The Federal Trade Commission (“FTC”) announced this week that it will host a roundtable on October 1 regarding the Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods (the “Care Labeling Rule”). As apparel manufacturers and retailers know, the Care Labeling Rule requires manufacturers and importers to attach labels with care instructions for drycleaning washing, bleaching, drying and ironing of garments and certain piece goods.
The roundtable will focus on a proposal to allow manufacturers and importers to include professional instructions for wetcleaning – described as an environmentally friendly alternative to drycleaning – on labels if the garment can be professionally wetcleaned and on whether the Commission should require a wetcleaning instruction for such garments. It will also address the cost of substantiating wetcleaning instructions, the availability of wetcleaning, consumer awareness of wetcleaning, and the content of labels providing a wetcleaning instruction.
The roundtable will also feature a discussion about the differences between ASTM International (American Society for Testing and Materials) and both the 2005 and 2012 ISO (International Organization for Standardization) care symbols, whether labels should identify ISO symbols as such if used to comply with the Rule, the change in the meaning of the circle P symbol in the ASTM system, and consumer understanding of symbols. In addition, the roundtable will include a discussion about the absence of ASTM and ISO symbols for solvents other than perchloroethylene and petroleum. The roundtable also will address how to clarify what constitutes a reasonable basis for care instructions.
The Commission has obtained civil penalties in several cases involving the Care Labeling Rule, and dry cleaning instructions in particular, over the last several years. Comments submitted in response to the Commission’s September 2012 request can be found here.