FEDERAL TRA.DE COMMISSION

A

_t)IVISION 

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ENFORCEMENT

AMERICAN TEXTILE

MANUFACTURERS INSTITUTE

January 31, 2002

Mr. Steve Ecklund

Federal Trade Commission

Division of Enforcement

Washington, DC 20580

Re: Request for FTC Staff

Opinion on Yarn Count

Dear Mr. Ecklund:

It has come to our attention again that. some companies are marketing bed

sheets and pillowcases to U.S. consumers where extremely high yarn or thread

counts are claimed -some as high as 1000 count. We believe these products

are mislabeled, creating deceptive information for the consumer.

Labeling these products based on a count that includes each ply in plied yarns

deceives the customer into believing that bedding products with higher counts

are better when, in fact, they might be inferior because of the method used to

determine the count. We wrote to the Commission regarding this same issue on

February 24, 1997 (copy enclosed) and provided a fabric sample and

independent lab report verifying our position.

In many cases, these extremely high counts are achieved by counting yams

within a ply as individual yams, thus dramatically increasing the number of yarns

in a square inch of fabric. A plied yarn is one in which two or more yarns are

twisted together to form a single strand.

ATMI believes this method of labeling products based on counting each

individual yarn in plies to be a deceptive practice, which misleads the American

. 1130 Connecticut Ave., NW. Suite 1200. Washington, DC 20036-3954

202-862-0500 .fax: 202-862-0570. http://www.atmi.org

fax on demand: 202-862-0572

Case: 1:17-cv-00754-DRC Doc #: 84-7 Filed: 02/01/21 Page: 1 of 2 PAGEID #: 1103 Case: 1:17-cv-00754-TSB Doc #: 1-4 Filed: 11/08/17 Page: 2 of 3 PAGEID #: 98
,

public into making decisions to purchase items, based on false and misleading

information.

ASTM method D 3775-96 (Standard Test Method for Fabric Count of Woven

Fabric) is the long-accepted industry standard for determining count. This

method has been in use in this country for many years and serves as the

industry's standard way to report the count of many woven textile fabrics,

including sheeting. It is based on the number of yarns in the warp direction and

filling direction, regardless of ply, and has become an important parameter used

by consumers to judge the quality of sheeting products, since the higher the

count, the more luxurious the product.

ATMI believes that any information provided to the consumer should be true and

correct so as not to be deceptive or mis-leading. We believe that plied yarns are

properly counted as only one yarn. For example, a fabric containing 250

individual four ply yarns in a square inch would be described as a "250 thread

count fabric, even though each thread or yarn contained four plies twisted

together." It would be false and mis-leading to describe this as a 1000 thread

count product.

ATMI requests a staff opinion from the Federal Trade Commission on this issue.

We believe that manufacturers, importers and retailers of bed sheets should rely

on the ASTM D3775-96 standard test method to determine count.

a:;;el# ~

Carlos Moore

Executive Vice President

Enclosure

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Case: 1:17-cv-00754-DRC Doc #: 84-7 Filed: 02/01/21 Page: 2 of 2 PAGEID #: 1104 Case: 1:17-cv-00754-TSB Doc #: 1-4 Filed: 11/08/17 Page: 3 of 3 PAGEID #: 99