FTC: Made In The USA Comments Concerning A. Hamilton Rostic--P894219

May 10, 1997

Made in the USA policy Comment
Office of the Secretary,
Federal Trade Commission
Room 159,
Sixth & Pennsylvania Avenue N.W.,
Washington, D.C.
USA 20580

Mr. A. Hamilton Rostic
8 Terrace Hill Road
St. Catharines, Ontario
Canada
L2P 2T7

Dear Sir/Madame:

Canada's number one trading partner is the United States. We buy an enormous range of goods from the USA including goods that were imported into the USA. Changing your content rules will not only affect American consumers but Canadian consumers of US, and US imported goods.

Even a simple percentage change or word change has repercussions here. As you know, under the rules for content agreed to in the United States/Canada Free Trade Agreement [USTT] and the North American Free Trade Agreement, goods manufactured in Canada, the United States or Mexico must meet certain content rules for eligibility. Meeting these rules allow the goods to attract a more favourable tariff treatment than non-NAFTA/USTT nations.

The whole purpose of NAFTA/USTT agreements was/is to promote freer trade between the three participating nations. It also encourages an economic incentive to do business within the three nations. This valuable trade advantage is not available to nonparticipating nations and for a very good reason. While wanting to use NAFTA/USTT trading rules for exports to NAFTA/USTT countries, non-participating nations don't want these same rules applied to goods entering their country. Its not that NAFTA/USTT is unavailable to them, it is, the problem lies in a one-way trade barrier that they are unwilling to remove.

Watering down of the “made in USA” rules would give an unfair advantage to non-NAFTA/USTT countries. It would allow them to disguise their products as made in the USA when in fact they are not. Giving them an advantage would be a violation of NAFTA/USTT rules and may encourage further dilution. Furthermore, it would provide a trade opportunity where no trade agreement exists. If you turn the tables the other way, would nonparticipating nations allow that same treatment of NAFTA/USTT goods? How does enriching a high profile off-shore shoe company benefit the NAFTA/USTT economy by allowing that company to claim some but not a substantial majority of the shoe manufacture in the US? It doesn’t.

Trade and manufacture didn't outgrow the “made in USA rule.” Other nations just want to get around it rather than have a level, two way trading field. Sometimes rules that were put in place years ago and recently re-visited, are labeled obsolete or outdated, when in fact they have every bit as much value as when they were cemented in place. Favourable tariff treatment is available to any nation wishing to enter into the same agreement that Canada, the United States and Mexico did. If they want to participate in our economies then they have to face us at the front door, not the back door.

Yours truly,

A. Hamilton Rostic

A. Hamilton Rostic