The proposed amendment concerns the existing Care Labelling of Textile Wearing Apparel & Certain Piece Goods Rule (commonly referred to as the Care Labelling Rule or Care Rule) and the petition aims to bring it into the internet era.
In its petition for rulemaking concerning the digital labelling of apparel, the AAFA said the change would enhance the way consumers, including those who face challenges accessing traditional labels due to current regulatory constraints, receive information on product care.
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The AAFA added that it also promises significant cost savings in printing and labelling, potentially amounting to millions of dollars, while concurrently contributing to waste reduction efforts.
Data from industry research indicates that current labelling practices lead to the production of around 5.7m miles of label tape each year. This figure is equivalent to traveling from earth to the moon and back twelve times annually.
The existing Care Labelling Rule, established in 1971 before the advent of the internet, mandates that manufacturers and importers affix physical labels with care instructions to garments.
The European Union and other developed nations have implemented similar labelling mandates, leading to an excess of lengthy, multi-language labels with small text and obscure symbols that are difficult to decipher and often result in discomfort due to their size, the AAFA explained in its letter to the FTC.
The AAFA suggests the FTC should permit compliance with the rule through digital labels, such as URLs or QR codes, which could be included on a minimal tag or directly imprinted on the clothing.
AAFA president and CEO Steve Lamar said: “Today’s shoppers demand clearer, more relevant information without being buried under pages of wasteful, uncomfortable labels they often ignore or cut off. By embracing digital solutions, the FTC can unlock vast potential for consumers to gain more insights into the products they buy.
“Consumers regularly use technology to interact with their fashion – either at the point of sale, when they are caring for their clothing, or when they are sharing fashions through social media. With this logical next step, to enable care instructions to be provided digitally, the FTC can better align the regulatory framework with consumer preferences.”
By April 2024, an estimated 10,744 manufacturers or importers will be producing or importing over 18.4bn garments annually under this rule.
According to FTC estimates, these entities devote around 25.5m hours yearly to comply with the rule. The associated labour costs are substantial: $34m annually for determining care instructions, $17m for drafting and ordering labels, and $166m for attaching them, reaching a total of $217m excluding printing costs.
AAFA believes that digital labels could alleviate these financial strains and potentially lower consumer prices.
AAFA senior vice president of policy Nate Herman states: “We urge the Federal Trade Commission to take this step toward creating more responsible and adaptable guidelines to allow companies to meet labelling requirements through digital methods.”
Last month, the AAFA published a whitepaper to shed light on the issues surrounding deceptive online platforms.
