Utah R70-101 Letter
Dear Kelly Pehrson, Amber Brown, & Amanda Price,
ACT (American Circular Textiles) represents thirty leading companies in the United States with interests and operations in the textile circular economy. We are a first-of-its-kind coalition of organizations aimed at identifying and supporting circular textile policy opportunities that will create sustainable jobs, bolster American business, educate consumers, and protect our supply chains and environment.
We are writing to express our concerns regarding the proposed regulations outlined in R70-101, specifically R70-101-13 and R70-101-14 of the Utah Administrative Code, based on the several secondhand businesses that we represent. While the intent to protect consumers is commendable, the proposed regulations, as written, will have unintended negative consequences for the secondhand market.
Firstly, we request clarification on the scope of the proposed regulations. Does this apply to all secondhand textiles or specifically to quilted clothing? A clear definition of ‘quilted clothing’ is essential for industry compliance.
The secondhand clothing industry is a vital component of Utah's economy, supporting countless small businesses and creating jobs. It also plays a crucial role in promoting sustainability by extending the lifespan of clothing and reducing waste.
The specific requirements for tag size, material, content, and placement outlined in R70-101-13 impose a substantial burden on the secondhand industry. These regulations necessitate significant investments in time, labor, and materials for each item, increasing operating costs dramatically. Given the typically low profit margins of secondhand clothing businesses, these additional expenses pose a severe threat to their viability. Most cannot absorb the increased costs without passing them on to consumers or closing their doors entirely.
R70-101-14 further exacerbates these challenges by imposing even more stringent requirements on repaired, reupholstered, and renovated products. The detailed specifications for tags, including the mandatory inclusion of URN numbers and extensive descriptions, are impractical for many secondhand businesses since, unlike new clothing, secondhand items possess a unique history, often with unknown origins, materials, and manufacturing processes.
We urge you to reconsider these regulations and explore alternative approaches that balance consumer protection with the needs of the secondhand industry. By collaborating with industry stakeholders, guidelines can be developed that effectively address consumer safety without imposing undue burdens on businesses. We appreciate the opportunity to provide our perspective.
Sincerely,
Rachel Kibbe
CEO, American Circular Textiles
