Federal Trade Commission
Received Documents
July 8, 1996
P894219
B18354900335

               ENGINEERS POLITICAL ACTION COMMITTEE
                            LOCAL 675



                          June 14, 1996


Chairman Robert Pitofsky
Federal Trade Commission
Sixth & Pennsylvania Ave. NW
Washington, D.C. 20580

     Re: Made in U.S.A. Policy Comment, FTC File No.  P894219

Dear Chairman Pitofsky:

I am writing to convey my strong support for the Federal Trade Commission's standard for using an
unqualified "Made in U.S.A." claim and to express concern that the Commission should not weaken
that standard.  Under long- standing Commission rules, a company may not advertise its products as
"Made in U.S.A." unless "all of the materials, components, and labor used to make the products are
U.S. origin.  This standard supports investment in U.S. manufacturing at all levels and creates secure,
high paying jobs in this country.  Diluting the "all or virtually all" standard would have a disastrous
impact on many American workers and their families.

The widespread interest in the Commission's review of Made in U.S.A. claims is evidence of the
powerful marketing edge that the Made in U.S.A. label provides.  Together with the Commission's
"all or virtually all" standard that marketing edge provides a compelling incentive for companies to
use U.S. manufacturing and U.S. sources for materials and components whenever possible.  The
results is investment in U.S. production, advancement of U.S. technology, and expansion of U.S.
jobs.  Weakening the Made in U.S.A. standard would  eliminate the incentive to meet the all or
virtually all standard. Many companies that today rely on U.S. manufacturing would be compelled
to shift to foreign sources to compete on price and other factors.
Robert Pitofsky
June 14, 1996
Page two

The Commission's current rules do not create an "all or nothing" dilemma for investment in U.S.
manufacturing.
On the contrary, companies that have substantial U.S. manufacturing but do not meet the all or
virtually all standard may use non-deceptive, qualified Made in U.S.A. claims to inform consumers
of their products' U.S. content.

For these reasons, I urge the Commission not to alter the current standard for unqualified Made in
U.S.A. claims.  The rule provides a critical incentive to invent in U.S. manufacturing and to maintain
valuable American jobs  in the era of globalization of sourcing.


                                   Sincerely,


                                   Robert J. McMenemy
                                   Legislative Director

RJM/jmh