FTC: Made In The USA Comments Concerning Hartmann Luggage and Leather Goods Group--P894219 hartmann ® Hartmann Luggage and Leather Goods Group Peter C. Lathrop Hartmann Drive August 29, 1997 Office of the Secretary Dear Mr. Secretary: The US Federal Trade Commission recently proposed new guidelines to govern unqualified "Made in USA" origin claims. The proposed standard would replace the present standard of "all or virtually all" US content with a modestly revised “substantially all" standard. The revised substantially all standard is defined as 75% US content (labor and materials). Hartmann, Incorporated based in Lebanon, Tennessee, with the vast majority of our production still in the United States, believes that the 75% content standard will help us maintain our domestic manufacturing and marketing Hartmann products made in the USA. The FTC's proposed standard is an important breakthrough because it acknowledges present day, global economic realities. Today, US producers operate in a global economy and contend with a dwindling domestic supplier base. We need some imported components to support our domestic finished goods manufacturing. Also, US producers must compete against foreign suppliers whose wage rates and other production costs fall well below US standards. Most important, we US manufacturers should have the ability to advertise "Made in the USA" to compete against foreign goods and keep our US factories open. The current standard seriously compromises our domestic manufacturing strategy. Hartmann, Incorporated, urges the Commission to continue its efforts to reach a standard for unqualified "Made in the USA" origin claims that strikes a balance between consumer expectations and the realities of manufacturing domestically in a global market place. The 75% content standard is an enlightened approach to achieving such a balance. Sincerely, Peter C. Lathrop PCL/jap Luggage / Business Cases / Accessories |