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As reported in previous issues of “LabelTalk? the FTC had been considering four proposed amendments to the existing 16CFR23.

Effective September 1, 2000, the Commission adopted two of the four amendments considered. The amended Reasonable Basis requirements now include wording that include the entire garment in addition to its component parts. Amended Section 423.6(c)(3) now reads:

(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; or...

This means that the lab test results or whatever basis you have to verify the accuracy of the care instructions you provide your consumers must not only be applicable to the individual component parts of the garment, but also to the garment as a whole. This amendment does not require testing the entire, completed garment so long as there is adequate reasonable basis for the garment as a whole, without testing. The amendment does stipulate, however, that testing of the components is not necessarily sufficient to comprise a Reasonable Basis if problems, such as bleeding or puckering, are likely to occur when the components are combined.

Because AATCC practices are so widely accepted the Commission has changed the definitions of water temperatures used on care labels to coincide with AATCC standards. The “cold?and “warm?are redefined, and, rather than add a definition for “very hot? the range of temperatures for “hot?has been redefined to include the AATCC ranges for “hot?and “very hot?together. Water temperature amendments are:

To section 423.1(d), the last sentence is amended to read: (d)…When no temperature is given, e.g. warm or cold, hot water up to 145 F (63 C) can be regularly used.

To section 423.6(b)(1)(i) now reads: (i) Washing. The label must state whether the product should be washed by hand or machine. The label must also state a water temperature ?in terms such as cold, warm, or hot ?that may be used. However, if the regular use of hot water up to 145ºF (63ºC) will not harm the product, the label need not mention any water temperature. (For example, “Machine Wash?means hot, warm or cold water can be used.)

Appendix A.1.a ?1.c, is replaced with section A.1.a. ?1.a ?A.1.d which read as follows:

Washing, Machine Methods:
a. “Machine wash?/b> ?a process by which soil may be removed from products or specimens through the use of water, detergent or soap, agitation, and a machine designed for this purpose. When no temperature is given, e.g., “warm?or “cold,?hot water to 145ºF (63ºC) can be regularly used.

b. “Hot?/b> ?initial water temperature ranging from 112 to 145ºF [45 to 63ºC]. c. “Warm??initial water temperature ranging from 87 to 111ºF [31 to 44ºC].

d. “Cold?/b> ?initial water temperature up to 86ºF [30ºC].

The Commission did NOT adopt the other two proposed amendments that would have required home washing instructions if possible, even if a dry cleaning instructions was provided and preferred, and that would have allowed a “Wetclean?instruction.

You can find all the most current labeling requirements on the FTC’s web site. The address for that portion of the FTC home page dedicated to textile and apparel labeling issues is:

And, of course, you can always contact your TextileIndustry Affairs representative for the latest on labeling regulations, compliance and consumer research.

Many manufacturers rely solely on their mill representatives to provide them with reliable care instructions for the fabrics they buy. The care labeling rule has been amended to require Reliable Evidence of care instruction accuracy applicable to the entire garment. So, if your products are made of more than a single fabric construction or of a single construction from more than one source, you need to know you can depend on the information the mills provide. The Federal Trade Commission still considers the responsible entity for care instruction accuracy to be the manufacturer or importer whose RN/WPL numbers appears in the garment.

The good news is that your mill sources can be held accountable for the care information they provide to you. Even though mills are not specifically covered by the requirements of the Care Label Rule the FTC recognizes that businesses make decisions based on mill representations. Mills have an obligation to make certain the information they provide is accurate and that they have a reasonable basis for their claims. If your care instructions are questioned by the FTC an important mitigating circumstance would be documented evidence that you acted in good faith based on information received from your mill source. You are still responsible for the accuracy of your care instructions, but you do have a reasonable expectation of reliability from your suppliers.

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