FTC: Made In The USA Comments Concerning Mark W. NeumannTom Latham--P894219
OF THE UNITED STATES
April 23, 1997
Hon. Robert Pitofsky
We understand that the Federal Trade Commission is in the process of revising its rules governing claims about the U.S. content of goods sold in the United States. We are writing to strongly urge that the FTC retain its long-standing rule requiring that goods for which an unqualified "Made in USA" claim is made have "all or virtually all" U.S. content.
Under current rules, 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. The FTC has consistently taken the position that an unqualified "Made in the USA" claim is truthful and not misleading only if the product concerned is "all or virtually all" American made. Some have now suggested weakening this rule so that goods with more than minimal foreign content could be advertised as "Made in the USA." We strongly oppose any weakening of this rule.
Weakening this rule will result in the deception of American consumers who have come to trust the Made in USA label. Products with substantial foreign content should NOT be given this coveted mark of quality. Consumer surveys conducted in connection with an FTC workshop in 1996 showed that a majority of consumers believed "Made in USA" means 100% U.S. origin.
If this rule is weakened, consumer confidence will be shaken and cynicism with government in general will spread. If "Made in USA" is no longer true, why should consumers believe other claims made by manufacturers or by the federal government?
Equally important, weakening the rule could 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 USA" label.
Therefore, we strongly urge the FTC to maintain the existing Made in USA rule.