United States of America

FEDERAL TRADE COMMISSION

Washington, D.C. 20580

Office of Commissioner

Rohit Chopra

To: April Tabor

From: Maria Bazan

Date: September 15, 2020

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

On September 8, 2020, Commissioner Chopra, Erie Meyer, and I met with Mary Scalco, CEO of 

the Drycleaning & Laundry Institute (DLI) regarding the Federal Trade Commission’s Notice of 

Proposed Rulemaking regarding the repeal of the Care Labeling Rule.

During the call, Ms. Scalco noted that there was no mention or proposal to remove care labeling 

altogether when the Commission previously conducted roundtables on the rule. She emphasized 

that care labels are an essential tool for dry cleaners, as many within the industry rely on them 

for guidance on how to treat their customers’ garments. She noted that it is not always evident 

which procedure should be used to clean a specific item just from reading the list of textiles it 

contains because differences in composition can affect how fabrics react to certain chemicals. 

The DLI is concerned that repealing the Care Labeling Rule would expose dry cleaners to 

additional liability when clothes are damaged. When something happens to a garment during the 

cleaning process, consumers typically turn to the last person who handled the item, even in cases 

where the dry cleaner followed the care instructions meticulously. In these situations, care labels 

provide an added protection for their members because they are able to prove that the issue is 

with the instructions printed on the label. 

Ms. Scalco warned that this increased liability could be very damaging to the DLI’s members, 

especially now during the COVID-19 health crisis. The economic downturn, combined with 

reductions in public gatherings like weddings and funerals, has translated into diminished 

revenues because fewer customers require or seek their services. 

Commissioner Chopra inquired about the owners and operators of professional cleaning 

establishments. Ms. Scalco noted that the majority of dry cleaners in the United States are small, 

family-run businesses, many of whom are minority-owned or owned by immigrants, and have 

fewer than five employees. These small businesses, who may already be struggling to break even 

while operating at a reduced capacity, would be disproportionately affected by the FTC’s 

decision to repeal the Care Labeling Rule. She noted that this would also impact providers of 

wash-and-fold services.
2

Additionally, the DLI’s membership serves frontline workers addressing the COVID-19 health 

crisis. Care labels help outline temperature guidance to allow cleaners to process the clothing at 

as high a temperature as indicated. Higher temperatures are more effective at killing viruses. 

Without specific care labels, the business would be guessing at how best to launder the garments, 

and may choose a lower temperature out of caution for not damaging them. The DLI says that 

their members want certainty so that they can keep their clients as safe as possible.

The DLI believes that this repeal is not in the best interest of its members, or consumers in 

general. The only group that may stand to benefit from this decision would be manufacturers 

who make low-quality clothing. Scalco noted that it was unclear whether there would be any 

cost savings, because manufacturers would still need to produce labels to disclose fiber content 

and country of origin.