FTC: Made In The USA Comments Concerning Richard B. Wright--P894219

June 10, 1997

WRIGHT TOOL

Chairman Robert Pitofsky
Federal Trade Commission
Sixth and Pennsylvania Avenue, N.W.
Washington, D.C. 20580

Re: "Made in USA"

Dear Mr. Pitofsky:

The Wright Tool Company is a family and employee owned business that has been manufacturing high quality sockets and wrenches since 1927 in Barberton, Ohio. Our contacts with customers and prospects in the professional portion of the tool market indicates a strong preference both for quality and a product made in the United States. Some people are strong unionists or nationalists and prefer U.S. made tools per se. Others know that historically the U.S. tools have been made to the highest and most comprehensive standards in the world, policed by product liability lawyers in a very competitive market with many large and small companies involved. As one of the smaller companies in the industry, Wright Tool lacks the recognition of our Fortune 500 competitors or the Craftsman brand. But, we gain an important degree of acceptance with a perspective customer when we tell them in person, or by advertisement, that we use no foreign blanks and not even any foreign steel. Indeed, the forging operation, because of its importance, is done by us.

If the definition "Made in U.S.A." were enlarged, it would no longer strictly convey U.S. workmanship and would appear on lower quality tools and would lose not just part of its meaning but all of its meaning. The strict definition of "Made in USA" which now exists is a benefit not only to US manufactures and their employees, but much more importantly, to our consumers who have used it as a definite assistance in purchasing.

Reducing the standard for "Made in U.S.A." to 75% of U.S. content, or even less under some circumstances, has the practical effect of robbing the phrase of most of its meaning. There is some misrepresentation in mislabeling going on now. There is no reason to believe that the people doing this mislabeling and misrepresenting today would have any hesitancy to increase their foreign content while continuing to mislabel and misrepresent. We would be moving down a slippery slope with no good stopping point. Tools are a simple product, with few exceptions, without sub- assemblies or components that could come from a variety of countries. Also, the two most important factors in determining the quality of hand tools are the quality of the steel and the skill and care with which the forging operation is performed. These are the first and second steps in the process of making a quality hand tool and, therefore, the ones most likely not to be made in U.S.A. No amount of inspection of a foreign product will ensure as high a quality level as a U.S. manufacturer with the type of statistical and other in-process controls that Wright Tool has.

I recognize that "Made in U.S.A." has a different connotation for other products and other consumer groups. The Hand Tool Industry will continue to offer the customer a choice of both qualities and countries of origin. I have no quarrel with that or the fact that some customers choose an imported product or lower quality product. My concern is that the choice be a knowing choice. I would welcome the opportunity to answer any questions based on a lifetime of experience in both engineering, manufacturing, and selling hand tools.

I would also like to address the marking issue of separate markings for export under the existing regulations. First, the need to mark exported product differently from domestic product, this only occurs when the product has foreign content. Much of the product sold in the US today has no such foreign content and, therefore, those manufacturers have no problem. The US manufacturer that is complaining about the marking cost, already has four separately branded product lines in the US market that in many cases start with the same blank. So he is already incurring the cost of multiple marking and finds it acceptable. Second, marking is either the last or near to the last operation performed on the product and it is, therefore, perfectly practical to run large lots and carry most of the inventory in an unmarked condition and incur only a small cost penalty. It is this relatively small cost that needs to be weighed against the benefit lost by consumers and by manufacturers without foreign content.

Sincerely,

Richard B. Wright

Richard B. Wright
President

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