FTC Answers Frequently Asked Questions about Care Labels

Sunday, August 16, 2009

The topic of care labels come up quite a bit in the textile and clothing business, so I thought I would share a post just published by our friends at the National Textile Association, a terrific association based in Boston. They also have an excellent blog that I recommend.

The following provides a list of answers by the US Federal Trade Commission (FTC) to frequently asked questions about care labels.

Label Location
Q. May care instructions be put on the back of another permanent label sewn into the garment?

A. If only one end of a permanent label is sewn into the garment and the front and back of the label are readily accessible to the consumer, care information may appear on the reverse side. The front of the label doesn't have to say "Care on reverse."

Q. Does each piece of an ensemble, suit or other multi-piece garment need a care label?

A. A garment that consists of two or more parts and is always sold as a unit needs only one care label if the care instructions are the same for all the pieces. The label should be attached to the major piece of the suit. If the suit pieces require different care instructions or are designed to be sold separately, like coordinates, then each item must have its own care label.

Q. May I print care instructions directly on the product?

A. Yes, if the instructions meet the Rule's requirements of permanence and legibility.

Q. May I print care instructions on the "fiber content" label?

A. Yes, if the instructions meet the Rule's requirements of permanence and legibility.



Label Content
Q. What's the minimum washing instruction that can appear on a care label?

A. At a minimum, a washing instruction would include a method of washing and a method of drying, like "Machine wash. Tumble dry." This minimal wording, however, means that the product can be machine washed and tumble dried at any temperature, that ironing isn't necessary, that any type of bleach can be used, and that no warnings are required. Thus, all elements of a proper washing instruction would have to be considered - washing, drying, ironing, bleaching and warnings.

Q. Generally, when wash-and-wear garments are removed promptly from the dryer, they don't need ironing. But if the garments aren't removed promptly, they will wrinkle and require some pressing with a cool iron. Must a care instruction say something about this?

A. Yes. The Rule requires ironing instructions if ironing is needed on a regular basis to preserve the appearance of the product or as a special warning when a consumer can be expected to use an iron and using a hot iron would harm the product. In these cases, it is reasonable to expect some consumers to use an iron. Therefore, the instruction could read "Cool iron, if needed." This indicates that ironing is not always needed, but if an iron is used, it should be set at the lowest temperature setting.

Q. Is it proper if the bleach portion of a washing instruction says, "Do not use chlorine bleach"?

A. No. A care label that contains only the words "Do not use chlorine bleach" is unacceptable. If using chlorine bleach on a regular basis would harm the product, but using non-chlorine bleach on a regular basis would not, the label must say, "Only non-chlorine bleach, when needed." This instruction is designed to warn consumers that chlorine bleach is not safe, but non-chlorine bleach is safe for regular use. For more clarity, the care label may say "Only non-chlorine bleach, when needed. Do not use chlorine bleach."

Q. Would a care label that says "Wash in warm water. Block to dry. Do not use bleach" be permitted under the Rule?

A. No. This instruction is not complete, even if no other warnings are required and ironing is not necessary. The Rule requires washing instructions to state whether the products should be washed by hand or machine.

Q. Must a care instruction take into consideration such things as linings, trim, buttons or zippers?

A. Yes. Care instructions must include all components of the product, including non-detachable linings, trim and other details. Any special considerations for such components should be contained in the instruction as a warning, for example, "Remove trim," or "Close zipper." A detachable component, such as a slip out liner, must be separately labeled when it requires a different care procedure than the main product.

Q. When may "Dryclean only" be used?

A. "Dryclean only" may be used when the garment can be safely drycleaned by the normal process, using any drycleaning solvent. The instruction indicates that the garment can't be safely washed. When "Dryclean only" is used, there must be a reasonable basis for both the drycleaning instruction and the warning against washing.

Q. Is the single word "Dryclean" a sufficient care instruction?

A. Yes. While a drycleaning instruction generally must include a type of solvent that can be used safely (say, perchlorethylene or petroleum), if any type of commercially available solvent can be used, it is not necessary to name a type of solvent that can be used. A care instruction with only the word "Dryclean" means that any solvent may be used safely in a process that includes machine cleaning, moisture addition to solvent of up to 75% relative humidity, hot tumble drying up to 160 degrees Fahrenheit, and restoration by steam press or steam-air finishing.

Q. When should "Professionally dryclean" be used?

A. "Professionally dryclean" should be used when the normal drycleaning process must be modified to safely dryclean the product. However, by itself, "Professionally dryclean" is not an adequate instruction. It must be accompanied by the modification(s) necessary to make the drycleaning process safe. For example, "Professionally dryclean, reduce moisture, short cycle, tumble warm, no steam" would mean that any commercially available solvent could be used, the moisture addition to the solvent should be reduced, the cleaning time should be reduced, the warm setting should be used for tumble drying, and steam should not be used in pressing or finishing.

Care Symbols
Q. Must I use symbols?

A. No. Symbols are optional as long as there are care instructions on the label. If you choose, however, you may use symbols without words, but, if you do, you might want to include information about the meaning of the symbols (for example, on a hangtag or in your catalogue) to be sure your customers understand them.

Q. May I use the system of symbols used in Europe and designated as an international standard by the International Standards Organization (ISO)?

A. No. The symbols you use must be those developed by the ASTM and designated as ASTM Standard D5489-96c. The system used in Europe does not provide symbols for all the information required by the Care Labeling Rule.

Labeling Piece Goods
Q. What does "certain piece goods" mean?

A. Under the Rule, certain piece goods are fabrics sold at retail on a piece-by-piece basis from bolts, pieces or rolls for use in home sewing of textile wearing apparel. The term "fabric" means any material woven, knitted, felted, or otherwise produced from, or in combination with, any natural or manufactured fiber, yarn or substitute.

Two categories of piece goods are excluded from the Rule:

Trim up to 5 inches wide, such as ribbon, lace, rick-rack, tape, belting, binding, or braid; and

Manufacturer's remnants up to 10 yards long when the remnants are clearly and conspicuously marked as "pound goods" or "fabric of undetermined origin," and the fiber content of the remnants is unknown and can't be readily determined. If the remnant's fiber content is known, it's not excluded. Remnants created at the retail level, or by the manufacturer at the request of the retailer, are not excluded either.

Q. Manufacturers and importers must put care information for piece goods "on the end of each bolt or roll." Is there any specific location for this information?

A. Care information may be placed on the selvage of the material, on the end of the "board" on which the goods are wound, on a tag attached to the selvage or the "board end," or on any other position at the end of the roll where the information can be found easily and read by a consumer. If a tag is used, it should be attached so that it will not separate from the bolt until the last piece is sold.

Exemptions to the Rule
Q. The Rule exempts products sold to institutional buyers for commercial use. Does this include rental service companies?

A. Yes. Other institutional buyers include: hospitals; nursing homes; colleges and universities; local, state, and federal institutions; hotels; motels; and other bulk purchasers of uniforms and employee work clothes.

Q. Is there any exemption that applies to a whole product line?

A. The only product line exemption applies to hosiery, including stockings, anklets, waist-high tights, panty hose, and leg warmers. While hosiery items don't need a permanent care label, they must have care instructions on a hang tag, on the package, or in another conspicuous place. This includes sheer hosiery (50 denier or less). However, hosiery that retails for $3 or less and can be washed and dried at hot settings without damage doesn't need a label.

Drycleaners
Q. Must a drycleaner clean a garment according to the instructions on the care label?

A. No, but using a care method not specified on a care label may be risky. Clothing labeled as washable may - or may not - dryclean satisfactorily. Many local drycleaners have facilities for properly washing and finishing washable garments, but customers who request a method of cleaning not listed on the care label may be asked to sign a consent form. The form explains that the drycleaner and the customer have discussed the potential risks of cleaning the garment. With or without the consent form, when drycleaners accept garments for cleaning, they are obligated to clean garments professionally, to the best of their ability.

"Professionally Wetclean"
Q. Does a care label that states "Professionally wetclean" comply with the Care Labeling Rule?

A. No. The subject was of considerable interest during the amendment proceedings, and is discussed at length in the Care Labeling Rule Statement of Basis and Purpose, published in the Federal Register on August 2, 2000, and available in the Care Labeling section on the Textile, Wool, Fur and Apparel page on www.ftc.gov/os/statutes/textilejump.htm.

Here's a brief explanation of the Commission's reasons for not allowing a "Professionally wetclean" instruction now:

The Commission believes that a final definition of "professional wetcleaning" and an appropriate test method for the process must be developed before the Commission can amend the Rule to permit a "Professionally wetclean" instruction on required care labels. This is necessary in order to give manufacturers clear guidance as to how they may establish a reasonable basis for a wetclean instruction. Currently, manufacturers can test garments for drycleaning by having them drycleaned in perchloroethylene or another commercially available drycleaning solvent. They can test for home washing by laundering them at various water temperatures. In order to have a reasonable basis for a "Professionally wetclean" instruction, manufacturers would need to be able to subject the garments to such a cleaning method. In this case, however, the "method" may encompass many different processes, and the one chosen would depend in large part on the particular cleaner. In recommending a particular cleaning method, manufacturers must have assurance that the method they are recommending - and for which they have established a reasonable basis - is the same method that cleaners actually would use to clean the garment labeled for that method. For this reason, a definition of "professional wetcleaning," for purposes of amending the Care Labeling Rule, must either describe all important variables in the process, so that manufacturers could determine that their garments would not be damaged by the process, or be coupled with a specific test procedure that manufacturers could use to establish a reasonable basis.

In short, the Commission concluded "that some level of standardization is necessary before a 'Professionally wetclean' instruction can be placed on garments that are to be sold throughout the entire country." The Commission noted, however, that it was "encouraged by the fact that, during the year since the workshop took place, standards-setting organizations and other interested participants in this proceeding appear to have been working independently to resolve these outstanding issues."

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