Federal Trade Commission
Received Documents
Dec. 26, 1995
P894219
B18354900016


NAHM
National
Association
of Hosiery Manufacturers

90th Anniversary
NAHM 1905-1995

200 NORTH SHARON AMITY ROAD * CHARLOTTE NC 28211-3004
PHONE:  (704) 365-0913 FAX:  (704) 362-2056

Office of the Secretary
Federal Trade Commission-Room 159
Sixth and Pennsylvania Avenue, N.W.
Washington, D.C. 20580

Re:  "Made in USA Policy Comment," FTC File No. P894219

Dear Mr. Secretary:

The National Association of Hosiery Manufacturers (NAHM) is the
trade association representing the interests of those companies
in the United States that produce all types of men's, women's,
and children's hosiery.  NAHM m embers manufacture and market
over 85% of all the hosiery sold in the United States.

The following comments are predicated on NAHM's understanding
that the FTC's consideration of whether (1) it should alter its
legal standard regarding the use of unqualified "Made in USA"
claims, and (2) how domestic content should be measured under any
future standard, does not directly address textiles and apparel,
including hosiery, because this category is governed by the
"Rules and Regulations Under the Textile Fiber Products
Identification Act (TFPIA)."

NAHM believes the issue of "Made in the USA" is especially
complex given today's interdependent world and the rise of
international trade.  The FTC needs to maintain flexibility and
make determinations on a case-by-case basis.  For example, when
Congress amended the TFPIA in 1984, the objective was to clarify
and improve country of origin labeling requirements and increase
consumer awareness at the point of purchase (Rule 33).  As good
as the definitions were for textiles and apparel, they presented
a problem for the hosiery industry.

The Association, working closely with the FTC staff, was able to
demonstrate the manufacture of hosiery is a two-step process:
first, yam is knitted into a cylindrical fabric; and second, by
means of a number of different cutting, sewing, and finishing
processes, the creation of a product.  The ability to label
hosiery products "Made in the USA," regardless of the origin of
the yams or fibers, has proven practical and beneficial to this
segment of U.S. industry, and allowed it to be competitive on
both the domestic and international levels.

The determination that hosiery manufacturing is a two-step
process entitled domestic manufacturers to label their products
"Made in the USA," and assured U.S. consumers that those products
accurately reflect the quality associated with American made
hosiery.

NAHM appreciates the opportunity to submit comments regarding
"Made in USA Policy." Please feel free to contact me if I may be
of assistance.  Best wishes for the Holiday Season.

Very truly yours,



Chuck Brooks
Vice President and Secretary