16 CFR Part 423--Care Labeling Rule --Comment July 26, 1998 Donald S. Clark, Secretary Dear Mr. Clark: The following comments are written in response to the proposed care labeling rule change as detailed in the Federal Register, Vol. 63, No. 89, dated May 8, 1998. Comments are written on behalf of Pendleton Woolen Mills. Pendleton's vertical operation includes textile production, apparel manufacturing, and retailing. Pendleton products include wools, but also a wide variety of natural fiber and man-made fiber goods. Pendleton's vertical involvement offers perspective on care labeling from several levels within the apparel industry. Here are comments regarding the proposed care label changes: (1) The proposed change that would require that an item that can be cleaned by home washing be labeled with instructions for home washing. This proposed change is consistent with Pendleton's current direction for increased emphasis on garment washability. Market information gathered by Pendleton staff has indicated the importance of washability to consumers. This requirement may mean a relatively small increase in the amount of testing, but Pendleton is already seeking to put washable care instructions on garments when possible. The Federal Register notice indicated the likelihood of dry-clean care labels on many home-washable items. This raises the concern that garment washability can be somewhat difficult to determine and may be interpreted differently by different individuals. For a substantial number of apparel items, home washing more rapidly deteriorates garment appearance than dry cleaning, and has much more impact on garment fit. In these cases, home washing can result in high levels of consumer dissatisfaction, depending on individual expectations regarding performance. The proposed care label change refers to garments that can be "safely" washed at home or to garments for which home washing is "appropriate." If the appearance and the sizing of the garment is significantly compromised by home laundering, is that method still "safe" or "appropriate?" The proposed changes indicate manufacturer discretion in care labeling when garments can be washed safely but not adequately finished by the average consumer at home. It would seem that manufacturer discretion in care labeling should be extended to cases where garment performance as a "washable" is questionable, and to cases where dry cleaning would provide noticeably superior garment performance over washing. Apparel manufacturers appear to be in the best position to anticipate their consumer needs and expectations regarding garment performance. Given that different care methods can result in different garment performance levels, the Commission might also consider adding an aspect to care labeling terminology which would indicate that one care method provides superior garment performance over another care method. An example might be--machine wash...or dry clean for best results. This would still give the consumer the option to wash at home but also some indication of garment performance when using different care methods. (2) The proposed change to allow that a garment that can be professionally wet cleaned be labeled with instructions for professional wet cleaning. For Pendleton, professional wet cleaning is viewed as an emerging technology with very limited consumer accessibility. The merits of this technology have yet to be established both within the apparel industry and with the consumer. Currently, Pendleton has received almost no consumer inquiries regarding professional wet cleaning. Although Pendleton does not anticipate use of professional wet cleaning care instructions in the short term, developments in professional wet cleaning will be monitored and potential applications of this technology considered for Pendleton products. Based on the very limited availability of professional wet cleaning and the lack of consumer familiarity to this cleaning method, it seems very important that this care instruction should be accompanied by another cleaning instruction. Consumer confusion regarding the meaning of "professional wet cleaning" and the resulting potential for garment damage due to misinterpretation, remain important concerns for care labeling with this care method. (3) The proposed change to amend what constitutes a reasonable basis for care instructions by clarifying that the requirement applies to the garment in its entirety rather than to each of its component parts. The proposed change seems appropriate since compatibility of garment components during cleaning is crucial to successful garment performance. Pendleton already supports this proposed change in practice, with a testing program that tests both garment components and finished garments. (4) The proposal to change the temperature definitions of hot, warm and cold water, and to add a "very hot" water definition. The proposed change to align water temperatures with those used by testing associations for the cold, warm and hot designations seems appropriate, especially since this seems to reflect changes in consumer washing practices. However, the need for the addition of a "very hot" water designation does not seem to be clearly demonstrated. In fact, the trend in home washing practices for a number of years, has been away from the use of hot water. None of Pendleton's 30+ current care labels carry a hot water designation. It seems that the use of the "very hot " water terminology would be very confusing to consumers, difficult to interpret and implement as a home washing option, and probably not needed as an option by the vast majority of consumers. If hotter wash temperatures are commonly used or needed in professional laundering, it would seem appropriate for this aspect of cleaning to be controlled by a "professional laundering" care instruction, much as the specifics of dry cleaning are controlled by the professional dry cleaner when the "dry clean" care instruction is used. A more relevant issue to consumers regarding water temperature, might be the addition of a lower end temperature for the cold water designation. As noted in several comments listed in the Federal Register notice, many laundry detergents do not work effectively if the water temperature is too low. To summarize, Pendleton supports the proposed rule change to indicate garment washability when possible, but with allowance for manufacturer discretion in care labeling when home washing presents significant performance or finishing concerns. Pendleton also has no serious objections to the proposed rule changes regarding professional wet cleaning, clarification of "reasonable basis" for care instructions, and the changes in water temperature definitions, with the exception of the proposed "very hot" water category. With the current introduction of care symbols on care labels in the American apparel market, Pendleton has seen increased consumer confusion regarding the appropriate care of their garments. It seems that as we consider changes to the care labeling rule, changes that make consumer care easier, more understandable and more effective should be given importance. Respectfully Submitted, Pendleton Woolen Mills Written by Kay Gipson, CFCS |