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printing, and finishing, and-Do you know how many kinds of fabric are for sale today? You don't, because no one does, but it's estimated there may be ten million.

And we're supposed to know how to get them clean?

Recognizing our problem, many clothing manufacturers put care instructions on the containers the clothes come in. Even more put this information on what they call hangtags, paper tags attached directly to the clothing. Theoretically we're supposed to keep these tags and, at cleaning time, remember which tage came with which item, referring to it each time we wash or clean the piece of clothing. Conscientiously done, this tag-keeping would turn the laundry room of a family of four into a filing cabinet and the woman of the house into a frantic file clerk. So, on the whole, we don't save these tags. Nor should we have to. If "easy care" means hard work, then it's not so easy. Besides all this, some of the language on the tags turns out to be more promotional than instructive. Many a woman has discovered that the phrase "Never needs ironing" could use the parenthetical warning: "If you don't mind looking a little wrinkled." And many a harrier housewife has had cause to wonder whether "permanent press' applied to the pleats put in by the manufacturer or the wrinkles she herself acquired later.

I recently bought a floor mat that came with a paper label reading: "Cleans Easily." Okay, but I had to write to the manufacturer to find out how, and with what.

Women trying to keep their families washed and cleaned and pressed aren't the only ones wondering what temperature of water, which method of drying, and how hot an iron (if any) to use or whether maybe dry cleaning was the answer in the first place. Professional laundries and, to a greater degree, dry cleaners need this information as much as we do.

The National Institute of Dry Cleaning, an association of 10,000 drycleaning firms, has a laboratory where it tests garments that have been ruined at the cleaner's. These are the items we've holiered about because they've lost their shap or body or color. If the cleaner has hollered back that he did everything right and it's not his fault, and he's a member of the NID, he can then send the botched-up garment to the lab for testing-to find out what went wrong.

In 1969, the NID lab tested 36,150 garments and found that 46 percent of the problems could be laid at the door of the manufacturer, either because he used incompatible items in a garment (such as two fabrics, bonded together, that weren't destined to stay bonded in any cleaning process) or because, though the fabric appeared to have been made or dyed or finished by a certain process, it was not. In other words, the garment should have had special handling; but in the absence of attached instructions, the cleaner had no way of knowing this.

The American Institute of Laundering has its testing laboratory, too, and its problems. Among its recent reports was one about a polka-dot dress it had examined. white dots on a black background. When the dress was machine washed at home, enough of the black dye faded and ran to muddy the white dots. Hand washing, which included some scrubbing, then worsened the effect. Dry-cleaning solvents tried as a last resort, caused the black background to fade and run even more. As the institute concluded its report: "This garment, then. might well have been labeled 'Hand wash only. Do not rub'-or might better never have been made."

What we all need-housewives and professionals alike is permanent care labeling. That means a label attached to every garment we buy, designed to stay. forever and ever, till the garment, not the label, wears out-with simply worded care instructions, either stamped on the item itself or sewn in on a woven or printed label.

But this poses problems. Who is responsible for seeing that the right information gets on the right shirt? Like the animals in "The Little Red Hen," "Not I," says the fiber maker. He doesn't know how or with what other elements his fiber will be woven. "Not I," says the fabric maker. He doesn't know how it's going to be dyed or finished. "Who, me?" asks the clothing manufacturer. Yes, you. Because you know, or can find out, the properties you're dealing with; and besides, in many garments, it's your decision as to what gets combined with the basic fabric-lining, trim, buttons, and so on.

Sometimes these elements aren't compatible, and yet how is the housewife in Denver supposed to know that? By the manufacturer's telling her, that's how. But why should the manufacturer take on this bother and responsibility? It's a simple matter to label an Orlon sweater, but it could be complicated in a dress combining several elements. Besides, it costs money-and there's the rub. In middle- or higher-priced items, the added cost of a label isn't going to affect the maker or the purchaser very much. But as the price goes down, the cost of the label represents a higher percentage of the total cost; and in low-priced items, where competition is rough, a difference of a couple of cents can mean a sale or no sale. And sale is the name of the game.

In 1966, when Esther Peterson was the official worrier for consumers in Washington, she established an Industry Advisory Committee, composed of people representing fiber, fabric, and apparel manufacturers, retailers, and dry cleaners and launderers. Their first mission was to develop a glossary of care terms that would fit on labels and be easily understood.

Two years later, they presented the glossary to me (when I was the official Washington worrier) and announced that they were going to make every effort to see that permanent care labels were used by industry, on a voluntary basis. Soon afterward, the American Apparel Manufacturers Association, representing 435 manufacturers, urged its members to adopt this plan.

But. though a trade association can urge, prod. and plead, it has no authority, no clout over its members. So what happens is that a few enlightened members decide permanent care labeling is a good idea, and they use it; but the few tend to be very few. And remember, it's only the organization's members who have been urged to take on this added trouble and expense. Even if they all complied, there would still be many manufacturers who weren't doing it, simply because they didn't have to.

There's also a hitch in the voluntary labeling plan itself. Permanent care labels are intended only for items that need special handling. If it's obvious how something should be cleaned-men's underwear, bath linens, wool suits, etc.-no label would be used. So, in the absence of a label, we might assume that what we're about to wash can be handled "normally." But there may be pertinent information that the maker simply hasn't given us. (It's still possible to buy a dress that seems to be cotton, wash it, then put a hot iron to it, and burn an iron-shape hole right through the fabric.)

Of course, fiber-content labeling should make such an accident avoidable, but fiber-content labeling isn't always done, law or no law. Even when it is, it doesn't always do the trick.

Recently I bought two blouses labeled "Dacron & Cotton." I thought I knew how to take care of them. But because the blouses were expensive ($16 and $20), I washed them by hand and put them on hangers to dry. Dried, both were full of tiny wrinkles. So I tried a touch-up with a cool and then a warm iron. Nothing. Both were unwearable.

I later had occasion to address some fiber manufacturers (an opportunity not given to every housewife with a ruined blouse), and in urging them to push for permanent care labeling, I showed them my blouses. It happened that the president of the store from which I'd bought the blouses was there. He took back one of them and sent me a replacement immediately, and the fiber people took the other, to see if they could get the wrinkles out. They did, and told me that if I had machine washed and tumble dried the blouse, and plucked it immediately from the dryer, the wrinkles wouldn't have developed. Or, with a steam iron, I could have got out the ones I had unwittingly put in. Swell, fellows, but where was the label telling me that?

Incidentally, if the blouses had been so labeled, I might not have bought them. One good reason for buying the "miracle" fibers is that they're so convenient when you're traveling. But, overpack though I do, I don't take with me either the necessary steam iron or yet a tumble dryer.

It's interesting to note that the store president didn't really think permanent care labeling necessary. He felt that his Fifth Avenue customers cared more about fashion that such mundane things as cleaning or laundering. I'm likely to stay closer to another Fifth Avenue store, where I got a pair of slacks with a woven label, sewn in, that read: "This is a washable fabric. Dry clean, or launder as follows: Use lukewarm water, no chlorine bleach, drip dry, do not wring or spin dry. Press lightly."

That's my kind of label.

Along with you and me, the Federal Trade Commission recently decided that the textile-care problem was getting out of hand and proposed a Trade Regulation Rule making it mandatory that every textile product used by consumers carry a permanent care label.

There's nothing that grabs the attention of an industry like the threat of being "regulated." Hearings were held, and some interesting (and funny) points were brought out.

By and large, all industries involved-fiber makers, fabric makers, clothing manufacturers, even the laundry and cleaning industries-were opposed to labeling all textile items; instead, they favored "exception" labeling. The exceptions would be textiles that require other than obvious cleaning methods (back to cotton, linen, wool, and silk). I'm persuaded that this is probably a good idea. I agree that the appearance of wall-to-wall carpeting would not be enhanced by a care level in the corner. And I think the man from Spring Mills had a point when he said: "The fact that both sides of a handkerchief are used prohibits affixing a permanent label sufficient to carry the required instructions and certifications. In addition, the label could scratch the nose." I'm even persuaded that men's socks don't need a label if they can be safely washed and dried in a machine.

It may also be true, as industry argues, that if every item we owned had a permanent label, we might become so used to them that we would ignore them, whereas exception labeling would act as a red flag and get our attention every time.

But just when I think an industry is indeed being responsive to consumer needs, along comes a man representing a knitwear manufacturer who says, "A industry which is dominated by fashion and is highly seasonal is faced with the fact that they make many fabrics without being completely sure how they will actually be called upon to perform, and they are pushed in this direction by the consumer" (emphasis added). What consumer? Name one. He goes on to say, "These innovated developments are the babies of the textile industry, and both the consuming public and the industry love them, though they must anticipate all the problems involved with these infants." I submit, Mr. Knitwear, that there's a basic difference between a regular infant and a textile infant. We can recognize the one on sight and know what to expect of it. That is not true of the other.

Happily, there are segments of industry that do not share this cavalier attitude. Montgomery Ward is about to see to it that all its wearing apparel has permanent care labeling, which it has designed. There will be 28 combinations of instructions in simple terms.

I asked why they're doing this, since it's costly and they don't, as yet, have to. "Because it's a good idea," they answered, "and inevitable."

Sears Roebuck, too, is totally committed to permanent care labeling. It does point out that the labeling can be difficult and even objectionable in such items as sheer blouses and lingerie, and it warns that when it buys high-fashion items from the open market for fast delivery, they may not all carry the labeling. But it assures me that all items made to its own specifications will have labels.

Though Montgomery Ward is moving ahead with the labeling plan, the vicepresident in charge of it isn't convinced that all of us want it, considering the attendant cost that will inevitably be passed on to us. He thinks the plan is a good idea, his wife thinks it's a good idea, and he knows I do, too, but he's not sure how much the whole problem has been bothering you.

The FTC has not come to a decision regarding its proposed rule. Why not let the commission know what you think? Should every textile item be labeled permanently? Or would you prefer exception labeling, to be used only when there cou'd be confusion about proper care methods? And which cost would you prefer to pay-the cost of the label in a lot of items where it doesn't now exist, or the potential cost of ruined garments?

As a representative from Montgomery Ward pointed out at the FTC hearings, "In our cost-competitive economy, it seems unlikely that permanent care labeling shall ever become widespread unless required by the government." The absence of government regulation can mean the absence of a lot of care labeling. The absence of a label can lull us into a sense of false security if we assume that no label means go ahead and wash it any old way.

So now is your chance to get in on the decision-making process. If you're tired of running a test lab in your own home, tell the FTC; or tell me, and I'll tell them.

Or if you think the subject doesn't warrant the fuss and feathers and costtell them that.

Either way, if you don't tell them, who's going to?

AMERICAN RETAIL FEDERATION,
Washington, D.C., May 14, 1971.

Hon. JOHN Moss,

Chairman, Subcommittee on Commerce and Finance,
House Committee on Interstate and Foreign Commerce,
House Office Building,

Washington, D.C.

DEAR MR. Moss: On May 10, the House Subcommittee on Commerce and Finance of the Interstate and Foreign Commerce Committee held hearings on H.R. 6143, a bill requiring that certain textile products bear a label containing cleaning instructions. The bill would make it an unfair method of competition and an unfair or deceptive act or practice to sell or import any textile product which does not have a permanent tag or label which discloses laundering cleaning instructions for such product which, if not followed, may result in the impairment of its utility or appearance. The Federal Trade Commission would have the power to enforce the provisions of the act.

The American Retail Federation is a national organization which, through its 50 state and 28 national retail trade association affiliates, represents more than one million retail establishments of all types across the country. We respectfully request that action on this bill be postponed until the FTC publishes final regulations on their care labeling proposals. The issue has been before the Commission for some time and we believe it would be more appropriate for the subcommittee to await their action on this complex issue.

If the subcommittee feels that this legislation should be acted upon, it is our hope that more hearings will be scheduled in order for industry experts to present their knowledge and expertise on this subject.

We would appreciate the inclusion of this letter in the hearing record.
Cordially,

EUGENE A. KEENEY,

President.

AMERICAN APPAREL MANUFACTURERS ASSOCIATION,
Washington, D.C., May 10, 1971.

COMMITTEE ON INTERSTATE AND FOREIGN COMMERCE,
U.S. House of Representatives,
Washington, D.C.

GENTLEMEN: On behalf of the membership of this Association, I hereby submit a statement of our industry's position as it relates to your bill requiring the permanent care labeling of all textile products. We would appreciate it if this statement could be made a part of your hearing record.

This statement was prepared and filed in response to a proposal of the Federal Trade Commission, March 17, 1970, which also proposed to require the permanent care labeling of all textile products. This industry document represents our industry response to the care labeling requirements proposed in H.R. 6143.

Our Association urges careful consideration of this complex proposal and the effects it will have on the apparel/textile/fiber complex of this Country. Respectfully submitted,

ELLIS E. MEREDITH, Executive Vice President.

OF

STATEMENT BY ELLIS E. MEREDITH, EXECUTIVE VICE PRESIDENT, ON BEHALF OF THE AMERICAN APPAREL MANUFACTURERS ASSOCIATION, PRESENTED AT THE FEDERAL TRADE COMMISSION PROCEEDING FOR THE PROMULGATION TRADE REGULATION RULES RELATING TO CARE LABELING OF TEXTILE PRODUCTS, MARCH 17, 1970

Mr. Chairman and Gentlemen, my name is Ellis Meredith, and I am Executive Vice President of the American Apparel Manufacturers Association located in Washington, D.C. Our Association has a membership of 435 apparel manufacturers with production in 43 states, doing an estimated annual volume of $9.5 billion in sales, at manufacturers' prices. We very much appreciate the opportunity to discuss with you today an area in which we have been actively involved since its inception: namely, permanent care labeling of apparel products.

My comments will be brief. They are directed solely to outlining, in summary form, a history of our concern for, and involvement in, the entire question of permanent care labeling for the apparel and textile industries. Our next witness will present for your consideration the specific recommendations we wish to make with respect to the proposed Trade Regulation Rules. His recommendations represent the best judgment of our membership generally and our Consumer Affairs Committee in particular.

The American Apparel Manufacturers Association is clearly committed to concern for the best interests and welfare of its members' consumers. As a prime mover in the area of voluntary establishment of permanent care labeling by the apparel manufacturing community, we ask that a long, hard look be taken at the record-the record of achievement in this field by both AAMA and its member firms. Action-positive, affirmative action-backed by three solid years of effort in this vital area should not, we believe, be overlooked or down-graded by this body.

No one is or has been more aware of, or more concerned with, proper care labeling of apparel products than AAMA and the membership we represent. The Association's record on permanent care labeling is, we think, a good one, an enlightened one, one that supports our total commitment that what's good for our consumers is good for us and what's bad for our consumers will either immediately or ultimately be bad for us.

As early as 1966, AAMA was a moving force in the industry-government discussions which culminated in formation of the Industry Advisory Committee on Textile Information-a special industry-wide committee which worked with the President's then-Advisor for Consumer Affairs, Mrs. Esther Peterson, in developing a guide for sound care labeling practices for the apparel and textile industries.

In fact, it was at my personal initiative that a representative inter-industry delegation called on Mrs. Esther Peterson to discuss a possible voluntary approach to the care labeling problem. That approach was made in a sincere spirit of cooperation and not under any duress or compulsion of any kind.

Through extensive and exhaustive liaison with the IACTI, AAMA assisted in formulating the initial Industry Guide for the Voluntary Improvement of Permanent Care Labeling of Consumer Textile Products.

This initial guide, accepted by Miss Betty Furness, Mrs. Peterson's successor and then-Special Assistant to the President for Consumer Affairs, was incorporated into a comprehensive care labeling packet, published by the Association and numerous manufacturing firms, which received industry-wide distribution and attention. This intensive effort, praised by Government and industry alike as a landmark of voluntary inter-industry cooperation to help meet a clear-cut consumer need, has resulted in an ever-increasing practice of permanent care labeling, conciseness and uniformity of terminology and clearly demonstrated our industry's continuing concern for consumer satisfaction.

As you know, the IACTI has been re-named the Textile Advisory Committee on Consumer Interest. By continuing the work of this Committee as an independent group concerned with meeting consumer needs, we believe our industry, and its sister industries, can continue demonstrating their interest in meeting consumer responsibilities without abrogating his responsibility to Government. Equipped through its work with IACTI, with full cognizance of the need for consumer-oriented industry guidance in this area, AAMA pioneered in 1967 with the establishment of the Association's Consumer Affairs Committee-a

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