Creating a New Care Label for

Environmentally Friendly Professional Wetcleaning:

Why Reliable Evidence Supports Its Required Use

March 28, 2014

Federal Trade Commission Roundtable

FTC Conference Center

601 New Jersey Avenue, NW

Washington, DC 20001

1

Peter Sinsheimer, Ph.D., MPH

Executive Director

Sustainable Technology & Policy Program
Definitions: 

Dry Cleaning and Professional Wet Cleaning 

Dry Cleaning

A commercial process by which soil is removed from products or specimens in a 

machine which uses any solvent excluding water (e.g., petroleum, 

perchloroethylene, silicone, glycol ether, carbon dioxide, or aldehyde). The 

process also may involve adding moisture to the solvent, up to 75% relative 

humidity, hot tumble drying up to 160 degrees F (71 degrees C) and restoration 

by steam press or steam-air finishing. 

Professional Wetcleaning

A commercial process for cleaning products or specimens in water carried out by 

professionals using special technology (cleaning, rinsing, and spinning), 

detergents, and additives to minimize adverse effects, followed by appropriate 

drying and restorative finishing procedures. 

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Why is professional wet cleaning environmentally friendly? 

Technology

Human Health & 

Environmental Hazard

Air 

Regulations Health Regulations

Fire 

Regulations



Professional 

Wet Cleaning

▪ None Identified N/A ▪ Choose cleaning agents

to min env impact 

N/A

CO2▪ None Identified N/A ▪Fee on CO2volume ▪ Permit 

Petroleum ▪ Neur/eye/skin/resp irr

▪ Pers & aqu tox concern

▪ Mixtures of contain 

▪ Regulated

▪ Emits VOCs

▪ Registration 

▪ Fee for haz waste 

generated

▪ Permit 

▪ Combustible 

(Class IIIA)

GreenEarth ▪ Susp carc & repro tox

▪ Liver/immune/nerv sys 

▪ Persist in env

▪ Regulated

▪ Registration 

▪ Fee for haz waste 

generated

▪ Permit 

▪ Combustible 

(Class IIIA)



PCE ▪ Carcinogen 

▪ Liver/kidney effects

▪ Neurotoxicity

▪ Pers in the env.

▪ Regulated

▪ Permit 

▪ Phase out 

▪ Fee for haz waste 

generated

N/A

nPB ▪ Repro and dev tox

▪ Neur/eye/skin/resp irr

▪ Regulated

▪ Permit 

▪ Fee for haz waste 

generated

▪ Flam(Class I), 

NFPA rating 3

(Cite: Adopted from Alt Assessment, S.F Dept Env) 3
Professional Wetcleaning Process/Equipment

Computer-Controlled Washing

• Machine drying - precise 

moisture control 

• Air drying – expose 

garments to ambient air

• Gentle agitation 

simulates hand 

washing

• Low water level and 

low temperature

 Moisture Sensor Drying

Dispensing System: Programmed to dispense precise amount of 

cleaning agents mixed with water

Cleaning Agents

• Detergents

• Conditioners 

• Sizing

Tensioning Presses: used to enhance restoration of 

constructed garments

(9 manufacturers)

(7 manufacturers)

(8 manufacturers)

(8 manufacturers)

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Overall Findings on Commercial Viability of 

Professional Wet Cleaning

Initial Study: 2000-2004

• Dry cleaners switching to professional wet cleaning able to successfully wet clean 

over 99% of the ‘Dry Clean’ and ‘Dry Clean Only’ labeled garments.

• Operating costs and electricity use significantly lower after switching to PWC.

Validation, Consistency, Generalizability: 2005-Present

• Across equipment models and detergents.

• Across geography – throughout California, Mass, etc., across income levels.

• Over time – 2000 to present.

Created Profession of Professional Wetcleaning

• Skill set to successfully process full range of sensitive items labeled ‘DC’ or ‘DCO’.

• Experience and expertise to accurately predict success or failure of new apparel in 

professional wet clean process.

• Professional Wetclean Association. 5
Should the FTC require or allow the use of a new 

‘Professional Wetclean’ label?

• FTC legal standard for requiring use of a particular care label: 

– Must show:

(1) The failure to list the method is prevalent.

(2) The failure to list the method is deceptive or unfair.

(3) The response of requiring a label must be 

appropriate and cost effective to address unfair or 

deceptive practice.

* 65 Fed. Reg. 47261, 47269 (August 2, 2000) 6
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st Criterion for requiring a label: Is the failure to list a 

method prevalent?

• 99+% apparel labeled ‘DC’ or ‘DCO’ successfully professionally wetcleaned.

• In US, not legal to label of garment ‘Professional Wetclean’.

• What if ‘Professional Wetclean’ label is allowed but not required?

• ISO developed PWC label in 2007. Allowed to be used throughout Europe.

• Perfect natural experiment: Search countries where ISO ‘Professional Wetclean’ 

label allowed for prevalence of label six years after label allowed.

FTC Legal Standard for Requiring a Label 7
On-line search of apparel company web sites where ISO 

‘Professional Wetclean’ label is permitted

FTC Legal Standard for Requiring a Label 8
2

nd Criterion for requiring a label: Is failure to list a 

method deceptive and/or unfair?

• Criteria FTC uses to determine practice is deceptive

– Likely to mislead,

– to a reasonable consumer,

– that is material.

• Criteria FTC uses to determine practice is unfair

– Substantial injury to consumers,

– not outweighed by countervailing benefits to the consumer or to 

competition,

– which consumers themselves could not have reasonably avoided.

FTC Legal Standard for Requiring a Label 9
• Harris Interactive commissioned to conduct online survey within the United 

States between September 18-20, 2013 among 2,000 adults (aged 18 and over). 

• Survey questions developed by the UCLA Sustainable Technology & Policy 

Program and Harris. 

• Harris adjusted questions and potential responses to increase clarify and reduce 

unintended bias. 

• Respondents for survey selected from among those who have agreed to 

participate in Harris Interactive surveys.

• Figures for age, sex, race/ethnicity, education, region and household income 

were weighted where necessary to bring them into line with their actual 

proportions in the population. 

FTC Legal Standard for Requiring a Label

Harris Interactive Consumer Survey of 

Professional Care Label Options

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Q: When you see a garment with a care label that says ‘Dry Clean’ what do 

you think it means? (n=1,191 users of prof. cleaning service) 

0%

10%

20%

30%

40%

50%

Dry cleaning is the only

method for cleaning the

garment.

Dry cleaning is the

recommended method for

cleaning the garment.

Dry cleaning is just one

reliable method for

cleaning the garment but

other methods may also

be appropriate.

Don’t know

FTC Legal Standard for Requiring a Label

Harris-UCLA Consumer Survey

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Q: Have you ever heard of “professional wet cleaning”? 

(n=1,191 users of prof. cleaning service) 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

Yes No Not sure

FTC Legal Standard for Requiring a Label

Harris-UCLA Consumer Survey

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Information on Professional Wetcleaning

For the next few questions please read and consider the following information.

“Professional wet cleaning” is an alternative to dry cleaning and involves professional 

cleaners using water and special technology to clean garments typically labeled ‘Dry 

Clean’ or ‘Dry Clean Only.’

The United States Environmental Protection Agency (EPA) has encouraged dry cleaners 

to add or switch to professional wet cleaning because the process is non-toxic, 

eliminating the use of dry clean chemicals used at most cleaners that the agency 

considers to be harmful to human health and the environment. 

University research has shown that cleaners making the switch are able to successfully 

wet clean the full range of ‘Dry Clean’ and ‘Dry Clean Only’ garments they previously 

dry cleaned and do so at a comparable cost.

The Federal Trade Commission (FTC), which considers professional wet cleaning an 

environmentally friendly alternative to dry cleaning, has proposed adding a new 

‘Professional Wet Clean’ care label.

FTC Legal Standard for Requiring a Label

Harris-UCLA Consumer Survey

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Q: Imagine you owned a garment labeled “Dry Clean or Professional Wet 

Clean” and the quality and cost of the two cleaning methods were the 

same. Which of these two professional cleaning methods would you 

prefer using for this garment? (n=1,191 users of prof. cleaning service)

0%

10%

20%

30%

40%

50%

60%

Dry cleaning Professional wet

cleaning

Not sure

FTC Legal Standard for Requiring a Label

Harris-UCLA Consumer Survey

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Q: How significant, if at all, is avoiding the environmental and human 

health impacts of dry cleaning in your preference for professional wet 

cleaning? (n=659 users of prof. cleaning service who preferred professional wet cleaning)

0%

10%

20%

30%

40%

50%

60%

Very significant Fairly significant Somewhat

significant

Not at all significant

FTC Legal Standard for Requiring a Label 15

Harris-UCLA Consumer Survey
Q: If the cleaner(s) you typically use were not able to professionally wet 

clean a garment you owned that was labeled ‘Dry Clean or Professional 

Wet Clean’, how willing, if at all, would you be to use a different cleaner 

which was able to professionally wet clean this garment (instead of dry 

cleaning it) if the price, quality, and location of this cleaner were 

comparable to the cleaner(s) you typically use? 

(n=659 users of prof. cleaning service who preferred professional wet cleaning)

0%

10%

20%

30%

40%

50%

60%

Very willing Somewhat willing Somewhat unwilling Very unwilling

FTC Legal Standard for Requiring a Label 16

Harris-UCLA Consumer Survey
Q: Which of the following garment care labels would make you more likely

to want to professionally wet clean a garment?

(n=659 users of prof. cleaning service who preferred professional wet cleaning)

FTC Legal Standard for Requiring a Label 17

Harris-UCLA Consumer Survey
Evidence that failure to list ‘Professional Wet Clean’ on 

label is deceptive

Likely to mislead,

– ‘Dry Clean’ label extremely misleading and biased to dry cleaning.

to a reasonable consumer,

– Survey of US population using professional cleaning services.

that is material.

– Strong consumer preference for professional wet cleaning (55%) to dry 

cleaning (18%).

– Preference based on value of avoiding harm to the environmental human 

health.

– Preference strong enough that vast major willing to switch cleaners.

– Consumers with preference for professional wetcleaning less likely to act on 

their preference if words ‘Professional Wetclean’ omitted from the care label.

FTC Legal Standard for Requiring a Label 18
Evidence that failure to list ‘Professional Wet Clean’ on 

label is unfair

Substantial injury to consumers,

– Avoids harm to human health and the environment significant to virtually 

all consumers with preference for professional wet cleaning. 

not outweighed by countervailing benefits to the consumer or to 

competition,

– No trade-off benefits identified in using dry cleaning.

– No increased competition by not requiring ‘Professional Wetclean’ label.

which consumers themselves could not have reasonably avoided.

– Consumer have little knowledge of ‘Professional Wetcleaning’ so likely to 

get essential information for care label.

– Consumers with preference less likely to use professional wetcleaning if 

words ‘Professional Wetclean’ not on care label.

FTC Legal Standard for Requiring a Label 19
3

rd Criterion for requiring a label: Is the response of 

requiring a label (a) appropriate and (b) cost-effective 

to address unfair or deceptive practice?

3 (a) Is requiring a ‘Professional Wetclean’ label appropriate?

Assessing Appropriateness of Requiring Label

Specific Criteria for Requiring Label

(1) Does it resolve failure to label? Yes

(2) Does it resolve deceptive or unfair practice? Yes

FTC Legal Standard for Requiring a Label 20
3 (b) Is the required use of a ‘Professional Wetclean’ 

care label cost-effective?

Costs

• Highest quality data to determine ‘Professional Wetclean’ label – experience, 

expertise, testing by trained professional wet cleaners.

• Expert judgment by professional wet cleaners (using experience and expertise) can 

be used for 99% of garments.

• Cost of expert judgment by professional wet cleaners extremely low: $50/item. 

o This cost likely comparable to current cost of expert judgment.

• Cost of testing at professional wet cleaners very low: $100/item. 

o This cost likely comparable to current cost of internal testing.

• Quick transfer of knowledge to apparel industry to allow cost to be internalized 

and assure current cost comparability. 

• Cost saving likely: professional wet cleaning less expensive than dry cleaning, 

reduced enforcement cost, reduced pollution remediation cost.

FTC Legal Standard for Requiring a Label 21
3 (b) Is the required use of a ‘Professional Wetclean’ 

care label cost-effective?

Effectiveness

• Requiring ‘Professional Wetclean’ label eliminates deceptive practice of labeling 

garment ‘Dry Clean’ which could also be professionally wetcleaned.

• Requiring ‘Professional Wetclean’ label eliminates unfair practice of labeling garment 

‘Dry Clean’ which could also be professionally wetcleaned.

Cost-Effectiveness

• Requiring ‘Professional Wetclean’ label is extremely cost effective.

FTC Legal Standard for Requiring a Label 22
Summery of Evidence in ‘Professional Wetclean’ Case 

for Criteria Used by FTC to Require Use of a Care Label

Decision-Making Criteria for Requiring Label Evidence

Strength of 

Evidence

Specific Criteria

(1) Likelihood that failure to use label well be prevalent Very high High

(2) Likelihood that failure to list method will be deceptive or 

unfair Very high High

(3a) Requiring label is appropriate Yes High

(3b) Requiring label cost-effective Yes High

Overall Decision

Extent evaluation of criteria supports required use of a label Very high High

FTC Legal Standard for Requiring a Label 23
Key Questions

• Before conducting this research: Should the FTC allow or required the use 

of a ‘Professional Wetclean’ care label?

• After conducting this research: What factors should the FTC consider in 

making an efficient and effective transition to a rule requiring the use of 

the ‘Professional Wetclean’ care label?

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