FTC: Made In The USA Comments Concerning Dale Bumpers--P894219
APR 18, 1997
The Honorable Robert Pitofsky
Dear Chairman Pitofsky:
I understand that the FTC is now revising its rules governing claims about the U.S. content of goods sold in the U.S. I am writing to strongly urge that the FTC retain its longstanding rule requiring that goods for which an unqualified "Made in USA" claim is made have "all or virtually all" U.S. content.
Claims regarding the U.S. origin of goods are voluntary. Vendors are not required to advertise the U.S. content of their goods, but if they choose to do so, the claims cannot mislead or deceive consumers. For many years, the FTC has taken the position that an unqualified "Made in USA" claim is truthful and not misleading only if the product concerned is all or virtually all U.S. - made. It has now been suggested that this rule be weakened to provide that goods with more than minimal foreign content could be advertised as "Made in USA." I strongly disagree with this proposal, or for that matter, with any proposal which results in the diminution of the current rule.
Common sense tells us that consumers will be deceived or misled if products with substantial foreign content are presented as "Made in USA." The consumer surveys conducted in connection with the FTC workshop last year confirm this common sense view. These surveys all show that "Made in USA" claims are an important factor in many consumers' purchasing decisions. Moreover, a majority of consumers polled who were specifically asked what percentage of a "Made in USA" product is made in the U.S. said 100%.
Arguments that the existing rule is outdated in this era of the global market and global manufacturing miss the point. Even if fewer products are wholly "Made in the USA," it does not follow that the meaning of the phrase has changed -- rather, that fewer
products may meet the standard. Weakening the rule could also lead to a loss of U.S. jobs and investment because those companies that have invested in U.S. jobs and production facilities in order to meet the current standard would no longer need to produce wholly in the U.S. to obtain the marketing advantage of a "Made in the USA" label.
For all the foregoing reasons I urge you to maintain the existing rule.