FTC: Made In The USA Comments Concerning Writing Instrument Manufacturers Association, Inc.--P894219
MADE IN THE USA POLICY COMMENT
FTC FILE NO. P894219
WRITING INSTRUMENT MANUFACTURERS ASSOCIATION, INC.
On behalf of the Writing Instrument Manufacturers Association, Inc. ("WIMA"), we are filing these comments regarding the FTC's Proposed Guides for the Use of U.S. Origin Claims (hereinafter referred to as the "Proposed Guides"), that were released in May, 1997. These comments are filed pursuant to the FTC's request for comments concerning the Proposed Guides.
II. IDENTIFICATION OF THE COMMENTOR
WIMA is one of the oldest consumer product associations in the country. WIMA has approximately 100 members, including approximately 30 manufacturers of pens and pencils. WIMA's members are responsible for the vast majority of pens and pencils manufactured in this country.
III. POSITION OF COMMENTOR
WIMA supports the position of the FTC as presented in the Proposed Guides. Specifically, WIMA believes that the FTC's position that a marketer who makes an unqualified claim of U.S. origin must "at the time it makes the claim, possess and rely upon a reasonable basis that the product is substantially all made in the United States," is consistent with consumer perceptions, and is appropriate in today's global economy. WIMA believes that the two alternative safe harbors proposed by the FTC will be helpful to marketers in determining when a product is substantially all made in the United States. However, in order to further assist markerters, WIMA requests that the FTC provide more examples regarding how to compute the "75% U.S. Content" required by one of the safe harbors.
Thank you for your time and consideration in this matter.
David H. Baker
Dated: July 8, 1997