United States of America

FEDERAL TRADE COMMISSION

Washington, D.C. 20580

Office of Commissioner

Rohit Chopra

To: April Tabor

From: Maria Bazan

Date: September 24, 2020

Re: Care Labeling Rule NPRM: Comments to be placed on the public record 

On September 17, 2020, Commissioner Chopra, Erie Meyer, and I met with Brian Wallace, CEO 

of the Coin Laundry Association (CLA) regarding the Federal Trade Commission’s Notice of 

Proposed Rulemaking regarding the repeal of the Care Labeling Rule.

During the meeting, Mr. Wallace informed us that there are approximately 30,000 laundries 

across the United States. Ownership in this industry is largely fragmented; most industry 

participants are small mom-and-pop businesses and only a handful of companies own more than 

50 stores. 

The majority of the CLA’s members fall into one of two categories: self-service laundromats and 

full-service laundries, each of which would face different constraints if the FTC repealed the 

Care Labeling rule. Full-service laundries, which make up just over half of the CLA’s members, 

rely heavily on care labels to determine how they should treat the garments that customers 

entrust to their care. Textiles are becoming more complex and often contain a blend of various 

types of fibers or dyes. Without the instructions from the manufacturer, it is difficult to know the 

appropriate temperatures or detergents to use or avoid when cleaning a garment. 

When items are damaged in the wash, upset consumers often turn to the launderers because they 

are the last people to handle the garment. These disputes are usually resolved by looking at the 

care labels to determine whether the employee followed its instructions properly. In such cases, 

care labels shield businesses from liability when they are able to show that they followed the 

correct procedure. 

Care labels also help full-service laundries minimize the damage to their relationship with 

customers who may otherwise lose trust in their services when one of their belongings is 

damaged. While losing one client may not seem eventful, Mr. Wallace noted that almost one 

third of the CLA’s full-service laundry members cater to commercial accounts, such as 

restaurants, gyms, or local first responders. For businesses who serve a limited number of large 

accounts, losing one contract could have a substantial impact on their profits for that year. 

Self-service laundromats would not be affected in the same way as full-service laundries because 

their employees are usually not involved in helping customers wash their clothes. However, Mr. 
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Wallace warned that the FTC’s decision to repeal the Care Labeling Rule would affect their 

clients disproportionately. Self-service laundromats typically serve consumers who are unable to 

purchase or afford in-unit washers and driers, many of whom are renters or low-income 

households who earn less than $40,000 per year. These customers may not have the disposable 

income to continue replacing items when they are damaged in the wash, so they rely on care 

labels to extend the life of their clothes. 

The CLA opposes the FTC’s proposal to repeal the Care Labeling rule and believes this decision 

would hurt consumers.