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1 Timothy J. Muris, Care Labeling Rule Amendments: Memorandum to the Commission 1 (1982)

handle is hein.usfed/crlrammc0001 and id is 1 raw text is: FEDERAL TRADE COMMISSION WASHINGTON. D. C. 20580 BUREAU OF CONSUMER PROTECTION May 25, 1982 MEMORANDUM TO : Commission FROM : Timothy J. Mu s Director Bureau of Consumer Protection SUBJECT: Care Labeling Rule Amendments I. Introduction I am forwarding the staff's final proposals for amendments to the Care Labeling Rule, including the staff's recommendations for changes in the proposed amendments as previously published for comment, the staff's summary of comments received during the latest comment period, a proposed Statement of Basis and Purpose (SBP), and a proposed Regulatory Analysis (RA). With minor modifications discussed below, I recommend promulgation of the amendments relating to textile wearing apparel and piece goods. These changes will clarify the Rule, and will benefit consumers, the cleaning industry, and apparel manufacturers and importers, while imposing little or no incremental cost. I cannot, however,.support the amendments that would for the first time impose care labeling obligations on manufacturers and importers of products not covered by the existing Rule, such as upholstered furniture, carpets and rugs,*drapes and curtains, household linens, slipcovers, yarn, and leather and suede apparel. The staff's effort to find in the record evidence sufficient to justify these provisions, although commendable, merely underscores the inadequacy of the rulemaking record to permit a reliable assessment of the need for an expanded Rule or of the costs it would impose. In my recent memorandum on the Food Rule, I explained in detail my analysis of the Commission's rulemaking obligations. 2 Rulemaking is justified only when the record contains hard 1 My criticism of the record should not be interpreted as criticism of the rulemaking staff. The staff merely followed the approach to rulemaking, emphasising anecdotal evidence rather than systematic inquiry, that prevailed at the Commission in the 1970's. 2 The relevant portion of that memorandum is attached as Appendix A to this memorandum.

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