Federal Trade Commission
Received Documents
Jan 17 1996
B18354900056
Secretary

PACKAGING
MACHINERY                     4350 North Fairfax Drive, Suite 600
MANUFACTURERS                 Arlington, Virginia 29203, USA
INSTITUTE                          Phone:(703) 243-8555
                                   Fax: (703) 243-8556

                         January 16, 1996

TO:       Federal Trade Commission

FROM:     Packaging Machinery Manufacturers Institute
          Timothy P. O'Rourke
          Director of Technical Services

SUBJECT:  Made in USA

The Packaging Machinery Manufacturers Institute (PMMI) is a national trade association whose
more than 350 members manufacture packaging and packaging-related converting machinery in
the United States.

PMMI member companies engage in joint activities designed to improve the packaging industry
as a whole and to provide information, education and services to members, users of packaging or
converting machinery, the government and the general public.

With regard to modifying the legal standard for making a "Made in USA" statement, PMMI
would like to submit the following in response to request for comments (60FR53922).

PMMI Board Guideline of What Constitutes U.S. Origin:

The Board of Directors of the Packaging Machinery Manufacturers Institute defines the phrase
"substantial portion of the value of the machine must be of U.S. origin" to mean that more than 50
percent of the cost of producing the packaging machinery or packaging-related converting
machinery can be directly attributable to these categories:

a)   The direct cost of designing the product.

b)   The cost of fabricating the component parts.

c)   The value of purchased inputs from U.S. sources (i.e., manufactured component parts of
     U.S. origin) for use in the fabrication and/or assembly of the final machinery.

d)   The value of U.S. labor associated with the final assembly of the machinery.

For further information, please call me at (703) 243-8555.


TO/dhw

PACK EXPO 96--The World of Packaging Technology - November 17-21, 1996, Chicago,
McCormick Place
PACK EXPO WEST 97--The Western Packaging Technology Show - October 13-16, 1997,
Las Vegas, Sands Expo and Convention Center