THE TRUTH ABOUT "DOWN CLUSTER"

Rumors and mis-information are circulating about the term "DOWN CLUSTER". To correct this false and mis-leading information, IDFL re-iterates the following:

1. DOWN CLUSTER does NOT include any allowance for down fiber.
2. Use of the term "DOWN CLUSTER" will NOT allow manufacturers to more easily adulterate plumage products. In fact, just the opposite is true.

The term "DOWN" is beset with multiple definitions and confusion.
If "DOWN" is used on the sub-label, "DOWN" will have three separate, different definitions in labeling regulations.

Using the term "DOWN CLUSTER" in the sub-label makes it absolutely clear to all manufacturers and retailers that the percentage listed on the sub-label includes only down, nestling down and plumules.

Using the term "DOWN CLUSTER" on the sub-label makes it easier for the consumer to understand the difference between the old FTC label and the new label. Eventually, the consumer can finally compare products world-wide. If "DOWN" is used on the sub-label, "DOWN" will be listed twice on the law label with two different meanings.

The proposed definition of "DOWN CLUSTER" has been modified to make the term crystal clear:

DOWN CLUSTER = The group of components: down, nestling down, and plumule. (Down fiber and other components are specifically EXCLUDED.)

Please contact IDFL directly about any questions or suggestions on the term "DOWN CLUSTER." IDFL will be presenting this term and definition to the world-wide IDFB meeting in June 2000 and would appreciate any comments.

Definitions of "Down" Terms

DOWN PRODUCT

a category of finished products. Countries have criteria for "DOWN PILLOW", etc. in labeling, advertising, packaging, and inserts.
Examples: In Europe a "DOWN PILLOW" must have at least 60% of Europe's legally defined term "DOWN".

"DOWN"
Legal Definition on a Law Label

Most countries have a legal definition for "DOWN" when used on a law label. This often includes allowances for down fiber and other components.

• In Europe, "DOWN" on a law label legally includes 5% down fiber and a 5% manufacturing tolerance.
• "DOWN" in the old USA-FTC law label allowed up to 10% down fiber and 20% other components.
• The new USA standard allows "DOWN" on a law label if the product has at least 75% down cluster.

DOWN CLUSTER(Group of Components)
Used on SUB-LABEL to specify actual % of this component group.

The term "DOWN CLUSTER" defines the group of components: down, nestling down and plumule.

(Down fiber and other components are specifically excluded from this group.)

This group of components describes the most valuable portion of any plumage product.

In the new USA standard, the actual or minimum percentage of down cluster (down, nestling down and plumule) is required on the "SUB-LABEL"

Down, Nestling Down, Plumule

These individual components are defined world-wide. Official technical definitions are found in the ABFLO Laboratory Handbook and the IDFB Technical Manual.

" DOWN CLUSTER "
PROPOSED WORLD-WIDE TERM and DEFINITION.

The word "DOWN" has four separate meanings. This has created world-wide confusion.

1. "DOWN" is used to describe a general product category.
2. "DOWN" is a legal term on a law label(Often Includes fiber & other allowances).
3. "DOWN" is a group of technical components (down, nestling down & plumule). "DOWN CLUSTER" is the proposed new term for this group of components.
4. "DOWN" is a technical term for a specific component.

These multiple definitions for the word "DOWN" have created the following problems:

1. The various definitions are often confused.
2. Both suppliers and vendors have regular product misunderstandings
3. Retailers have difficultly writing specifications for world-wide product orders.
4. Consumers have a difficult time comparing products.

To help solve these problems, "DOWN CLUSTER" should be used world-wide as follows:

DOWN CLUSTER = The group of components: down, nestling down, and plumule. (Down fiber and other components are specifically EXCLUDED.)

What are the advantages of the new term "DOWN CLUSTER"?

1. The term "DOWN" has so many separate and conflicting definitions. When the word "DOWN" is used -- no one can be certain what it means. The term "DOWN CLUSTER" will have a single meaning -- world-wide. It will always refer to the most valuable part of any plumage product, namely the group of components: down, nestling down and plumule.
2. To be effective world-wide, the new term for this group of components must be simple and should already have some common meaning. The use of the terms "DOWN CLUSTER" is well documented for over 30 years.
3. When writing specifications , manufacturers can specify "DOWN CLUSTER %" -- eliminating confusion. Today, if someone orders "72% DOWN", the vendor must always ask: is this FTC down?, European down?, Japanese down?, Australian down?, Chinese standard down?, etc.
4. Consumers and retailers will be able to use a "DOWN CLUSTER" value to compare products, regardless of the conflicting definitions of down in national labeling laws.