03/11/96...Red Devil Inc.?s request to participate in Made in USA
workshop

Federal Trade Commission
Received Documents
March 11, 1996
P894219
B18354900138

Red Devil

March 7, 1996


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


     Re:  "Made in USA Policy Workshop-Comment and Request to
Participate"
     FTC File No. P894219

Dear Commissioners:

     Red Devil Inc. is filing this submission to express its' views on
the advertising and labeling of products with "Made in USA"
representations.  Red Devil Inc. is a 120 year old American
manufacturer located in Union, NJ.  We are a leading manufacturer of
tools and chemicals for industrial, professional, and consumer use.
Red Devils' operations are global with export sales throughout the
world.  Red Devil Inc. employs 250 persons at two manufacturing
locations in Union, NJ, and Pryor, OK.

I. Substantial Transformation test preferable to ?all or virtually
all? standard.

     Red Devil Inc. is in strong support of the comments made by The
Stanley Works in their submission to the Commission of January 18,
1996.  A great majority of our products are manufactured in the United
States.  Those that are imported are clearly marked with the country
of origin.  Many of our manufactured products are proudly exported
with the "Made in USA" representation.  Products for export can have
different labeling standards than those for domestic sale.  This can
result in multiple packaging requirements for the same products
resulting in higher costs to the consumer.  Red Devil believes a
single standard, such as the substantial transformation test, would
best serve the American consumer.

     The extremely narrow definition of "all or virtually all" as
supported some comment letters serves the interest of a small number
of manufacturers at the expense of the American consumer.  Denying the
"Made in USA" representation to products meeting the substantial
transformation test could be a deception in itself.  We suspect the
Americans who manufacture these products in the United States would be
upset to learn they can not say their products are "Made in USA".

II. Tariff classification change with supplemental criteria preferable
to quantitative criteria for determining
substantial transformation.

     Red Devil believes that a quantitative standard for determining
whether a product is "Made in USA" would be arbitrary, inefficient,
and not in the best interest of the American consumer.  This would not
reduce the need for maintaining dual inventories, and would create
confusion by maintaining multiple standards across several regulatory
agencies.

     The substantial transformation test would be consistent with
NAFTA, more likely to stand up to foreign challenges under GAAT, and
minimize costs to the benefit of American consumers.

III.  Conclusion.



Red Devil, Inc., 2400 Vauxhall Road, P.O. BOX 3133, Union, New Jersey
07083-1933
     Phone:    (908) 688-6900 FAX: (908) 688-8872

     Red Devil Inc. believes the best interests of consumers and
manufacturers will be met by utilizing the substantial transformation
test for representations of "Made in USA".  This will allow US
manufacturers to sell products domestically, and for export, with the
best efficiencies.  Maximizing efficiency is critical to allow US
manufacturers to compete effectively in world markets.  Red Devil, and
many other companies, are experiencing growth in export sales.  This
increases manufacturing efficiencies and the US balance of trade; both
are in the interest of American consumers.

     It would not be in the best interest of most Americans to allow
an obsolete "all or virtually all" standard to create confusion,
inconsistency between various government agencies, and manufacturing
inefficiencies.  All Americans benefit from the expansion of US
manufactured products into world markets, both in terms of jobs and
income.  The Substantial transformation test will best promote that
expansion.

IV.  Request to Participate in Made in USA Workshop.

   Red Devil Inc. requests the opportunity to participate in the
public workshop to be held March 26 and 27, 1996 at FTC Headquarters
in Washington, D.C., and would be represented by our chairperson Ms.
Jane Lee.  My telephone number and fax number are included on the
first page of this submission.


Sincerely,



Gregory T. Lawn, CPA
Vice President, Finance
Red Devil Inc.