FTC: Made In The USA Comments Concerning John P. Kelly--P894219
July 10, 1997
REFERENCE: Made in USA Policy Comment. FTC File No. P 894219
Dear Mr. Chairman:
Our company and employees urge you and the Federal Trade Commission to not weaken the position of the Made in USA policy.
In an environment where global markets have become more evident, the position of the truly Made in USA manufacturers, like us, is already compromised by the barriers to free market that are placed on us by the U.S. government when compared to those of competing foreign companies and their governments abroad. From labor & employment laws, taxes, exposure to product liability and environmental regulations, U.S. based companies are dealt a severe disadvantage from the start when trying to compete in this expanding global market.
Many of the competitors in our industry are large multi-national corporations that manufacture all around the world. We have seen many abuses where these companies cloak a foreign made product with the name of one of their U.S. Subsidiaries so that they can misleadingly claim Made in USA benefits. We are constantly battling the practice of our competitors that send partially assembled or large sub-assembled product to the U.S. that is then only final-assembled or finish machined and tested and then identified with a USA label.
Many U.S. based companies have now been forced to source a large part of there iron castings and machined products from Mexico or other off shore sources due to the fact that the cheaper labor and lack of environmental regulations of these countries allows the production of this type significantly cheaper than USA made iron castings and manufactured parts. This practice, while providing competitiveness for a company, will only further deteriorate our U.S. manufacturing base over time unless our government reduces the barriers it has placed in front of U.S. manufacturers.
We have seen the erosion of the small American manufacturer in our part of the country over the last few years and feel that while the Made in USA policy will not directly assist in returning the United States to being the manufacturing leader it once was, perhaps it would evoke some patriotic duty to support and promote the companies and their workers who still do make in the USA.
Again, we urge you to not weaken the criteria and retain the position that currently exists with the Federal Trade Commission's current policy of Made in USA.
John P. Kelly
John P. Kelly