I admit that sometimes I make mistakes. A person reading my previous blog entry on a wedding care/content label pointed out some inaccuracies in how I wrote my suggested label. The FTC has some guidelines on how to write labels, both for content and care. I've read these instructions many times, but I sometimes need a refresher. Yes, it would be a good idea for anyone who has to write labels to read the instructions themselves rather than rely on a blog entry (or an anonymous commenter).*
Care instructions follow the general form:
If a dress truly cannot be dry cleaned, then the label should include that instruction. My label suggestion would be more accurate if I had included that instruction. I had also placed the bleaching instruction in the wrong order. Perhaps a better, more accurate, and perhaps correct label (changes in bold) would read:
Do not dry clean.
Hand wash or
Spot clean in cold
water with mild
soap. Do not bleach.
Hang to dry.
Do not iron.
Made in China
RN12345 (<------ Made up)
Avoid the use of
alcohol based products
such as hairspray,
perfume, etc., as these
may damage the dress.
The commenter also pointed out that if there is a reasonable basis for care instructions, then a manufacturer does not need to destroy a dress to prove it. I guess the question that must be determined is what is reasonable? In my opinion (and just for this commenter, this IS my opinion, for what it's worth), a new wedding dress manufacturer should destroy a few dresses to prove their labels. If you think something can be dry cleaned, you should be able to prove it. Same with any other care instructions. Over time, you may be able to reduce the type and amount of testing provided you do not change your component parts. This is probably the reason behind some of the testing requirements in the CPSIA. When you change a component (sometimes even from the same source), you have introduced a variable which may result in different testing guidelines.
I know wedding dresses are expensive, even the initial samples. Is it reasonable that every dress be tested to prove the care instructions? I am not sure every manufacturer goes to that extreme. But it is reasonable that a few have been. Testing a whole complete unit is the only way to test for compatibility of components. Testing a whole complete unit will tell you what a customer will experience. Wedding dresses have a lot of sentimental value and you wouldn't want a customer to have a dress ruined by poor or incorrect cleaning instructions. But this decision is best left to the manufacturer and the responsibility they are willing to bear if something were to go wrong.
As a manufacturer develops, it is reasonable to also test components. It is common for a manufacturer to use the same polyester satin in multiple styles and all they do is change up the trimming. In this case, the satin has probably been washed tested a few times and they know how it should be cleaned. But the trimming is different. In this case, I take some yardage, stitch the trim on and wash it (or dry clean it) - multiple times.
I can recall some concern I had about some flocked glitter on a chiffon. The glitter can fall off because the dry cleaning solvents will dissolve the glue. Washing by hand or machine can cause the glitter to fall off due to abrasion. So we tested various scenarios and came up with a reasonable basis for care. The same scenario can be applied to beads. Though I must say, based on my experience testing, some beads can be dry cleaned and some cannot. Some will fall apart even when hand washing. You won't know unless you test.
It is reasonable that a manufacturer has proof for the testing they recommend. I believe this includes documentation. You won't have documentation unless you test something. These days, I am not sure that a government regulator will appreciate your good intentions or your word without some kind of proof.
And finally, it is true that the CPSIA does not specifically mention wash testing (as I stated in my previous blog entry). It does imply that any testing be done by a certified 3rd party lab. When I worked various private label programs for Big Box stores, they required wash testing by an approved 3rd party testing lab. At that time we were able to negotiate creating an in-house wash testing program to save money. We were required to submit a copy of our test results with the 3rd party testing reports to the technical designers of the big box stores. In the days of CPSIA, I imagine this is no longer possible (I haven't worked on any private label programs in a while, so someone else who has will have to clarify this point). So while the law may not specifically mention wash testing by a certified lab, Big Box retailers might require it anyway. This is thus my reasoning for why I said what I said.
*When I wrote my original blog entry, the FTC site was down and had been down for a few weeks. My intention was to verify and correct my article and I didn't do that because I couldn't. It was one of those things that fell off my radar and I didn't get back to it. My apologies to anyone if I misled. I appreciate comments that politely correct me when I have misstated something. However, I won't print comments that are insulting and offensive.