Mr. Robert Pitofsky
Dear Mr. Pitofsky:
As someone who has studied some American history, I recollect that the Federal Trade Commission was established around 1912 to curb the excesses of " big business " and to protect the American consumer against predatory business practices. It has , over the years, had produced some good results in its protective capacity. However, it seems to be forgetting its real mission, and heading in another, deceptive direction.
I am referring specifically to the idea now being considered, of giving manufacturers more leeway in defining what a "Made in U.S.A. " label means. You now define that term as meaning virtually all " parts & labor be from the U.S.A. Now you want to use the term "substantially transformed" before the goods are placed in the market. Both are "weaseling" phrases which have the potential to allow manufacturers to paint a false picture as to where a product is made, and are designed to confuse, frustrate, and wear down the consumer. It tells me that big business is calling the shots on this one.
I well realize that in this global market many products will have components made elsewhere. If you really want to give the American consumer a truer picture about the domestic contributions that go into a product, first set up a NUMERICAL standard to define what " Made In U.S.A." means, and then give us a label which gives us the percentage of domestic parts in the product & the percentage of domestic work that went into assembling the item. Then we will know if the bulk of the product is truly "American made". I can already hear manufacturers screaming about the extra work this will entail, but in reality they would already have these figures readily available.
After all these efforts over the past 60 years to get Truth in Labelling, please do not take the first step to destroy the protections the consumer has over that time.
Thank you for your time and consideration of this letter.