Care Labels: A brief history.
Long before polyester, acrylic and automatic washing machines came along, consumers could easily identify a wool or cotton garment and successfully clean it without a care label.

But those days are long gone. New fibers and new technology have created a vast array of apparel and textiles - each designed to look beautiful and to stand up to the test of time. Unfortunately, consumers had no way of knowing just how to properly clean these items, often damaging both the apparel's beauty and long-lived nature.

So in 1972, the Federal Trade Commission introduced the Care Labeling Rule which, for the first time, required manufacturers to label their clothing with instructions for at least one safe cleaning method for the garment. From this time on, it would be considered unfair and deceptive for manufacturers or importers to sell items without care labels.

Two key goals.
Requiring care labels actually accomplished two very important goals. First, it helped consumers make buying decisions based upon the care method required. Some people prefer the convenience of dry cleaning, others the economy of machine washing. At the same time, care labels assured that consumers knew how to safely clean their clothes so that they retained their appearance and performance over time. Something which the entire apparel industry was all for as well.

One key revision.
In January 1984, the FTC made a number of revisions to its Care Labeling Rule based upon findings that many consumers considered care labels to be incomplete, inaccurate and inconsistent. The rule was amended to clarify care labeling requirements, simplify and unify the care label language and provide more specific, detailed information for consumers. The Rule was also intended to make care labeling compliance easier for manufacturers which would, in turn, make care labels more beneficial and informative for consumers.

The next step: A move toward symbols.
Now, the FTC is introducing a "conditional exemption" to its Care Labeling Rule. This exemption, which begins July 1, 1997, allows manufacturers to use certain care symbols in place of written instructions to communicate a method for cleaning. Originally proposed in November 1995 and then refined over the following 15 months, this exemption is designed to further simplify and unify care labels, making them more helpful to consumers. The symbols to be used have been developed by the American Society for Testing and Materials (ASTM).

Why care label symbols?
One of the major reasons behind the introduction of care label symbols is to harmonize American clothing labeling regulations with those of Canada and Mexico. In fact, the intent is that the new symbols will become standard in all countries participating in the North American Free Trade Agreement. This means that apparel manufacturers will now be able to use the same care label on garments offered for sale in any or all of these countries. And consumers will be able to make purchase decisions based upon care requirements, and follow appropriate care instructions, without knowledge of the language.

Additionally, this move to care label symbols can help satisfy another consumer demand which is to decrease the size of care labels. Lately, there's been growing concern among manufacturers that the higher cost of larger labels are being reflected in higher apparel cost. Using symbols in place of words is a simple tactic for saving both space and money.

You should keep in mind, however, that the upcoming conditional exemption stops short of creating a global standard for care labeling. This is still a goal of the FTC. It's just that the FTC does not believe the system of symbols set up by the International Standards Organization (ISO) and known as Ginetex is as comprehensive as those developed by the ASTM. Efforts to harmonize the ASTM and ISO care symbol systems are expected to continue.

Educating manufacturers and consumers alike.
With a proposed change of this magnitude, education is a critical factor in the success of the new care symbols. Consumers need to be made aware of the new care symbols - what they stand for and how to read them. At the same time, manufacturers need to be informed so that they know exactly what is required of them. After all, garments that are made without care label - or with one that provides inaccurate cleaning instructions - may be found to be in violation of this rule.

Fortunately, a comprehensive effort is underway on both fronts. A number of apparel manufacturers, retailers, suppliers, trade organizations, and consumer groups have joined with the FTC to form the Care Labeling Education & Awareness Network (CLEAN). Project CLEAN represents a cooperative effort to provide a variety of educational messages and materials to consumers about the new care symbols.

This booklet is also part of the effort - produced and distributed by Paxar a as part of our ongoing commitment to the apparel and textile industries. In the pages that follow, we will outline the conditional exemption and attempt to answer your questions concerning the usage of care label symbols, and compliance with the conditional exemption.

Making the move to care symbols.
As previously stated, beginning July 1, 1997, manufacturers will be able to use ASTM-developed care symbols in place of written instructions on permanent labels inside of garments.

The use of care symbols is voluntary. However, if you do choose to use them, the FTC has made it absolutely mandatory that, for the first 18 months (through December 31, 1998), written explanations for the care symbols must be provided with the item. This requirement is aimed at making sure that consumers understand what the symbols stand for. These explanations do not have to be right on the label, but they must be somewhere with the clothing or packaging such as on hang tags, stickers or elsewhere. Of course, if you wish, you can state the instructions on the label itself, along with the symbols. If you do this, you do not need any other explanatory material such as a hang tag. The FTC has stated that you, as the manufacturer, have the flexibility and freedom to choose how to best convey this information to keep with the overall look of your care, content and brand identification program.

Understanding the care label symbol system.
The entire care label symbol system, as designed by the ASTM and approved by the FTC, is based upon five basic symbols which represent five basic care operations. These are: a washtub with a water wave for the washing process; a triangle for bleaching; a square for dying; an iron for ironing; and a circle for dry cleaning. Only one safe method of care is required on the label - usually either laundering or dry cleaning.

In addition, the "X" symbol can be superimposed on any of the symbols whenever there is evidence to support that using that process could damage the apparel.

To adequately represent the laundering process, at least four symbols must be used in the following order - washing, bleaching, drying and ironing. If you have evidence that dry cleaning will damage the item, and you wish to warn against it, add the dry cleaning symbol with an X after the four other symbols.

For garments that must be dry cleaned, the dry cleaning symbol must be used at a minimum.

Using additional symbols to clarify proper care.
Additional symbols or words are also used within and below each basic symbol when it is necessary to further define proper care instructions.

Washing: A water temperature must be given if certain temperatures would damage the garment. The following system of dots can be used within the washtub to indicate suggested water temperatures for washing.

Six dots = 95 C/200 F
Five dots = 70 C/160 F
Four dots = 60 C/140 F
Three dots = 50 C/120 F
Two dots = 40 C/105 F
One dot = 30 C/85 F.

The washing machines used by most U.S. consumers, however, do not heat the water to a precise temperature. In addition, many consumer washing machines cannot attain the very high temperatures indicated by six, five or even four dots. For this reason, the FTC consumer chart (shown below) shows only three dots for hot, two dots for warm and one dot for cold/cool. Unless you intend for your product to be professionally laundered at very high temperatures, you will probably want to use one, two or three dots and explain to the consumer that these correlate to cool, warm and hot.

Underlining the tub once indicates the permanent press cycle, and underlining it twice indicates the delicate-gentle washing cycle.

Bleaching: The triangle means all bleach can be safely used. If chlorine bleach cannot be safely used, diagonal lines should be included within the bleaching triangle to indicate non-chlorine bleach only. If no bleach can be safely used, an X through the triangle should be used to provide a do not bleach warning.

Drying: Additional symbols within the drying process square are designed to indicate the type of drying process to use such as tumble dry, line dry, drip dry, dry flat or dry in the shade. If apparel is designed for tumble dry, but a special cycle is necessary, one underline indicates permanent press while two underlines indicate the delicate-gentle cycle.

Ironing: Additional ironing symbols include dot symbols inside the iron to indicate the proper temperature setting:
Three dots = high
Two dots = medium
One dot = low.
A steam burst can be used under the iron to indicate steaming, or it can appear with an X to warn not to steam.

Dry Cleaning: A letter enclosed in the dry cleaning symbol indicates the type of solvent recommended. Additional symbols can be used to provide warnings about parts of the normal dry cleaning process that should be modified or avoided.

As you can see, in a relatively small space, the care symbol system is designed to offer simple, detailed, straightforward care instructions. For more information on individual symbols, please refer to the chart on page 11 which has been prepared by the Federal Trade Commission.

Care for some answers to your questions?
Q. Do I have to use symbols?

A. No. You can continue to use written care instructions if you'd like. The conditional exemption approved by the FTC simply give you the option of using care symbols instead of words beginning July 1, 1997. Using care symbols can result in smaller labels, unify care labeling among NAFTA countries and help consumers buy and care for apparel without knowledge of the language.

Remember, if you do choose to use care symbols you must also provide written care instructions with the garment - for example, on hang tags, stickers or package inserts. (Of course, you may simply state the instructions in both words and symbols on the label itself. This mandate is effective for the first 18 months of care symbol usage - July 1, 1997 through December 31, 1998.

Q. Can I use additional explanatory words with the symbols?

A. Yes. In fact, in certain cases, you may want to use additional words with care symbols in order to clarify care procedures. For example, where laundering instructions are concerned, terms such as with like colors, do not pretreat, remove shoulder pads, do not use fabric softener - to name just a few - may be necessary.

Q. Can I put care symbols on the reverse side of the label?

A. Yes. But it is required that either the care label or the detailed care instructions be visible at the point of purchase.

Q. Do the symbols have to be in any order?

A. Yes, they do. For apparel that needs to be laundered, at last four symbols must be used and they must appear in the following order - washing, bleaching, drying and ironing. If you have evidence that dry cleaning will damage the item and you wish to warn against it, you should add the "do not dry clean" symbol last. If dry cleaning is the suggested care, only the dry cleaning symbol with any appropriate additions, needs to be used.

Q. Do the symbols have to be a certain size?

A. Care label symbols do not have to be a specific size. But they do have to meet the existing Care Label Rule requirement of legibility. Of course, it is important to keep in mind, that failure to print legible care symbols may be considered an unfair or deceptive practice and result in civil penalties.

Q. Can the symbols be stacked down the side of the label?

A. Yes, provided they still appear in the proper order and are legible.

Q. Do the symbols have to be a certain color?

A. The care symbols do not have to be a particular color.

Q. How do care symbols meet with NAFTA's call for harmonizing care labeling?

A. One of the motivating factors in the FTC's introduction of care symbols in the U.S. was mandate by NAFTA to unify care labeling. The ASTM care labeling system has been designed to be harmonious with systems in Canada and Mexico. Currently, care labeling in Canada is strictly voluntary. In Mexico, care labeling is mandatory and there are indicators that Mexico is moving toward accepting the FTC rules on care labeling. Keep in mind that, at present, this ruling only applies to the United States.

Q. Do I have to use dots and temperatures in the wash box?

A. The dots must be used: the temperature can be used in addition to the dots if you wish.

Q. Can I use or continue to use European care symbols?

A. No, you cannot. The FTC has concluded that the care symbols developed by the ASTM are more comprehensive in nature than the European care symbols developed by the ISO. Thus, the FTC has ruled that only ASTM-symbols can be used.

Q. Can I put the symbols and the explanations just on the packaging?

A. No. The FTC's conditional exemption specifically states that care symbols must appear on permanent labels within the garment. Explanations of the care symbols must accompany the garment and can be placed, for example, on hang tags, stickers or package inserts.

A few words from Paxar.
As the leading global supplier of care, content and brand labels, Paxar has always been committed to helping apparel manufacturers understand, comply with and benefit from labeling regulations.

Back in 1972, Paxar introduced, fabrics that could be printed and cut into labels at high speeds - providing a quick, economical solution to the new Care Labeling Rule. In 1984, we followed up on the FTC's care label revisions with an industry-wide education campaign as well as new care labeling solutions.

Today, Paxar is ready to provide you with the information, support and solutions you need to make the move to a care symbol label system with ease and efficiency. This includes providing you with an array of solutions that can be produced at our facilities or that you can print in your factory on a Paxar in-plant system.

Paxar can produce labels and tags any way you want. We can even offer you care symbol labeling software for your Paxar in-plant label printing system. There's an endless choice of formats - care only, care and bar code, combination logo and care or virtually any combination log/care/bar code labels. And you can get them just as fast as you need them - shipped, in some cases, within 48 hours using Paxar's PDQ Service. Whether you want to revise an existing label layout or create one from scratch, with Paxar, you'll always have total design flexibility.

Finally, and perhaps most importantly, whichever Paxar solution you choose, it is available in over 50 countries around the globe - all backed by our unwavering commitment to help you succeed.

A closer look at the care label symbol system.

For additional information.
If you have further questions about the conditional exemption to the Care Labeling Rule, please contact the FTC or Paxar.

Edwin Rodriguez
Staff Attorney
Federal Trade Commission
United States of America
Washington, D.C. 20580
Care Label Marketing Group
Paxar Corporation
105 Corporate Park Drive
White Plains, NY 10604
Fax 914-696-4128

Paxar Corporation
105 Corporate Park Drive
White Plains, NY 10604
Telephone: 914-697-6800
Fax: 914-696-4128

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Last Rev. 1/4/2001