UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

600 PENNSYLVANIA A VENUE, NW

WASHINGTON, D.t. 20580

Division of Enforcement

Bureau of Consumer Protection

August 5, 2002

John S. Rode

Rode & Qualey

295 Madison Avenue

New York, New York 10017

Dear Mr. Rode:

I am writing in response to your request for an advisory opinion on behalf of Amicale

Industries. I apologize for the delay in response.

Your letter describes in detail Amicale's quality control procedures in the manufacture of

cashmere and cashmere/wool blend fabrics. The letter then asks whether these proGedures

constitute "due care" as the tenn is used in the Wool Products Labeling Act. The relevant

language of the statute reads as follows:

Provided, That deviation of the fiber contents of the wool product from percentages

stated on the stamp, tag, label, or other means of identification, shall not be misbranding

under this section if the person charged with misbranding proves such deviation resulted

from unavoidable variations in manufacture and despite the exercise of due care to make

accurate the statements on such stamp, tag, label, or other means of identification.

15 V.S.C. § 68b(4)(a)(2)(A).

The Commission's Rules of Practice, 16 C.F.R. § 1.1(a) state: "Any person, partnership,

or corporation may request advice from the Commission with respect to a course of action which

toe requesting party proposes to pursue." The Rules further state: "Hypothetical questions will

not be answered, "

Amicale's quality control procedures, as described in your letter, appear to be exemplary.

Indeed, such procedures should ensure that fabrics manufactured by Amicale are accurately

labeled with respect to fiber content.
John S. Rode, page 2

However, your letter does not set forth a proposed course of action for which an advisory

opinion would be relevant or appropriate. The procedures described are Amicale's general

business practices, which presumably have been in effect for some time. Weare aware of no

allegation or suggestion that any of Amicale's products are improperly labeled. Therefore, there

is no question for which a Commission or Commission staff advisory opinion would be

appropriate.

We do appreciate Amicale's high level of concern and attention to labeling issues and its

care in adhering to manufacturing and testing procedures designed to ensure accurate labels.

Pursuant to Section 1.4 of the Commission's Rules of Practice, 16 C.F.R. § 1.4, your

letter, together with this response, will be placed on the public record.

Sincerely yours,

~ ~ 9~1-n?""- ~~

Carol J. Jennings
]OHN S. RODE

MICHAEL S. O'ROURKE

PATRICK D. GILL

R. BRIAN BURKE

WILLIAM]. MALONEY

WASHINGTON OFFICE

1742 N STREET, N.W

WASHINGTON, D.C.

TELEPHONE: (202) 223-0957

FACSIMILE: (202)785-2210

M ILYAS KHAN, OF COUNSEL

(ADMITTED IN PAKISTAN)

KARACHI, PAKISTAN

TELEPHONE: (92-21) 5685541

FACS1MILE: (92-21) 5683050

ATrORNEYS AT LAW

295 MADISON AVENUE

NEW YORK, N.Y. 10017

TELEPHONE: (212) 685-4437

FACSIMILE: (212) 213-3206

E-MAIL: TRADELA W@AOL.COM

ELEANORE KELLY-KOBAYASHI WWW.RODE-QUALEY.COM

December 6,2001

Division of Enforcement

Bureau of Consumer Protection

United States Federal Trade Commission

600 Pennsylvania Avenue, N. W.

Washington, D.C. 20580

Re Labeling of Woven Fabrics Produced From 100% Cashmere Yarns

and From Blended Cashmere and Wool Yarns

Dear Sir:

Amicale Industries, Inc., with headquarters at 1375 Broadway, New

York, N.Y. 10018, is a leading maker of cashmere fabrics in the United States and is

the largest cashmere merchant in Europe; Amicale has asked us to seek your advice

with respect to the labeling of the woven fabrics they produce from yarns spun by

Amicale from cashmere and wool fibers at Amicale's fabric division in the United

States. All of these fabrics fall within two general categories: fabrics produced from

yarn spun from 100% cashmere fibers, and fabrics made from blended yarn spun

from cashmere and wool fibers. The blended yarns used to produce the latter

category are most frequently spun from 50% (by weight) cashmere and 50% (by

weight) of wool fibers, although Amicale often spins blended yarns to the order of
their customers, in which the proportion of cashmere to wool is other then 50/50,

e.g., 80% cashmere, 20% wool.

Amicale, established. over fifty years ago, follows the Rules and

Regulations issued under the Textile Fiber Products Identification Act and the Wool

Products Labeling Act, as well as the dictates of the commercial market for 100%

cashmere and cashmere/wool blended products, and has accordingly devoted

substantial time and resources to ensure that the articles produced by Amicale meet

or exceed all applicable legal and commercial requirements. To that end, upon

which their worldwide reputation depends, Amicale rigorously controls all phases of

their production from raw material procurement through finished goods. Our client

is able to exercise such control because their production is vertically integrated,

unlike some of their competitors, who must relinquish control over their materials

and intermediate products at various stages of production, and send such materials

and intermediate products to unrelated mills for the performance of manufacturing

operations which they cannot conduct in their own facilities.

Consequently, and perhaps uniquely, when Amicale delivers a finished

fabric to one of its customers, our client is in a position to represent, accurately, that

every step in the manufacture of that product was accomplished within the facilities

owned, operated, and supervised directly by Amicale

Cashmere and Wool Fiber Procurement

Amicale purchases cashmere fibers from three principal sources:

2
1. Amicale obtains Mongolian cashmere from its joint venture with

the government of Mongolia, Mongol-Amicale, which was established in 1990.

Mongol-Amicale purchases the raw cashmere directly from the herdsmen through a

chain of over twenty regional warehouses; this fiber is transported from those

warehouses to the Mongol-Amicale factory in Ulaan Baatar, where every kilogram

of raw fiber is hand-sorted and examined, tested in the joint venture's laboratory,

scoured, dehaired, baled, and then shipped to Amicale's wholly-owned subsidiary,

W. Fein & Sons Limited, in Bradford, U.K.

2. Amicale has an office in Inner Mongolia, China, which is

supervised by the former head of the Export Section of the Cashmere Department of

Inner Mongolia. This office of Amicale draws samples from every lot of Chinese

cashmere which is offered for purchase, and forwards those samples to the

laboratory of W. Fein & Sons Limited for testing. If a sample meets Amicale's

quality standard, the office in Inner Mongolia is then authorized to purchase the lot

from which that sample was drawn, and arrange for delivery of the approved lot to

Amicale in Inner Mongolia, where the fibers are again inspected before shipment of

the Chinese cashmere to W. Fein & Sons Limited in the United Kingdom.

3. Amicale also acquires cashmere fibers from other sources,

principally raw cashmere offered on the "spot" market in Euroli>e; samples of these

shipments are tested at the laboratories of W. Fein & Sons Limited, and fibers

purchased on the spot market are usually shipped to W. Fein & Sons although, on

occasion, such fibers may be shipped directly to Amicale in the United States.

Amicale also purchases wool fibers for their use in blending; as with

cashmere fiber purchases, the wool is inspected, sampled, and tested by Amicale,

3
~ODE & QUALEY

and, as is done with Amicale's cashmere fiber, all lots of fiber are segregated by lot

number until withdrawn from inventory for further manufacture. When such fibers

are shipped to Amicale's fabric division in Charlotte, North Carolina, whether

shipped by W. Fein & Sons or from other sources, each fiber lot is inspected and

tested by the Quality Control Laboratory at Amicale North Carolina and is then

placed in inventory until required for production. Amicale maintains records of all

examination, sampling, and testing, whether performed in Mongolia, in China, at

W. Fein & Sons, or in North Carolina, and maintains lot number integrity

throughout its manufacturing processes.

Fabric Production

Production in the United States of 100% cashmere fabrics and of

blended cashmere/wool fabrics begins with the withdrawal from Amicale's inventory

in North Carolina of selected lots of cashmere and, in the case of blended

cashmere/wool fabrics, wool fibers. If the desired end product is, for example, a

50/50 cashmere/wool fabric, equal quantities of each fiber will be selected from our

client's inventory, typically 1,000 pounds of cashmere fiber and 1,000 pounds of

wool fiber. The lot numbers of the selected cashmere or cashmere and wool fibers

are recorded, and these fibers are then blended after a mixture of oil and water

equal to approximately 6% of the total weight of fibers has been added. The oil in

this mixture lubricates the individual fibers so that they will be evenly mixed, and

the water provides moisture which minimizes breakage of the individual fibers

.during the mechanical blending process. When the cashmere or cashmere and wool

fibers have been blended to the satisfaction of the Amicale North Carolina Quality

Control Laboratory, the resultant blend is carded into the form of a web, the web is

converted to sliver form, and the yarn is then spun. The finished yarn is then

4
tested to ensure that the yarn is uniform throughout, that is, that the different

length cashmere or cashmere and wool fibers are evenly distributed throughout the

full length of the yarn which has been produced; if the yarn contains both cashmere

and wool fibers, it is further tested to ensure that the two fibers are evenly

distributed in the 50/50 or other specified proportions, as appropriate, at all points.

Amicale notes that the different characteristics of cashmere and wool

fibers, particularly the fiber diameter which, in the case of cashmere, ranges from

14.5 to 16.5 microns, with a maximum of 17 microns, in contrast to the diameter of

wool fibers which exceeds 18 microns, requires particular care in the mixing of these

fibers to yield a uniform blend throughout the yarn run, and necessitates laboratory

testing of the finished yarn to ensure that, whether it is a 50/150 or other blended

yarn, the total variation over the run does not exceed 1-2%.

Mer spinning the 100% cashmere or blended cashmere and wool

fibers into yarn, and upon completion of testing to ensure that every finished

blended yarn does not deviate significantly from the specified proportions, the 100%

cashmere or blended cashmere/wool yarns are then woven into fabrics within the

facilities of Amicale North Carolina. As a consequence, Amicale is able to maintain

complete control over this final stage in the production of 100% cashmere and

cashmere/wool blended fabrics, and, as in each of the preceding production stages,

Amicale is able to ensure that no materials other than the tested yarns spun by

Amicale are introduced into the finished fabrics. The finished fabrics are, in fact,

made from and composed solely of the yarn spun by Amicale from the cashmere and

wool fibers maintained in our client's inventory; our client's strict control over all

phases of manufacturing eliminates any possibility of the introduction of any other

non-specification yarns or fibers.

5
l\ODE & ~UALEY

Amicale's Laboratory Eguigment and Personnel

The quantity of cashmere fibers purchased by Amicale, coupled with

the volume of production at our client's integrated facilities, has led Amicale to

conclude that they cannot depend upon outside laboratories to conduct the

quantitative and qualitative testing and analyses at each of the stages of

procurement and manufacture of these high-quality luxury fabrics which our client

has determined are necessary for the production of 100% cashmere and blended

cashmere/wool fabrics which will meet the standards of Amicale and its customers.

While Amicale does use outside laboratories for some purposes, the scale and

volume of Amicale's manufacturing operations are viewed by our client as

sufficiently great enough to warrant the investment in appropriate equipment and

qualified personnel at their facilities in Mongolia, the United Kingdom, and North

Carolina.

The testing performed in Amicale's laboratories is conducted in

accordance with the standards and methods used by accredited independent

laboratories; in particular, Amicale's laboratories follow all applicable Standards

and Procedures approved by ASTM and the Cashmere and Camel Hair

Manufacturers Institute, of which latter organization the President of Amicale,

Boris Shlomm, is one of the two co-founders. Attached to this letter, as Exhibit A, are

lists of the equipment maintained in each of Amicale's laboratories, as well as lists of

.the personnel employed in each of those laboratories, with a summary of their

experience and qualifications.

6
Conclusion

Amicale believes, based upon over fifty years of experience in the

production of 100% cashmere and cashmere/wool blended yarns and fabrics, that they

take appropriate steps to ensure that all of their cashmere and cashmere/wool yarns

and fabrics will not vary from their stated fiber content for any reason other than "a

small amount of unintended inconsistency in the manufacturing process," for purposes

of the Textile Fiber Products Identification Act, or "unavoidable variation in

manufacture despite the exercise of due care to make accurate the statements" on

their labels, for purposes of the Wool Products Labeling Act. We would very much

appreciate your advising us whether, on the basis of the information set forth above in

this letter and the material included in Exhibit A, you would agree that the

procedures followed by Amicale constitute "due care" to ensure the accuracy of the

labels applied by Aniicale to their finished 100% cashmere and blended cashmere/wool

In the event you need additional information about the yarns and fabrics fabrics.

produced by our client, please do not hesitate to call me at your convenience

JSR/cps

Enclosure

7
Nov'-13-01 03:31P P.~2

13-t--OJ-2001 10:~ FR(J1 lJ F=E I N ~ S!J-IS TO ~I~ P.O2/16

Q~a1ity Cobtrol PenoDQel & EouinmeDt/P~cedura at Mouaol-Amicale.JY

QC O~rativ.£~

Tumendemberel- Raw Materials Manage!

1.

2.

3.

4.

5.

6.

.,.

8.

9.

1O.

Bulgan -Sorting

Badamsetseg -Sorting

Munkhzul -Sorting

Otto Suren -Scouring

Horol Suren -Scouring

Bolonuya -Scourinj

Alginnaa -QC Mllnaaer/Dehairing/Press Control

Enkhtungalag -Dehairiu&fPress Control

Unmchimig -Carding/Spilming

Z 0 1 tuy a -C aring/ S pinning

~guinment Used in Laboratorv:-

Micron -Projectina Microscope

Micron -Summa Sketch 3

Scollrini -WlRA Grease Extractor

Scouring -Soxhlet ApparatuS

Scow-jng -Precision Economy Oven

Scouring -AND Moisture Determinine Balancc

Dehairing -Alfred Suter Co. Length Tester

Carding/Spinning -Henry L Scott Strength Tester

Carding/Spinning -Twist Tester

Carding/SpiMing -Brown 81. Sharpe Count Tester

Carding/Spinning -James H Heal Strength Tcste:r

CaJ-dingiSpinning- CCV Teater

Carding/Spinning -Uster Tester 3

Carding/Spinning -WtRA Graphing Balancc:

Carding/Spinning -Uster Roving Sensor

Electronic Balance x 3
Nov-13-0103:32P

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..~ t.J FEIN AtJD 50'S TO ~ICALE P.04/16

Quality Control Laboratory

W. FEIN & SONS LIMITE!)

Lahoratorv ~uilment

WIRA Rapid oil content tester

HC31's wrap reel

Black boards I whitc boards I velvet board

Uster Automatic ~omctc (Str8nith and Elonaation)

Us~er Evenness tester

Heal'! Two-fold tWist tester

SUter comb ~orter

WIRA Fibre fiDCDefS mI;ter

Torsion balance

Digital bWance

Heal's conditioning oven

Heal's ayrow.sh.

Bausch and Lomb projection mieroscope

Sample card

Sampl~ spinne::r

Streat electroni~ moisture meter

ElectrOnic moisture probe

Li~ cabinet

Fumc cupboard

Hot plat~

various chemicals (for oil extncUon, dye mipping, scouring)

Matsuya 12 gaugc knittini roacbine

Tritex LT1OI 5 puge circl\latbUningmachlnc

10 gauge strap knitting machine

Air condjtioD~ laboratory

Comnute'r:
Nov-13-0103:32P

J...)-~1-,,-~1 l~: ~ ~~ W I-clN ru~ 5()£ P.~5 TO 1:t1ICALE P.05/16

Julie Ann Smith

Quality Control Manaler

Responsibilities .Oreanisation and day.to-day running of the Quality Control l.aboratory

.Monitoring of dehai red cashmere and yarn quality to ensure that the

reQuired standards are met.

Education and Qaaaliftcations 1983-1990 Lanpands Community College, St. N8otS~ Camba.

Three A' levels (advanced leve'). one O' 'evel (ordinary level) and Eight GI:SE's

(Genera! certificate of secondary .ducatlon:,

The University of Hudder5field. Huddersfi.ld, West Yorks. 1990-1994

BEng. (Bachelor of Enlineering) In I-extile Manufacture with Clothing Studies

Upper second class honours degree

(subjects incorporated. yarn and fabric: manufacture, computing, enginecring,

instrumentation and control, management, mate(ials science. product

evalu~tion, textile manUfacturing and developments, indu5trlat training).

Work Experience F'ebr.Sept.1993 J. H. Walker Limited, ~.n.thorp8, West YorksIfldustrial training as part of the BEng. Textile Manufacture degree cour~le.

Quality Control Assistant responsible for the daily monitoring of weft krntted

fleece and leisure wear fabrics. Other duties involved colour matching,

compiling fabric reports, 3S51sting with product development. producing fabric

performance standards and product specifications.

March 1995.Present da, W. 'ein" Sons Limited, Bradford, West Yorks.

Quality Control Ma"ag~r .Orpnisation and runntng of the Quality Control

Laboratory. Monitoring of quality standards, dehaired fibre purchases 3"d

assisting in the assessment of greasy and scoured material.

Training Oct. 1115 YocOltl-McCoIl TestiftC laborltoraH (Denver, USA)

One we~k training tl> use The Suter Comb Sorter (fibre length) and fibre

id~ntification and measurement using a projection microscope, OFDA a,d

Laserscan

Nov. 2001 Yorkshi,. Post Tralninc, Leeds, West Yorks.

"I nsight to Mansgement" Management training course.
~ r t<U'1 I" I- ~ I N ~ND :;LJ"S TO AMICALf:: P.06/16

Claire Loui.e Armital8

Job Title

Quality Control Laboratory Technician

Reapon;i billtles

.Daily monitoring of dehalred cashmere quality.

.Routine te~ting of cashmere fibre to ensure required standards are m~t

.Perform tests to ensure that yarn proces$ed by commission dyers an(i

spinner'Sc meets required $tandards.

Edueatlon Deta11s

1"6~19'4 Hanley High School & Stxth Form Centre

One A' Level (advanced level), ten GCSE's (General certificate of second~ry

education). City & Guilds (Information Technology) and RSA (Royal SOClf!ty of

Arts) (D~sk top pub/ishini).

1997-2000 Modern ApprenticeshiP

8TEC (8usinesfo Technical Education Council) National Certificate in Textile

Technology

BTEC Higher National Certificate in Textile Technology

NVQ (Nationa[ Vocational Qualification) in Manufar..-turing Textiles (1extile

Laboratory Technician)

NEBS (National Examination Board) Management

Trainee of the Year BTEC Natlonat Certificate Year 2. 1998

Trainee of the Year BTEC ~igh8r National Certificate Year 1 .1999

John 5 Dryer Cup for Innovation of Raw Materia! -1999 & 2000.

Work Experience

Oct 1990 R. Butterworth .& Sons (Hudder$field W Yorks)

School work experience. Observed and took part in various practices around

the spinning mill, conc&ntrating mainly on the twisting operation.

Oct 1994-Mar 1196 Patons RTN (Huddersf1eld W Yorks)

Trained as a y~rn colour matcher at ths carding and spinning mill

Mar 1996-Present Day W. Fein ..Sans (Bradford W Yorks)

Trained as a Quality Control Laboratory Technician at the Ceshmer8

Dehairers.
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