Report of Market Access Ombudsman Council (May 13, 1994)

2-(1) Relaxing Standards for Care Labellings of Clothing

1. Complainant: Keidanren

2. Ministry concerned: Ministry of International Trade and Industry

3. Complaint:

The Household Goods Quality Labeling Law and related regulations set out specific quality labelling provisions for textile goods, by type of textile (e.g. "composition of fiber," "home laundering instructions," "shrinkage," etc.). Where labelling for home laundering instructions is concerned, labels are required to carry pictorial instructions based on JIS standards.

Similar international standards (ISO standards) exist for pictorial instructions, but since ISO, different from JIS, has not testing and evaluation methods, when clothing manufactured abroad is imported and sold in Japan, the foreign pictorial instructions may not be used as they are, and Japanese labels must be produced and affixed separately. This constitutes a barrier to imports, particularly from developing countries, and raises the price of imported clothing (particularly low-cost articles).

The complainant states that the standards relating to care labellings of clothing should be relaxed as described below in order to eliminate such barriers.

(1) On pictorial instructions, permit the use of a color other than red for the mark of 'x' which means the prohibition symbol
(2) When there are no specific instructions (items with no specific instructions regarding dry cleaning, chlorine bleach, ironing, wringing, drying), allow that care labellings of clothing be dispensed with
(3) Regarding the method of affixing labels, these must currently be sewn on, but simpler methods, for example, pasting labels on the back of price tags, should be allowed as well
(4) The use of foreign pictorial instructions (at least those based on ISO) should be allowed in Japan

4. Results of deliberation:

(1) The fact that domestic and ISO standards for care labelling of clothing may differ in effect constitute a barrier to imports. However, it should be borne in mind that JIS standards for pictorial labels have spread widely among consumers and that at the time of the introduction of such labelling, the opinions of consumers and industries were solicited, considering that ordinary laundering methods in Japan and abroad may differ, and domestic standards were adopted taking such opinions into account.

Because of this, while harmonization of ISO and domestic standards should be promoted over the intermediate term, domestic standards should be fully established with promoting the convenience of consumers and the necessary measures should be taken.

(2) The actions taken by the ministry concerned regarding this complaint are as follows. Where changes are necessary, these should be implemented without delay.

1) With respect to mark 'x' which means the prohibition symbol, the provision regarding the color of 'x' in red will be abolished by amending JIS standards during fiscal 1994.
2) It is important that consumers should not suffer as a consequence of inappropriate laundering methods. In the simplest case, a label showing only "method of laundering" will be allowed. In that case, if the garment is made of a single fiber and is undyed, and if the manufacturer assumes responsibility of selling such garments as underwear, care labelling of clothing.
3) Regarding method of attachment of labels, for the convenience of consumers when laundering, labels must be attached in such a way that they will not come off from the garment during laundering, but attachment method will not be limited to sewing and other methods leg gluing labels etc. on will be permitted as well.
4) With respect to the use of foreign pictorial instructions in Japan, since testing and evaluation methods for the symbols used have not yet been specified by the ISO standards, pictorial labelling based on ISO standards does not provide objective decision-making criteria to consumers when selecting goods. Accordingly, it is difficult under the present circumstances to introduce a domestic rule permitting the use of foreign pictorial labelling in Japan.

However, the ISO is currently discussing the adoption of testing and evaluation methods for ISO standards concerning pictorial instructions of clothing, and if such methods are adopted in ISO standards, JIS will be reviewed immediately to harmonize JIS standards with ISO standards as far as possible.

Government decision (June 24, 1994)

2-(1) Changes in regulations concerning care labelling of clothing

While harmonization of ISO and domestic standards will be promoted over the intermediate term, domestic standards will be fully established with promoting the convenience of consumers.

To simplify standards, the provision regarding the color of 'X' in red, which means the prohibition symbol, will be abolished by amending JIS standard during fiscal 1994.

Follow-up (June 5, 1995)

2-(1) Relaxing Standards for Care Labelling for Clothing

Since ISO standards contain no regulations concerning testing and evaluation methods needed when indicating care-labelling instructions for clothing, testing and evaluation methods should be established. Practical deliberations to this end began in 1994 in the ISO's TC38 (technical committee on textiles), SC11 (sub-committee on textiles and care labelling for clothing), and WG3 (working group on testing methods and standards), and Japan is actively participating in these deliberations.

Japan will continue to participate in ISO deliberations, and based on the results of deliberations, will study harmonization of JIS with ISO standards.

When the study of harmonization of JIS with ISO standards is completed, the necessary measures will be taken to ensure that the new domestic standards become well established, by holding meetings to explain the new standards and so on, and the issue of reviewing regulations concerning quality labelling for textiles drawing on JIS will be studied.

The requirement that the color red be used to indicate prohibition in the JIS for care labelling for clothing was abolished in March 1995 after deliberations by the Japanese Industrial Standards Committee, which is composed of manufacturers, users and others.