substantial. 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. If a manufacturer or importer
concludes that one of the systems has symbols that more effectively
convey the proper care instructions, it can choose to use that
system.\152\
---------------------------------------------------------------------------
\152\ E.g., if a manufacturer or importer determines that it
needs to use one of the ASTM drying symbols not available in the ISO
system to convey drying instructions properly, it can opt to use the
ASTM symbol system. If both systems have a drying symbol that
suffices, it can opt to use either system.
---------------------------------------------------------------------------
The Commission notes 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, means 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.\153\
---------------------------------------------------------------------------
\153\ As noted in footnote 149, consumers can find the symbols
and explanations of their meaning on the Internet.
---------------------------------------------------------------------------
However, even if consumers understand the symbol at the time of
purchase, confusion could result with respect to: (1) Products labeled
before, but sold after, the symbol system change; and (2) situations
where the consumer does not remember whether he or she purchased the
product before or after the symbol change. The change in the symbol's
meaning could also cause confusion if drycleaners do not know whether
the garment was labeled before the change. Of course, notwithstanding
the change in symbol meaning, consumers and drycleaners can avoid any
risk of using an inappropriate solvent by using petroleum rather than
perc to dryclean the product (under both the old and new meaning, the
symbol indicates that petroleum can be used). The Commission seeks
comment on these issues.
As explained above, a comment from GreenEarth urged the Commission
to replace the ASTM and ISO symbols with new symbols based on a
solvent's aggressiveness rather than type.\154\ GreenEarth did not
submit any evidence on consumer perception of its proposed symbols or
establish that any resulting benefits would exceed the cost to
business.\155\ Moreover, none of the other comments proposed anything
similar to GreenEarth's proposal. The record, therefore, does not
indicate that GreenEarth's approach to care instructions would be
superior to the current one. Moreover, it would represent a significant
departure from the symbol system currently permitted by the Rule as
well as from the updated ASTM and ISO symbol systems widely used by
apparel manufacturers and importers and favored by nearly all of the
other comments that addressed the use of symbols. Therefore, the
Commission declines to adopt GreenEarth's proposal.\156\
---------------------------------------------------------------------------
\154\ GreenEarth's arguments and proposal are summarized in
Section II.C.
\155\ GreenEarth argued that its proposal would encourage the
substitution of less aggressive solvents for more aggressive ones in
the cleaning process, thereby measurably reducing claims for damaged
garments. However, it did not address whether its proposal would
increase the cost of providing care instructions or submit any
evidence showing that its proposal would actually reduce the use of
more aggressive solvents.
\156\ GreenEarth may wish to submit its proposal to ASTM and ISO
for their consideration if it has not already done so.
---------------------------------------------------------------------------
Finally, Section 423.8(g) states that, for the 18-month period
beginning on July 1, 1997, symbols may be used in lieu of terms only if
an explanation of the symbols is attached to, or provided with, the
product. This provision has expired; therefore, the Commission proposes
to remove it from the Rule.
To implement the revisions described above, the Commission proposes
amending Section 423.8(g) as set forth in the proposed amendment in the
last section of this Notice of Proposed Rulemaking.
One of the comments urged the Commission to update the Rule by
referring to the ASTM standard without identifying the year or version
of the standard. The comment argued that, if the Commission amended the
Rule in this way, the Rule would always incorporate the most recent
ASTM standard. The Commission declines to follow this approach because
it would, in effect, grant ASTM the power to revise a Commission Rule.
If ASTM
[[Page 58347]]
revises the standard, the Commission can consider whether to revise the
Rule to incorporate the revised standard. Any interested party can
petition the Commission to amend the Rule at any time, particularly if
the failure to incorporate the revised standard would have an adverse
effect on consumers or commerce.\157\
---------------------------------------------------------------------------
\157\ See 16 CFR 1.9.
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C. Clarification of Reasonable Basis Requirements
As noted above, the Rule requires that manufacturers and importers
possess a reasonable basis for the care instructions they provide prior
to sale. Under the Rule, a reasonable basis must consist of reliable
evidence supporting the instructions on the label.\158\ Specifically, a
reasonable basis can consist of: (1) Reliable evidence that the product
was not harmed when cleaned reasonably often according to the
instructions; (2) reliable evidence that the product or a fair sample
of the product was harmed when cleaned by methods warned against on the
label; (3) reliable evidence, like that described in (1) or (2), for
each component part of the product in conjunction with reliable
evidence for the garment as a whole; (4) reliable evidence that the
product or a fair sample of the product was successfully tested; (5)
reliable evidence of current technical literature, past experience, or
industry expertise supporting the care information on the label; or (6)
other reliable evidence.\159\
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\158\ 16 CFR 423.6(c).
\159\ Id.
---------------------------------------------------------------------------
Several comments summarized in Section II.C above urged the
Commission to impose more rigorous testing requirements or to clarify
the Rule's reasonable basis requirements. These comments explained that
some manufacturers and importers appear not to understand the Rule's
reasonable basis requirements. No comment provided specific
suggestions.
The record is devoid of evidence showing that any manufacturers or
importers improperly relied on evidence other than testing, that
particular testing was inadequate or flawed, or that the benefits of
requiring additional or more rigorous testing to ensure better care
instructions would exceed the costs to manufacturers and importers. The
mere assertion that some manufacturers or importers violate the Rule
does not prove that the Commission needs to amend the Rule. Therefore,
the Commission declines to propose more rigorous testing requirements.
However, the comments suggest a need to clarify the Rule's
reasonable basis requirements to aid compliance without increasing or
decreasing the burden imposed on industry. Specifically, providing
examples of situations where testing an entire garment may be needed to
determine care instructions, as well as examples where such testing is
not needed, may help clarify the Rule's requirements. Accordingly, the
Commission proposes to incorporate advice from its business education
materials and include examples in Section 423.6(c)(3) and (5) as set
forth in the proposed amendment in the last section of this Notice of
Proposed Rulemaking.
Because the Commission does not intend to impose new requirements
on manufacturers or importers, it views these proposed revisions as
non-substantive.\160\ Nonetheless, the Commission seeks comment
regarding whether these proposed additions would be helpful and whether
the Commission should provide any additional clarification.
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\160\ The Commission also proposes to correct an error in
Section 423.6(c) by replacing the word ``processing'' with
``possessing.''
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D. Revised Definition of Dryclean
Several comments urged the Commission to update and expand the
Rule's definition of ``dryclean'' to include new solvents in the list
of examples and to cover solvents that are not organically-based. One
comment noted the introduction of new solvents over the last 25 years,
such as high flash hydrocarbons, silicones, glycol ethers, carbon
dioxide, and aldehydes. It also explained that one solvent listed in
the definition, fluorocarbon, is no longer used, and that not all
solvents are organically-based. Additionally, several comments argued
that the definition discourages the use of solvents not recognized by
the Rule and, therefore, risks curtailing technological advancement.
The record shows that the Commission needs to modernize the Rule's
definition of ``dryclean.'' Although the definition technically
includes all common organic solvents, it only lists three examples, one
of which is no longer used. To address the concerns raised by comments,
the Commission proposes to broaden the definition to cover any solvent
excluding water. In addition, the Commission proposes to drop the
reference to fluorocarbon and add new solvents identified in the record
to the list of examples. The Commission does not propose to delete
perchloroethylene from the list because drycleaners continue to use it
and may do so at least until California's ban takes effect in 2023.
Accordingly, the Commission proposes amending Section 423.1(c) as set
forth in the proposed amendment in the last section of this Notice of
Proposed Rulemaking.
The Commission also proposes to amend Appendix A.7.a in the same
way and to amend Appendix 7.c to include the solvent examples from the
revised definition.
V. Other Amendments the Commission Declines To Propose
A number of comments proposed amendments to the Rule other than
those discussed above. Some suggested that the Commission require
manufacturers and importers to disclose all appropriate care
procedures. Others proposed requiring additional disclosures,
disallowing certain care instructions, addressing the format or
composition of labels, expanding the scope of the Rule, or imposing
additional requirements such as making manufacturers or importers
accountable to consumers if they provide inaccurate care instructions.
One commenter proposed changing the ``overarching nomenclature and the
guiding principle'' behind the Rule to improve the reliability and
understandability of care labels. The Commission declines to propose
any of these amendments for the reasons explained below. Additionally,
the comments did not suggest amending the Rule to address the
presentation of instructions in multiple languages, and the Commission
declines to propose any amendments addressing this issue.
Several comments from the cleaning industry urged the Commission to
require manufacturers and importers to disclose all appropriate methods
of care. None of the comments from other affected industries supported
this proposal. The Commission issued the Rule to protect consumers from
unfair and deceptive trade practices. In issuing the Rule, the
Commission determined, based on the record in the proceeding, that it
was unfair or deceptive for manufacturers and importers to fail to
disclose a regular care procedure necessary for the ordinary use and
enjoyment of the product (or to warn the consumer that the product
cannot be cleaned without being harmed). It did not conclude that
manufacturers and importers must disclose multiple care procedures.
None of the comments included evidence demonstrating that the failure
to disclose all appropriate care methods would result in deception or
unfairness under the FTC Act. Nor did they submit evidence that the
benefits of requiring such a disclosure
[[Page 58348]]
would exceed the costs such a requirement would impose on manufacturers
and retailers. The Commission, therefore, has no reason to believe that
it is either unfair or deceptive for a manufacturer or importer to fail
to disclose all appropriate methods of care.
Similarly, the other comments proposing that the Commission impose
additional disclosure or other obligations on manufacturers and
importers, summarized in Section II.F above, failed to show that
imposing these obligations is necessary to prevent deception or
unfairness. Nor did they show that the benefits of the proposals would
exceed their costs. Thus, the Commission declines to propose any of
these amendments.
Some comments urged the Commission to require manufacturers and
importers to disclose fiber content on care labels even though the
Commission's Rules and Regulations Under the Textile Fiber Products
Identification Act (``Textile Rules'') already require disclosure of
fiber content.\161\ The comments did not provide evidence addressing
the need for this amendment or the costs it would impose. While it is
true that the Textile Rules do not require this disclosure in a form
that can be referred to by the consumer throughout the useful life of
the product, the Commission has anecdotal evidence that some
manufacturers and importers often include the fiber content disclosure
required by the Textile Rules on the same ``permanent'' label that
provides care instructions. In addition, as explained above, the
Commission proposes to require that any wetcleaning instruction
disclose fiber content if needed to select the appropriate wetcleaning
process. The Commission seeks comment on the extent to which care
labels already disclose fiber content and the need for fiber content
information on ``permanent'' labels but, at this time, declines to
propose amending the Rule to address this issue.
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\161\ 16 CFR part 303.
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GreenEarth proposed changing the ``overarching nomenclature and the
guiding principle'' behind the Rule to improve the reliability and
understandability of care labels (e.g., by replacing instructions such
as ``dryclean'' and ``do not dryclean'' with simplified categories of
``cleaning method'' and ``cycle'').\162\ GreenEarth, however, did not
submit any evidence on consumer perception of its proposed nomenclature
for care instructions or whether the benefits of replacing the Rule's
existing nomenclature and guiding principles would exceed the cost to
business.\163\ None of the other comments made similar proposals or
addressed GreenEarth's proposal. The record does not establish that
GreenEarth's approach would be superior to the current one. In
addition, it would represent a significant departure from the Rule's
longstanding approach to and industry practice for providing care
instructions. The Commission, therefore, declines to propose amending
the Rule as proposed by GreenEarth.\164\
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\162\ See discussion of GreenEarth's comment in Section II.B.
\163\ GreenEarth argued that its proposal would encourage the
substitution of less aggressive solvents for more aggressive ones in
the cleaning process, thereby measurably reducing claims for damaged
garments. However, it did not address whether its proposal would
increase the cost of providing care instructions, or submit any
evidence showing that its proposal would actually reduce the use of
more aggressive solvents.
\164\ The Commission rejects GreenEarth's proposal regarding
care symbols for similar reasons. See discussion in Section IV.B.
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Finally, the ANPR sought comments on whether the Commission should
amend the Rule to address care instructions in multiple languages. None
of the comments proposed amending the Rule to address the format for
presenting instructions in more than one language, although two
comments noted that using or harmonizing symbols would address problems
stemming from disclosures in multiple languages. Because none of the
comments proposed any amendments directly addressing the presentation
of multiple languages on care labels, the Commission declines to
propose any amendments on this issue. The Commission, however, seeks
additional comment on whether any of the proposed amendments to the
Rule affect the need to address this issue.
VI. Request for Comments
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before November 16,
2012. Write ``Care Labeling Rule, 16 CFR part 423, Project No.
R511915'' on your comment. Your comment--including your name and your
state--will be placed on the public record of this proceeding,
including, to the extent practicable, on the public Commission Web
site, at https://www.ftc.gov/os/publiccomments.shtm. As a matter of
discretion, the Commission tries to remove individuals' home contact
information from comments before placing them on the Commission Web
site.
Because your comment will be made public, you are solely
responsible for making sure that your comment doesn't include any
sensitive personal information, such as anyone's Social Security
number, date of birth, driver's license number or other state
identification number or foreign country equivalent, passport number,
financial account number, or credit or debit card number. You are also
solely responsible for making sure that your comment doesn't include
any sensitive health information, such as medical records or other
individually identifiable health information. In addition, don't
include any `[t]rade secret or any commercial or financial information
which is obtained from any person and which is privileged or
confidential,'' as provided in Section 6(f) of the FTC Act, 15 U.S.C.
46(f), and FTC Rule 4.10(a)(2), 16 CFR 4.10(a)(2). In particular, don't
include competitively sensitive information such as costs, sales
statistics, inventories, formulas, patterns, devices, manufacturing
processes, or customer names.
If you want the Commission to give your comment confidential
treatment, you must file it in paper form, with a request for
confidential treatment, and you have to follow the procedure explained
in FTC Rule 4.9(c), 16 CFR 4.9(c).\165\ Your comment will be kept
confidential only if the FTC General Counsel, in his or her sole
discretion, grants your request in accordance with the law and the
public interest.
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\165\ In particular, the written request for confidential
treatment that accompanies the comment must include the factual and
legal basis for the request, and must identify the specific portions
of the comment to be withheld from the public record. See FTC Rule
4.9(c), 16 CFR 4.9(c).
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Postal mail addressed to the Commission is subject to delay due to
heightened security screening. As a result, we encourage you to submit
your comments online. To make sure that the Commission considers your
online comment, you must file it at https://ftcpublic.commentworks.com/
ftc/CareLabelingNPRM, by following the instruction on the web-based
form. If this Notice appears at https://www.regulations.gov/#!home, you
also may file a comment through that Web site.
If you file your comment on paper, write ``Care Labeling Rule, 16
CFR Part 423, Project No. R511915'' on your comment and on the
envelope, and mail or deliver it to the following address: Federal
Trade Commission, Office of the Secretary, Room H-113 (Annex B), 600
Pennsylvania Avenue NW., Washington, DC 20580. If possible, submit your
paper comment to the Commission by courier or overnight service.
[[Page 58349]]
Visit the Commission Web site at https://www.ftc.gov to read this
NPRM and the news release describing it. The FTC Act and other laws
that the Commission administers permit the collection of public
comments to consider and use in this proceeding as appropriate. The
Commission will consider all timely and responsive public comments that
it receives on or before November 16, 2012. You can find more
information, including routine uses permitted by the Privacy Act, in
the Commission's privacy policy, at https://www.ftc.gov/ftc/privacy.htm.
The Commission invites members of the public to comment on any
issues or concerns they believe are relevant or appropriate to the
Commission's consideration of proposed amendments to the Care Labeling
Rule. The Commission requests that comments provide factual data upon
which they are based. In addition to the issues raised above, the
Commission solicits public comment on the costs and benefits to
industry members and consumers of each of the proposals as well as the
specific questions identified below. These questions are designed to
assist the public and should not be construed as a limitation on the
issues on which public comment may be submitted.
Questions
1. Is there empirical evidence regarding whether consumers
interpret a ``dryclean'' instruction to mean that a garment cannot be
washed? If so, please submit such evidence.
2. How many domestic businesses provide professional wetcleaning to
the public on a regular basis? To what extent do domestic businesses
provide both drycleaning and wetcleaning? What evidence supports your
answers?
3. To what extent do consumers have access to and use professional
wetcleaning services? To what extent are wetcleaning services widely
available geographically? What evidence supports your answers?
4. To what extent are consumers aware of the attributes and
availability of professional wetcleaning services? What evidence
supports your answer?
5. Assuming the Commission amends the Rule to permit a wetcleaning
instruction, should the Commission also amend Section 423.8(d) of the
Rule, which exempts products that can be cleaned safely under the
harshest procedures from the requirement of a permanent care label? If
so, how? What evidence supports your answer? For example, should the
Commission amend this section to add professional wetcleaning to the
list of procedures that safely can be used for a product to fall under
this exemption?
6. To what extent do drycleaners use solvents other than petroleum
and perc? To what extent do they use each of these drycleaning
solvents? How do these other solvents compare to perc with respect to
performance and environmental effects? To what extent do they use
multiple solvents? What evidence supports your answers?
7. To what extent do manufactures and importers disclose fiber
content information on labels providing care instructions? What
evidence supports your answer?
8. To what extent do manufacturers and importers use care symbols
to provide care instructions for garments and piece goods sold in the
United States? To what extent do they use symbols alone? To what extent
do they use symbols in conjunction with written instructions? To what
extent do they use ASTM symbols without using ISO symbols, ISO symbols
without using ASTM symbols, or both ASTM and ISO symbols? What evidence
supports your answer?
9. Is there empirical evidence regarding the extent to which
consumers understand or rely on care symbols or find labels using
multiple symbol systems, such as both the ASTM and ISO symbol systems,
confusing? If so, please submit such evidence.
10. The meaning of one drycleaning symbol in the ASTM symbol system
currently permitted by the Rule, a circle with the letter ``P'' inside,
changed significantly in the revised ASTM symbol system. The currently
permitted symbol means dryclean with any solvent except perc. In
contrast, the symbol under the revised system means dryclean with perc
or petroleum. Should the Commission amend the Rule to address this
issue? If so, how? What evidence supports your answer?
11. Do the proposed amendments to the Rule's reasonable basis
provisions clarify them adequately? Is any additional clarification
needed? If so, what? If not, why not? What evidence supports your
answers?
12. The record did not establish a need to amend the Rule to
address care labels in multiple languages. Do any of the proposed
amendments to the Rule affect the need to address this issue? If so,
how? What evidence supports your answer?
13. Would the following amendments impose costs or confer benefits
on consumers? Would they impose costs or confer benefits on apparel and
piece good manufacturers and importers, especially small businesses?
Would they impose costs or confer benefits on businesses that clean
apparel, especially small businesses? Would they impose costs or confer
benefits on businesses that sell apparel or piece goods to consumers,
especially small businesses? If so, how? If not, why not? What evidence
supports your answers?
(A) Amending the Rule to permit manufacturers and importers to
provide a professional wetcleaning instruction for garments or piece
goods that can be professionally wetcleaned;
(B) Amending the Rule to update the provision allowing the use of
certain care symbols in lieu of written terms by permitting
manufacturers and importers to use the symbol system set forth in
either ASTM Standard D5489-07, ``Standard Guide for Care Symbols for
Care Instructions on Textile Products,'' or ISO 3758:2005(E),
``Textiles--Care labelling code using symbols'';
(C) Amending the Rule to clarify the Rule's reasonable basis
requirements; and
(D) Amending the Rule's definition of ``dryclean.''
14. General Questions: To maximize the benefits and minimize the
costs for buyers and sellers (including specifically small businesses),
the Commission seeks views and data on the following general questions
for all the proposed changes described in this document:
(A) What benefits would the proposed changes confer, and on whom?
(B) What costs or burdens would the proposed changes impose, and on
whom?
(C) What regulatory alternatives to the proposed changes are
available that would reduce the burdens of the proposed changes while
providing the same benefits?
VII. Communications to Commissioners and Commissioner Advisors by
Outside Parties
Pursuant to Commission Rule 1.18(c)(1), the Commission has
determined that communications with respect to the merits of this
proceeding from any outside party to any Commissioner or Commissioner
advisor shall be subject to the following treatment. Written
communications and summaries or transcripts of oral communications
shall be placed on the rulemaking record if the communication is
received before the end of the comment period on the staff report. They
shall be placed on the public record if the communication is received
later. Unless the outside party making an oral communication is a
member of Congress, such communications are permitted only if advance
notice is
[[Page 58350]]
published in the Weekly Calendar and Notice of ``Sunshine''
Meetings.\166\
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\166\ See 15 U.S.C. 57a(i)(2)(A); 16 CFR 1.18(c).
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VIII. Preliminary Regulatory Analysis and Regulatory Flexibility Act
Requirements
Under Section 22 of the FTC Act, 15 U.S.C. 57b, the Commission must
issue a preliminary regulatory analysis for a proceeding to amend a
rule only when it: (1) Estimates that the amendment will have an annual
effect on the national economy of $100 million or more; (2) estimates
that the amendment will cause a substantial change in the cost or price
of certain categories of goods or services; or (3) otherwise determines
that the amendment will have a significant effect upon covered entities
or upon consumers. The Commission has preliminarily determined that the
proposed amendments will not have such effects on the national economy;
on the cost of labeling apparel and piece goods; or on covered parties
or consumers.
The proposed amendments provide manufacturers and importers with
additional options for disclosing care instructions, clarify the Rule,
and update the definition of ``dryclean'' to reflect current practices
and technology, so the proposed amendments would not require
manufacturers or importers to alter their behavior and would not impose
additional costs on them. The Commission, however, requests comment on
the economic effects of the proposed amendments.
The Regulatory Flexibility Act (``RFA''), 5 U.S.C. 601-612,
requires that the Commission conduct an analysis of the anticipated
economic impact of the proposed amendments on small entities. The
purpose of a regulatory flexibility analysis is to ensure that an
agency considers the impacts on small entities and examines regulatory
alternatives that could achieve the regulatory purpose while minimizing
burdens on small entities. Section 605 of the RFA, 5 U.S.C. 605,
provides that such an analysis is not required if the agency head
certifies that the regulatory action will not have a significant
economic impact on a substantial number of small entities. The
Commission believes that the proposed amendments would not have a
significant economic impact upon small entities, although it may affect
a substantial number of small businesses. Specifically, the Commission
proposes a few limited amendments designed to provide manufacturers and
importers with more options for disclosing care instructions, clarify
the Rule, and update the definition of ``dryclean.'' In the
Commission's view, the proposed amendments should not have a
significant or disproportionate impact on the costs of small entities
that manufacture or import apparel or piece goods. Therefore, based on
available information, the Commission certifies that amending the Rule
as proposed will not have a significant economic impact on a
substantial number of small businesses.
Although the Commission certifies under the RFA that the proposed
amendments would not, if promulgated, have a significant impact on a
substantial number of small entities, the Commission has determined,
nonetheless, that it is appropriate to publish an Initial Regulatory
Flexibility Analysis to inquire into the impact of the proposed
amendments on small entities. Therefore, the Commission has prepared
the following analysis:
A. Description of the Reasons That Action by the Agency is Being Taken
In response to public comments, the Commission proposes amending
the Rule to respond to the development of new technologies, changed
commercial practices, and updated industry standards.
B. Statement of the Objectives of, and Legal Basis for, the Proposed
Amendments
The objective of the proposed amendments is to provide
manufacturers and importers of apparel and certain piece goods with
additional options for disclosing care instructions, clarify the Rule's
reasonable basis provisions, and update the definition of ``dryclean''
to reflect current practices and technology. The Commission promulgated
the Rule pursuant to Section 18 of the FTC Act, 15 U.S.C. 57a. As noted
earlier, the Commission has wide latitude in fashioning a remedy and
need only show a ``reasonable relationship'' between the unfair or
deceptive act at issue and the remedy.\167\ The Rule as modified by the
proposed amendments would reasonably relate to the practices that led
the Commission to promulgate the Rule. It would provide covered
entities with additional options for complying with the Rule's
disclosure requirements without imposing new burdens or additional
costs.
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\167\ American Fin. Servs. Ass'n v. FTC, 767 F.2d 957, 988 (D.C.
Cir. 1985) (quoting Jacob Siegel Co. v. FTC, 327 U.S. 608, 612-13
(1946)).
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C. Small Entities to Which the Proposed Amendments Will Apply
Under the Small Business Size Standards issued by the Small
Business Administration, textile apparel and some fabric manufacturers
qualify as small businesses if they have 500 or fewer employees.
Clothing and piece good wholesalers qualify as small businesses if they
have 100 or fewer employees. The Commission's staff has estimated that
approximately 22,218 manufacturers or importers of textile apparel are
covered by the Rule's disclosure requirements.\168\ A substantial
number of these entities likely qualify as small businesses. The
Commission estimates that the proposed amendments will not have a
significant impact on small businesses because it does not impose any
new obligations on them. The Commission seeks comment and information
with regard to the estimated number or nature of small business
entities for which the proposed amendments would have a significant
impact.
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\168\ Federal Trade Commission: Agency Information Collection
Activities; Proposed Collection; Comment Request, 76 FR 77230 (Dec.
12, 2011).
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D. Projected Reporting, Recordkeeping, and Other Compliance
Requirements, Including Classes of Covered Small Entities and
Professional Skills Needed to Comply
As explained earlier in this document, the proposed amendments will
provide apparel manufacturers and importers with additional options for
disclosing care instructions, clarify the Rule's reasonable basis
requirements, and update the definition of ``dryclean'' to reflect
current practices and technology. The small entities potentially
covered by these proposed amendments will include all such entities
subject to the Rule. The professional skills necessary for compliance
with the Rule as modified by the proposed amendments would include
office and administrative support supervisors to determine label
content and clerical personnel to draft and obtain labels. The
Commission invites comment and information on these issues.
E. Duplicative, Overlapping, or Conflicting Federal Rules
The Commission has not identified any other federal statutes,
rules, or policies that would duplicate, overlap, or conflict with the
proposed amendments. The Commission invites comment and information on
this issue.
[[Page 58351]]
F. Significant Alternatives to the Proposed Amendments
The Commission has not proposed any specific small entity exemption
or other significant alternatives, as the proposed amendments simply
provide additional options for disclosing care instructions, clarify
the Rule's reasonable basis provisions, and update the definition of
``dryclean'' to reflect current practices and technology. Under these
limited circumstances, the Commission does not believe a special
exemption for small entities or significant compliance alternatives are
necessary or appropriate to minimize the compliance burden, if any, on
small entities while achieving the intended purposes of the proposed
amendments. Nonetheless, the Commission seeks comment and information
on the need, if any, for alternative compliance methods that would
reduce the economic impact of the Rule on small entities. If the
comments filed in response to this NPRM identify small entities that
would be affected by the proposed amendments, as well as alternative
methods of compliance that would reduce the economic impact of the
proposed amendments on such entities, the Commission will consider the
feasibility of such alternatives and determine whether they should be
incorporated into the final Rule. As explained above, the Commission
considered a number of alternative amendments advocated by commenters
and decided not to propose any of them.
IX. Paperwork Reduction Act
The Rule contains various ``collection of information'' (e.g.,
disclosure) requirements for which the Commission has obtained OMB
clearance under the Paperwork Reduction Act (``PRA''), 44 U.S.C. 3501
et seq.\169\ As discussed above, the Commission proposes amendments to:
(a) Clarify the Rule; (b) update the definition of ``dryclean'' to
reflect current technology and practices; and (c) provide manufacturers
and importers with added options for disclosing care instructions.
These proposed amendments do not impose any additional collection of
information requirements. For example, businesses that prefer not to
provide a wetcleaning instruction or use symbols need not do so.
Depending on the disclosure option selected for disclosing care
instructions, the associated PRA burden might even be reduced.
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\169\ The Commission recently published its PRA burden estimates
for the current information collection requirements under the Rule.
See Federal Trade Commission: Agency Information Collection
Activities; Proposed Collection; Comment Request, 76 FR 77230 (Dec.
12, 2011) and Federal Trade Commission: Agency Information
Collection Activities; Submission for OMB Review; Comment Request,
77 FR 10744 (Feb. 23, 2012). On March 26, 2012, OMB granted
clearance through March 31, 2015, for these requirements and the
associated PRA burden estimates. The OMB control number is 3084-
0103.
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List of Subjects in 16 CFR Part 423
Clothing, Labeling, Textiles, Trade practices.
For the reasons set out in the preamble, the Commission proposes to
amend 16 CFR part 423 as follows:
PART 423--CARE LABELING OF TEXTILE WEARING APPAREL AND CERTAIN
PIECE GOODS
1. The authority citation for part 423 continues to read as
follows:
Authority: 15 U.S.C. 57a.
2. Revise the heading of part 423 to read as set forth above.
3. Amend Sec. 423.1 by revising paragraph (c) and adding paragraph
(h) to read as follows:
Sec. 423.1 Definitions.
* * * * *
(c) 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% relative humidity, hot tumble
drying up to 160 degrees F (71 degrees C) and restoration by steam
press or steam-air finishing.
* * * * *
(h) 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.
4. Amend Sec. 423.6 by revising paragraph (b) introductory text,
adding paragraph (b)(3), and revising paragraphs (c) introductory text,
(c)(3), and (c)(5) to read as follows:
Sec. 423.6 Textile wearing apparel.
* * * * *
(b) Care labels must state what regular care is needed for the
ordinary use of the product. In general, labels for textile wearing
apparel must have either a washing instruction, a drycleaning
instruction, or a wetcleaning instruction. If a washing instruction is
included, it must comply with the requirements set forth in paragraph
(b)(1) of this section. If a drycleaning instruction is included, it
must comply with the requirements set forth in paragraph (b)(2) of this
section. If a wetcleaning instruction is included, it must comply with
the requirements set forth in paragraph (b)(3) of this section. If
washing, drycleaning, or wetcleaning can be used, the label need have
only one of these instructions. If the product cannot be cleaned by any
available cleaning method without being harmed, the label must so
state. [For example, if a product would be harmed by washing,
drycleaning, and wetcleaning, the label might say, ``Do not wash--do
not dryclean or wetclean,'' or ``Cannot be successfully cleaned.''] The
instructions for washing, drycleaning, and wetcleaning are as follows:
* * * * *
(3) Wetcleaning--(i) General. If a wetcleaning instruction is
included on the label, and a mild or very mild process should be used,
the label must state the process that must be used. If a normal process
will not harm the product, the label need not mention any type of
process. If the product's fiber content is needed to determine how to
select the appropriate wetcleaning process, the label must state the
fiber content.
(ii) Warnings. (A) If there is any part of the wetcleaning
procedure which consumers or wetcleaners reasonably can be expected to
use that would harm the product or others being cleaned with it, the
label must contain a warning to this effect. The warning must use the
words ``Do not,'' ``No,'' ``Only,'' or some other clear wording.
(B) Warnings are not necessary for any procedure which is an
alternative to the procedure prescribed on the label. [For example, if
an instruction states ``Professionally wetclean, very mild process,''
it is not necessary to give the warning ``Do not use normal process.'']
(c) A manufacturer or importer must establish a reasonable basis
for care information by possessing prior to sale:
* * * * *
(3) Reliable evidence, like that described in paragraph (c)(1) or
(2) of this section, for each component part of the product in
conjunction with reliable evidence for the garment as a whole; provided
that test results showing that a whole garment can be cleaned as
recommended may be required where, for example:
(i) The color of one part often bleeds onto another when the
finished garment is washed;
(ii) A dye that is known to bleed, or beads, buttons, or sequins
that are known to be damaged often in drycleaning are used; or
[[Page 58352]]
(iii) A garment contains several fibers, fabrics, or components not
previously used together; or
* * * * *
(5) Reliable evidence of current technical literature, past
experience, or industry expertise supporting the care information on
the label [For example, if past experience with particular dyes and
fabrics indicates that a particular red trim does not bleed onto
surrounding fabric, testing the entire garment might not be necessary];
or
* * * * *
5. Amend Sec. 423.8 by revising paragraph (g) as follows:
Sec. 423.8 Exemptions.
* * * * *
(g) The symbol systems developed by ASTM International (ASTM) and
designated as ASTM D5489-07, ``Standard Guide for Care Symbols for Care
Instructions on Textile Products'' and by the International
Organization for Standardization (ISO) and designated as 3758:2005(E),
``Textiles--Care labelling code using symbols,'' may be used on care
labels or care instructions in lieu of terms so long as the symbols
fulfill the requirements of this part. If the ISO symbols are used, the
label should disclose this fact. In addition, symbols from either one
of the two symbol systems above may be combined with terms so long as
the symbols and terms used fulfill the requirements of this part. This
incorporation by reference was approved by the Director of the Federal
Register in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. Copies
of ASTM D5489-07, ``Standard Guide for Care Symbols for Care
Instructions on Textile Products,'' may be obtained from ASTM, 100 Barr
Harbor Drive, West Conshohocken, PA 19428. Copies of ISO 3758:2005(E),
``Textiles--Care labelling code using symbols,'' may be obtained from
American National Standards Institute, 11 West 42nd Street, 13th Floor,
New York, NY 10036. Both ASTM D5489-07 and ISO 3758:2005(E) may be
inspected at the Federal Trade Commission, room 130, 600 Pennsylvania
Avenue NW., Washington, DC or at the National Archives and Records
Administration (NARA). For information on the availability of this
material at NARA, call 202-741-6030, or go to https://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.
* * * * *
6. Amend Appendix A by revising paragraph 7.a and c, and by adding
a new paragraph 9.a, to read as follows:
Appendix A to Part 423--Glossary of Standard Terms
* * * * *
7. Drycleaning; All Procedures:
a. ``Dryclean''--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% relative humidity,
hot tumble drying up to 160 degrees F (71 degrees C) and restoration
by steam press or steam-air finishing.
* * * * *
c. ``Petroleum,'' ``Perchloroethylene,'' ``Silicone,'' ``Glycol
Ether,'' ``Carbon Dioxide,'' or ``Aldehyde''--employ solvent(s)
specified to dryclean the item.
* * * * *
9. Professional Wetcleaning:
a. ``Wetclean''--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.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2012-22746 Filed 9-19-12; 8:45 am]
BILLING CODE 6750-01-P