Amicale Industries

UNITED STATES OF AMERICA
FEDERALTRADE COMMISSION
600 PENNSYLVANIA A VENUE, NW
WASHINGTON,	D.t. 20580
Division of Enforcement
Bureau of Consumer Protection
August 5, 2002
John S. Rode
Rode & Qualey
295 Madison Avenue
New York, New York 10017
Dear Mr. Rode:
I am writing in responseto your requestfor an advisory opinion on behalf of Amicale
Industries. I apologize for the delay in response.
Your letter describes in detail Amicale's quality control procedures in the manufacture of
cashmereand cashmere/woolblend fabrics. The letter then asks whether theseproGedures
constitute "due care" as the tenn is used in the Wool Products Labeling Act. The relevant
language of the statutereads as follows:
Provided, That deviation of the fiber contents of the wool product from percentages
stated on the stamp, tag, label, or other means of identification, shall not be misbranding
under this section if the person charged with misbranding proves such deviation resulted
from unavoidable variations in manufactureand despite the exercise of due care to make
accuratethe statementson such stamp,tag, label, or other means of identification.
15 V.S.C. § 68b(4)(a)(2)(A).
The Commission's Rules of Practice, 16 C.F.R. § 1.1(a)state: "Any person,partnership,
or corporation may requestadvice from the Commission with respectto a course of action which
toe requesting party proposes to pursue." The Rules further state: "Hypothetical questions will
not be answered, "
Amicale's quality control procedures,as described in your letter, appearto be exemplary.
Indeed, suchproceduresshould ensure that fabrics manufactured by Amicale are accurately
labeled with respectto fiber content.

JohnS. Rode,page2
However, your letter does not set forth a proposed course of action for which an advisory
opinion would be relevant or appropriate. The proceduresdescribedare Amicale's general
businesspractices, which presumablyhave been in effect for some time. Weare aware of no
allegation or suggestionthat any of Amicale's products are improperly labeled. Therefore, there
is no question for which a Commission or Commission staff advisory opinion would be
appropriate.
We do appreciateAmicale's high level of concern and attention to labeling issuesand its
care in adhering to manufacturing and testing proceduresdesignedto ensureaccuratelabels.
Pursuantto Section 1.4 of the Commission's Rules of Practice, 16 C.F.R. § 1.4, your
letter, together with this response,will be placed on the public record.
Sincerelyyours,
~ ~ 9~1-n?""-	~~
Carol J. Jennings

]OHN S. RODE
MICHAEL S. O'ROURKE
PATRICK D. GILL
R. BRIAN BURKE
WILLIAM]. MALONEY
WASHINGTON OFFICE
1742 N STREET, N.W
WASHINGTON, D.C.
TELEPHONE: (202) 223-0957
FACSIMILE: (202)785-2210
M ILYAS KHAN, OF COUNSEL
(ADMITTED IN PAKISTAN)
KARACHI, PAKISTAN
TELEPHONE: (92-21) 5685541
FACS1MILE: (92-21) 5683050
ATrORNEYS AT LAW
295 MADISON AVENUE
NEW YORK, N.Y. 10017
TELEPHONE: (212) 685-4437
FACSIMILE: (212) 213-3206
E-MAIL: TRADELA W@AOL.COM
WWW.RODE-QUALEY.COM	ELEANORE KELLY-KOBAYASHI
December6,2001
Division of Enforcement
Bureau of Consumer Protection
United States Federal Trade Commission
600 Pennsylvania Avenue, N. W.
Washington, D.C. 20580
Re Labeling of Woven Fabrics Produced From 100% Cashmere Yarns
and From Blended Cashmere and Wool Yarns
Dear Sir:
Amicale Industries, Inc., with headquarters at 1375 Broadway, New
York, N.Y. 10018, is a leading maker of cashmere fabrics in the United States and is
the largest cashmere merchant in Europe; Amicale has asked us to seek your advice
with respect to the labeling of the woven fabrics they produce from yarns spun by
Amicale from cashmere and wool fibers at Amicale's fabric division in the United
States. All of these fabrics fall within two general categories: fabrics produced from
yarn spun from 100% cashmere fibers, and fabrics made from blended yarn spun
from cashmere and wool fibers. The blended yarns used to produce the latter
category are most frequently spun from 50% (by weight) cashmere and 50% (by
weight) of wool fibers, although Amicale often spins blended yarns to the order of

their customers, in which the proportion of cashmere to wool is other then 50/50,
e.g., 80% cashmere, 20% wool.
Amicale, established. over fifty years ago, follows the Rules and
Regulations issued under the Textile Fiber Products Identification Act and the Wool
Products Labeling Act, as well as the dictates of the commercial market for 100%
cashmere and cashmere/wool blended products, and has accordingly devoted
substantial time and resources to ensure that the articles produced by Amicale meet
or exceed all applicable legal and commercial requirements. To that end, upon
which their worldwide reputation depends, Amicale rigorously controls all phases of
their production from raw material procurement through finished goods. Our client
is able to exercise such control because their production is vertically integrated,
unlike some of their competitors, who must relinquish control over their materials
and intermediate products at various stages of production, and send such materials
and intermediate products to unrelated mills for the performance of manufacturing
operations which they cannot conduct in their own facilities.
Consequently, and perhaps uniquely, when Amicale delivers a finished
fabric to one of its customers, our client is in a position to represent, accurately, that
every step in the manufacture of that product was accomplished within the facilities
owned, operated, and supervised directly by Amicale
Cashmere and Wool Fiber Procurement
Amicale purchases cashmere fibers from three principal sources:
2

1. Amicale obtains Mongolian cashmere from its joint venture with
the government of Mongolia, Mongol-Amicale, which was established in 1990.
Mongol-Amicale purchases the raw cashmere directly from the herdsmen through a
chain of over twenty regional warehouses; this fiber is transported from those
warehouses to the Mongol-Amicale factory in Ulaan Baatar, where every kilogram
of raw fiber is hand-sorted and examined, tested in the joint venture's laboratory,
scoured, dehaired, baled, and then shipped to Amicale's wholly-owned subsidiary,
W. Fein & Sons Limited, in Bradford, U.K.
2. Amicale has an office in Inner Mongolia, China, which is
supervised by the former head of the Export Section of the Cashmere Department of
Inner Mongolia. This office of Amicale draws samples from every lot of Chinese
cashmere which is offered for purchase, and forwards those samples to the
laboratory of W. Fein & Sons Limited for testing. If a sample meets Amicale's
quality standard, the office in Inner Mongolia is then authorized to purchase the lot
from which that sample was drawn, and arrange for delivery of the approved lot to
Amicale in Inner Mongolia, where the fibers are again inspected before shipment of
the Chinese cashmere to W. Fein & Sons Limited in the United Kingdom.
Amicale also acquires cashmere fibers from other sources,	3.
principally raw cashmere offered on the "spot" market in Euroli>e; samples of these
shipments are tested at the laboratories of W. Fein & Sons Limited, and fibers
purchased on the spot market are usually shipped to W. Fein & Sons although, on
occasion, such fibers may be shipped directly to Amicale in the United States.
Amicale also purchases wool fibers for their use in blending; as with
cashmere fiber purchases, the wool is inspected, sampled, and tested by Amicale,
3

~ODE & QUALEY
and, as is done with Amicale's cashmere fiber, all lots of fiber are segregated by lot
number until withdrawn from inventory for further manufacture. When such fibers
are shipped to Amicale's fabric division in Charlotte, North Carolina, whether
shipped by W. Fein & Sons or from other sources, each fiber lot is inspected and
tested by the Quality Control Laboratory at Amicale North Carolina and is then
placed in inventory until required for production. Amicale maintains records of all
examination, sampling, and testing, whether performed in Mongolia, in China, at
W. Fein & Sons, or in North Carolina, and maintains lot number integrity
throughout its manufacturing processes.
Fabric Production
Production in the United States of 100% cashmere fabrics and of
blended cashmere/wool fabrics begins with the withdrawal from Amicale's inventory
in North Carolina of selected lots of cashmere and, in the case of blended
cashmere/wool fabrics, wool fibers. If the desired end product is, for example, a
50/50 cashmere/wool fabric, equal quantities of each fiber will be selected from our
client's inventory, typically 1,000 pounds of cashmere fiber and 1,000 pounds of
wool fiber. The lot numbers of the selected cashmere or cashmere and wool fibers
are recorded, and these fibers are then blended after a mixture of oil and water
equal to approximately 6% of the total weight of fibers has been added. The oil in
this mixture lubricates the individual fibers so that they will be evenly mixed, and
the water provides moisture which minimizes breakage of the individual fibers
.during the mechanical blending process. When the cashmere or cashmere and wool
fibers have been blended to the satisfaction of the Amicale North Carolina Quality
Control Laboratory, the resultant blend is carded into the form of a web, the web is
converted to sliver form, and the yarn is then spun. The finished yarn is then
4

tested to ensure that the yarn is uniform throughout, that is, that the different
length cashmere or cashmere and wool fibers are evenly distributed throughout the
full length of the yarn which has been produced; if the yarn contains both cashmere
and wool fibers, it is further tested to ensure that the two fibers are evenly
distributed in the 50/50 or other specified proportions, as appropriate, at all points.
Amicale notes that the different characteristics of cashmere and wool
fibers, particularly the fiber diameter which, in the case of cashmere, ranges from
14.5 to 16.5 microns, with a maximum of 17 microns, in contrast to the diameter of
wool fibers which exceeds 18 microns, requires particular care in the mixing of these
fibers to yield a uniform blend throughout the yarn run, and necessitates laboratory
testing of the finished yarn to ensure that, whether it is a 50/150or other blended
yarn, the total variation over the run does not exceed 1-2%.
Mer spinning the 100% cashmere or blended cashmere and wool
fibers into yarn, and upon completion of testing to ensure that every finished
blended yarn does not deviate significantly from the specified proportions, the 100%
cashmere or blended cashmere/wool yarns are then woven into fabrics within the
facilities of Amicale North Carolina. As a consequence,Amicale is able to maintain
complete control over this final stage in the production of 100% cashmere and
cashmere/wool blended fabrics, and, as in each of the preceding production stages,
Amicale is able to ensure that no materials other than the tested yarns spun by
Amicale are introduced into the finished fabrics. The finished fabrics are, in fact,
made from and composed solely of the yarn spun by Amicale from the cashmere and
wool fibers maintained in our client's inventory; our client's strict control over all
phases of manufacturing eliminates any possibility of the introduction of any other
non-specification yarns or fibers.
5

l\ODE & ~UALEY
Amicale's Laboratory Eguigment and Personnel
The quantity of cashmere fibers purchased by Amicale, coupled with
the volume of production at our client's integrated facilities, has led Amicale to
conclude that they cannot depend upon outside laboratories to conduct the
quantitative and qualitative testing and analyses at each of the stages of
procurement and manufacture of these high-quality luxury fabrics which our client
has determined are necessary for the production of 100% cashmere and blended
cashmere/wool fabrics which will meet the standards of Amicale and its customers.
While Amicale does use outside laboratories for some purposes, the scale and
volume of Amicale's manufacturing operations are viewed by our client as
sufficiently great enough to warrant the investment in appropriate equipment and
qualified personnel at their facilities in Mongolia, the United Kingdom, and North
Carolina.
The testing performed in Amicale's laboratories is conducted in
accordance with the standards and methods used by accredited independent
laboratories; in particular, Amicale's laboratories follow all applicable Standards
and Procedures approved by ASTM and the Cashmere and Camel Hair
Manufacturers Institute, of which latter organization the President of Amicale,
Boris Shlomm, is one of the two co-founders. Attached to this letter, as Exhibit A, are
lists of the equipment maintained in each of Amicale's laboratories, as well as lists of
.the personnel employed in each of those laboratories, with a summary of their
experience and qualifications.
6

Conclusion
Amicale believes, based upon over fifty years of experience in the
production of 100% cashmere and cashmere/woolblended yarns and fabrics, that they
take appropriate steps to ensure that all of their cashmere and cashmere/wool yarns
and fabrics will not vary from their stated fiber content for any reason other than "a
small amount of unintended inconsistency in the manufacturing process," for purposes
of the Textile Fiber Products Identification Act, or "unavoidable variation in
despite the exercise of due care to make accurate the statements" on	manufacture
We would very much	their labels, for purposes of the Wool Products Labeling Act.
appreciate your advising us whether, on the basis of the information set forth above in
this letter and the material included in Exhibit A, you would agree that the
procedures followed by Amicale constitute "due care" to ensure the accuracy of the
labels applied by Aniicale to their finished 100% cashmere and blended cashmere/wool
In the event you need additional information about the yarns and fabrics	fabrics.
produced by our client, please do not hesitate to call me at your convenience
JSR/cps
Enclosure
7

P.~2	Nov'-13-01 03:31P
13-t--OJ-2001 10:~ FR(J1 lJ F=EI N ~ S!J-IS TO ~I~ P.O2/16
Q~a1ity Cobtrol PenoDQel& EouinmeDt/P~cedura at Mouaol-Amicale.JY
QC O~rativ.£~
Tumendemberel- Raw MaterialsManage!
1.
2.
3.
4.
5.
6.
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8.
9.
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Bulgan -Sorting
Badamsetseg -Sorting
Munkhzul -Sorting
Otto Suren -Scouring
Horol Suren-Scouring
Bolonuya -Scourinj
Alginnaa -QC Mllnaaer/Dehairing/Press Control
Enkhtungalag -Dehairiu&fPress Control
Unmchimig -Carding/Spilming
Z 01tuy a -C aring/ Spinning
~guinment Used in Laboratorv:-
Micron -Projectina Microscope
Micron -Summa Sketch3
Scollrini -WlRA Grease Extractor
Scouring -Soxhlet ApparatuS
Scow-jng -Precision Economy Oven
Scouring -AND Moisture Determinine Balancc
Dehairing-Alfred SuterCo. LengthTester
Carding/Spinning -Henry L Scott Strength Tester
Carding/Spinning -Twist Tester
Carding/SpiMing -Brown 81.Sharpe Count Tester
Carding/Spinning -James H Heal Strength Tcste:r
CaJ-dingiSpinning- CCV Teater
Carding/Spinning -Uster Tester 3
Carding/Spinning -WtRA Graphing Balancc:
Carding/Spinning-Uster Roving Sensor
Electronic Balance x 3

Nov-13-0103:32P
1';'-f'U}-~l. ~~: ~ P.cjJ4	..~ t.JFEIN AtJD50'S TO ~ICALE P.04/16
Quality Control Laboratory
W. FEIN & SONSLIMITE!)
Lahoratorv ~uilment
WIRA Rapid oil contenttester
HC31'swrap reel
Black boards I whitc boards I velvet board
UsterAutomatic ~omctc (Str8nith and Elonaation)
Us~er Evenness tester
Heal'! Two-fold tWisttester
SUtercomb ~orter
WIRA Fibre fiDCDefSmI;ter
Torsionbalance
Digital bWance
Heal's conditioning oven
Heal's ayrow.sh.
Bauschand Lomb projection mieroscope
Samplecard
Sampl~spinne::r
Streatelectroni~moisture meter
ElectrOnic moisture probe
Li~ cabinet
Fumc cupboard
Hot plat~
various chemicals (for oil extncUon,dye mipping, scouring)
Matsuya 12 gaugcknittini roacbine
Tritex LT1OI 5 puge circl\latbUningmachlnc
10 gaugestrap knitting machine
Air condjtioD~ laboratory
Comnute'r:

Nov-13-0103:32P
J...)-~1-,,-~1 l~: ~ P.~5	~~ W I-clN ru~ 5()£ TO 1:t1ICALE P.05/16
Julie Ann Smith
Quality Control Manaler
Responsibilities.Oreanisation and day.to-day running of the Quality Control l.aboratory
.Monitoring of dehai red cashmere and yarn quality to ensure that the
reQuired standards are met.
Education and Qaaaliftcations
1983-1990 Lanpands Community College, St. N8otS~ Camba.
Three A' levels (advanced leve'). one O' 'evel (ordinary level) and Eight GI:SE's
(Genera! certificate of secondary .ducatlon:,
The University of Hudder5field. Huddersfi.ld, West Yorks.
1990-1994
BEng. (Bachelor of Enlineering) In I-extile Manufacture with Clothing Studies
Upper second class honours degree
(subjects incorporated. yarn and fabric: manufacture, computing, enginecring,
instrumentation and control, management, mate(ials science. product
evalu~tion, textile manUfacturing and developments, indu5trlat training).
Work Experience
F'ebr.Sept.1993 J. H. WalkerLimited, ~.n.thorp8, West Yorks-
Ifldustrial training as part of the BEng. Textile Manufacture degree cour~le.
Quality Control Assistant responsible for the daily monitoring of weft krntted
fleece and leisure wear fabrics. Other duties involved colour matching,
compiling fabric reports, 3S51sting with product development. producing fabric
performance standards and product specifications.
March 1995.Present da, W. 'ein" Sons Limited, Bradford, West Yorks.
Quality Control Ma"ag~r .Orpnisation and runntng of the Quality Control
Laboratory. Monitoring of quality standards, dehaired fibre purchases 3"d
assisting in the assessment of greasy and scoured material.
Training
Oct. 1115 YocOltl-McCoIlTestiftC laborltoraH (Denver, USA)
One we~k training tl> use The Suter Comb Sorter (fibre length) and fibre
id~ntification and measurement using a projection microscope, OFDA a,d
Laserscan
Nov. 2001 Yorkshi,. Post Tralninc, Leeds, West Yorks.
"I nsight to Mansgement" Management training course.

~ r t<U'1 I" I-~ I N ~ND :;LJ"S TO AMICALf:: P.06/16
ClaireLoui.eArmital8
Job Title
Quality Control Laboratory Technician
Reapon;i billtles
.Daily monitoring of dehalred cashmere quality.
.Routine te~ting of cashmere fibre to ensure required standards are m~t
.Perform tests to ensure that yarn proces$ed by commission dyers an(i
spinner'Scmeets required $tandards.
Edueatlon Deta11s
1"6~19'4 Hanley High School & Stxth Form Centre
One A' Level (advanced level), ten GCSE's (General certificate of second~ry
education). City & Guilds (Information Technology) and RSA (Royal SOClf!ty of
Arts) (D~sk top pub/ishini).
1997-2000 Modern ApprenticeshiP
8TEC (8usinesfo Technical Education Council) National Certificate in Textile
Technology
BTEC Higher National Certificate in Textile Technology
NVQ (Nationa[ Vocational Qualification) in Manufar..-turing Textiles (1extile
Laboratory Technician)
NEBS (National Examination Board) Management
Trainee of the Year BTEC Natlonat Certificate Year 2. 1998
Trainee of the Year BTEC ~igh8r National Certificate Year 1 .1999
John 5 Dryer Cup for Innovation of Raw Materia! -1999 & 2000.
Work Experience
Oct 1990 R. Butterworth .& Sons (Hudder$field W Yorks)
School work experience. Observed and took part in various practices around
the spinning mill, conc&ntrating mainly on the twisting operation.
Oct 1994-Mar 1196 Patons RTN (Huddersf1eld W Yorks)
Trained as a y~rn colour matcher at ths carding and spinning mill
Mar 1996-Present Day W. Fein ..Sans (Bradford W Yorks)
Trained as a Quality Control Laboratory Technician at the Ceshmer8
Dehairers.

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