FTC: Made In The USA Comments Concerning Ron Culver--P894219
I sent the following to consumerline@ but, I wanted the webmaster to see the same thing... just a little check on the honesty of the FTC in their search for public comment on Made In America. Please note, this email file is in ASCII, it can easily be saved and posted as could a simple html form on the site... Here is the copy of email to consumerline:
I've just visited the FTC web-site and read the material regarding "Made In America." From what I see, the FTC is no longer concerned about consumer protection.
In the "Request for Public Comment" regarding this... it says "Individuals filing comments need not submit multiple copies or comments in electronic form. Submissions should be captioned: "Made in USA Policy Comment," FTC File No. P894219."
If you really wanted to know what the American people think about this idea, you would post a form page on the FTC website and find out very quickly. But, as newspaper accounts show, this is more about politics than honesty or consumer protection, and it seems the FTC is more interested in the political end of things than they are in maintaining the trust of the buying public.
Whatever the case, you have following - my comments about the proposal to modify the "Made In America" law. What you do with it remains to be seen...
Saying that if 75 percent of a product's manufacturing costs were incurred in this country and its assembly completed in the United States, it would qualify for the Made in U.S.A. label is outright deceit. Here - between the lines - is a somewhat edited example someone gave me.
<----- example ----->
Take a hypothetical case concerning a pair of army boots. Boots manufactured in Communist China for the United States Army use slave labor at $0.12 cents an hour. Total cost of the boots, including material, labor, amortization of plant and equipment, and shipping by COSCO to the US, can be conservatively estimated at $3.00 per pair of boots. These are unfinished boots.
They need two things to complete their fabrication - a stick-on label and a rough shine. The US customs applies a tariff of $2.40 instead of $24.00 because of Communist China's MFN trade status. The US manufacturer now gives it a label (the label was printed in Canada) and a rough shine. A woman, supporting two kids, making $6.00 an hour (she was downsized from $14.00 an hour, when the company moved the factory to Communist China) applies the label, gives it a QA inspection, a rough shine and reboxes the boots in 10 minutes. We are now up to $6.40 manufacturing costs. Adding employee supervision costs, amortization of US plant and equipment, meeting EPA waste disposal costs, OSHA safety education and safety implementation costs, workman's comp, various taxes and insurance, etc. etc., takes us to a total of $12.00 for that pair of boots. Since $9.00 is 75% of $12.00,
the boots now meet the FTC's labeling guidelines. The manufacturer then fulfills his contract to the US Army for $97.50 per pair and feels very patriotic because the boots were not made in Communist China. They are now labeled "Made in the USA" and we are the ones that get shined" (while losing the rest of our shoe industry).
<---- end example ---- >
It is just this kind of dishonesty the FTC has come up with in talks with multi-national companies who want to deceive the buying public. I find it reprehensible - and a further backhand of the fed- gov to those manufacturers who have not trotted off overseas looking for cheap labor.
If the FTC wanted to do the right thing in consumer protection, they would strengthen the current law - not weaken it.