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The Federal Trade Commission (FTC) enforces the Care Labeling Rule which requires manufacturers and importers to attach care instructions to garments. The FTC has information about other Rules relating to labeling textile products for fiber content, country of origin and manufacturer identity.
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Care labels often are a deciding factor when consumers shop for clothing. While some consumers look for the convenience of drycleaning, others prefer the economy of washable garments. In fact, surveys show that consumers want washing instructions. Some manufacturers try to reach both markets with garments that can be cleaned by either method. The Rule lets you provide more than one set of care instructions, if you have a reasonable basis for each instruction. Some manufacturers provide instructions for both methods but add, "For best results, dryclean." This tells consumers that the garment can be washed without damage, but drycleaning may be better for appearance and durability. If truthful and substantiated, care instructions like these are acceptable.
Manufacturers and importers must provide care information clearly and conspicuously on the end of each roll or bolt of fabric. The information should apply to the fabric on the roll or bolt, not to items the consumer might add to the fabric, like trim, lining or buttons.
Failing to provide reliable care instructions and warnings for the useful life of an item is a violation of the FTC Act. Violators are subject to enforcement actions and penalties of up to $16,000 for each offense. In enforcement actions, the FTC contends that each mislabeled garment is a violation. Since 1990, the FTC has brought 16 enforcement actions; 15 were resolved by settlements and one was litigated. Penalties have ranged as high as $300,000.
Labels for clothing must have a washing or drycleaning instruction. If an item can be washed and drycleaned, the label needs only one of these instructions. Remember that consumers like having washing instructions for items that can be washed. If you prefer, give instructions for both washing and drycleaning.
You may use the care symbols from the American Society for Testing and Materials (ASTM) designated as ASTM Standard D5489-96c Standard Guide for Care Symbols for Care Instructions on Textile Products, in place of words, but the symbols must fulfill the requirements of the Rule. These symbols are similar, but not identical, to the symbols designated as an international standard by the International Standards Organization (ISO) and used in many European countries.
Although only the ASTM symbols are approved for use in the United States, in September 2012 the Commission proposed amending the Rule to allow the use of the updated ASTM symbols in ASTM Standard D5489-07, and the ISO symbols in ISO Standard 3758:2005(E).
If a care procedure on one product could harm another product that is washed with it, the label must include a warning. For example, if an item is not colorfast, the label must say "Wash with like colors" or "Wash separately."
If any part of the drycleaning process would harm the product, the "dryclean" instruction must include a warning to avoid or modify that part of the process. The label must use "Do not," "No," "Only," or other clear wording. For example, if steam would damage a garment, the label should say "Dryclean. No steam."
A. You can put care information on the reverse side of a permanent label if only one end of the permanent label is sewn into the garment and the consumer has easy access to the front and back of the label. The front of the label doesn't have to say "Care on reverse."
A. A garment that has two parts or more 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, each item must have its own care label.
Q. Generally, when wash-and-wear garments are removed promptly from the dryer, they don't need ironing. But if garments aren't removed promptly, they might wrinkle and require some pressing with a cool iron. Does a care instruction have to address this?
A. Yes. Care instructions must include all components of the product, including non-detachable linings, trim and other details. The instructions should contain any special considerations for components as a warning; for example, "Remove trim," or "Close zipper." A detachable component, like a slip-out liner, must be labeled separately if it requires a different care procedure than the main product.
A. "Dryclean only" may be used when the garment can be drycleaned safely by the normal process, using any drycleaning solvent. The instruction indicates that the garment can't be safely washed. When you use "Dryclean only," you must have a reasonable basis for both the drycleaning instruction and the warning against washing.
A. Use "Professionally dryclean" when the normal drycleaning process must be modified to dryclean the product safely. "Professionally dryclean" is not an adequate instruction by itself. 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 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.
A. No. The symbols you use must be those developed by the ASTM and designated as ASTM Standard D5489-96c. In September 2012, the Commission proposed amending the Rule to allow the use of the symbols in ASTM Standard D5489-07, and the ISO symbols in ISO Standard 3758:2005(E).
A. Yes. In addition to rental service companies, 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.
A. Yes. Hosiery products, including stockings, anklets, waist-high tights, panty hose and leg warmers, are exempt. Hosiery items don't need a permanent care label, but they must have care instructions on a hang tag, on the package or in another conspicuous place. This includes sheer hosiery of 50 denier or less. Hosiery that retails for $3 or less and that can be washed and dried at hot settings without damage doesn't need a label.
A. No, but using a care method not specified on a care label may be risky. Clothing labeled as washable may not dryclean satisfactorily. Many local drycleaners have facilities for properly washing and finishing washable garments, but customers who ask for a method of cleaning not listed on the care label may be asked to sign a consent form explaining 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.
A. No. The subject was of considerable interest during the last amendment proceedings, and is discussed at length in the Care Labeling Rule Statement of Basis and Purpose. In September 2012, the Commission proposed amending the Rule to allow a wetcleaning instruction for items that can be professionally wetcleaned.
The National Small Business Ombudsman and 10 Regional Fairness Boards collect comments from small businesses about federal compliance and enforcement activities. Each year, the Ombudsman evaluates the conduct of these activities and rates each agency's responsiveness to small businesses. Small businesses can comment to the Ombudsman without fear of reprisal. To comment, go to www.sba.gov/ombudsman.
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