Agathon Associates Comments on FTC Wool Rules

On February 8, 2021, the Federal Trade Commission published in the Federal Register (86 FR 8641) Agency Information Collection Activities; Proposed Collection; Comment Request; Extension

The Wool Products Labeling Act of 1939 (Wool Act) prohibits the misbranding of wool products. The Wool Rules establish disclosure requirements that assist consumers in making informed purchasing decisions and recordkeeping requirements that assist the Commission in enforcing the Rules. The FTC provided this opportunity for public comment before requesting that OMB extend the existing clearance for the information collection requirements contained in the Commission's Wool Rules.

Agathon Associates submitted the following comment--

The Rules and Regulations under the Wool Products Labeling Act of 1939 serve three important functions. (1) They implement the Wool Act's charge to the Commission to enforce the Wool Act and provide clarification regarding the Commission's enforcement of the Act. (2) They implement industry best practices relating to the labeling of article of wool, thus providing some protection for good actors in the wool apparel trade from unfair competition from those who would make incomplete, inaccurate, or false representations about their merchandise absent the Rules. (3) They protect consumers from such incomplete, inaccurate, or false representations regarding merchandise. This third point is extremely important. Consumers have no independent way of verifying country of origin and fiber content of apparel. They rely on the labels that are required, and regulated, by the Wool Rules. Consumers are defrauded when articles they buy are not as represented on the labels.

The Rules do not impose an unnecessary burden on businesses. They are what honest traders would do anyway; they are a burden to only those who would cheat consumers and unfairly compete against other business. The Rules have been in place for many years; businesses know and understand their obligation to comply, and compliance costs are not excessively burdensome.

Respectfully submitted, David Trumbull