Federal Trade Commission
Received Documents
Jan. 16, 1996
B18354900049


                     COMMENTS SUBMITTED BY
                   WESTERN FORGE CORPORATION
             SUBSIDIARY OF EMERSON ELECTRIC COMPANY
               ON THE USE OF "MADE IN USA" CLAIMS
              IN PRODUCT ADVERTISING AND LABELING
                              AND
        REQUEST TO PARTICIPATE IN "MADE IN USA" WORKSHOP


                    Office of the Secretary
                    Federal Trade Commission
                            Room 159
            6th Street and Pennsylvania Avenue, N.W.
                     Washington, D.C. 20580



                        January 16, 1996MADE IN USA POLICY COMMENT
F.T.C. FILE NO. P894219



     Western Forge Corporation, a subsidiary of Emerson Electric
Company, is pleased to have the opportunity to respond to the
Federal Trade Commission's request for comments on its "Made in
USA" policy.
     Western Forge, a domestic manufacturer of hand tools,
strongly favors retention of the current Federal Trade
Commission's policy with regard to "Made in USA" claims.  Our
understanding of this policy is that a manufacturer may claim
that its products are "Made in USA" only if all, or virtually
all, of the component parts of the product are made in the United
States and all, or virtually all, of the labor in assembling the
product is performed in the United States.
     It is Western Forge's opinion that the end consumer of the
products we manufacture expects "Made in USA" claims to hold to
the truest meaning of this phrase.  The Federal Trade
Commission's current policy achieves this by providing the most
accurate information upon which consumers can base their
purchasing decisions.
     Western Forge is grateful for the opportunity to express its
views on this important topic and would be most appreciative of
the opportunity to participate in the upcoming public workshop
related to "Made in USA" claims.  For additional information,
please contact Dave Puerta, Senior Vice President of Sales and
Marketing, at (314) 595-1307.