BEFORE THE FEDERAL TRADE COMMISSION WASHINGTON, D. C. : CARE LABELING OF TEXTILE PRODUCTS AND LEATHER WEARING APPAREL

by Bruce Yandle on September 24, 1976
by Bruce Yandle, James C. Miller, William Lilley and Peter H. Lowry

On January 26, 1976, the Federal Trade Commission (“FTC” or “Commission”) proposed a revision of rules relating to Care Labeling of Textile Products and Leather Wearing Apparel (41 FR 3747). The proposed revision relates to a current Trade Regulation Rule, viz., Care Labeling of Textile Wearing Apparel, first published in the Federal Register on November 4,1969 (34 FR 17776), and in effect since July 3, 1972.

The proposed revisions extend coverage of care labeling to include suede and leather wearing apparel, household furnishings, piece goods and yarn, carpets and rugs, and intermediate components. In addition to extended coverage, the proposed rules give detailed requirements regarding the nature of care instructions, provide definitions of terms and describe specific conditions for exemption and waivers of the regulation.
The Council appreciates the seriousness of the FTC inquiry being undertaken with regard to care labeling. The Commission’s concern is clearly evidenced by its detailed summary of findings and the nature of questions raised in the announcement of the proposed rules. We also appreciate the value of information in complex markets and recognize
merit in assisting consumers in their search for maximum value. At the same time, we recognize there are practical limits to be considered where the cost of providing information be9ins to exceed potential benefits. In addition, labels can be so specified as to create confusion in the market, thereby misinforming the consumer. There are also consumers who
provide their own specifications for textile products, and thus have
little need for additional labels. To impose added net costs in these
situations would tend to be inflationary. There are trade-offs to consider.

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