FTC: Made In The USA Comments Concerning Jean-Rene Gougelet--P894219
July 31, 1997
Office of the Secretary
Dear Mr. Secretary:
We are a domestic glass tableware manufacturer located in Millville, New Jersey, where we employ approximately 1000 persons.
The proposed changes for "Made in U.S." will create a major problem and in particular the "safe harbor" which allows products whose U.S. manufacturing costs constitute 75% of total manufacturing costs and were last substantially transformed in the U.S.
This will create a major difficulty when materials from the Third World countries or other sources of extremely cheap labor, produce goods, ship them to the U.S. and a U.S. "manufacturer" utilizes these items transforming them into final form and professing it exceeds the requirement that U.S. manufacturing be 75% of total.
We see a potentially horrendous impact to our stemware business. Stemware is created by heat fusing a stem and a bowl to create the finished wine glass. Cheap labor imports of stems and bowls to be fused in the U.S. can easily be estimated to meet the 75% manufacturing cost requirement as well as the requirement that the object is substantially altered or transformed in the U.S. I am sure many other manufacturing concerns of different products than glass will face similar problems.
Finally, the monitoring of the U.S. "assembly" or manufacturing facilities will be a monumental administrative task. The penalty for misuse of the label "Made in USA" seems unclear, but surely a cease and desist order will be grossly inadequate to repair the damage to the legitimate U.S. manufacturers who have tried to compete in the world market place utilizing American labor and wages.
Thank you for giving us the opportunity to express our opinion on that matter.
Elegance in French Glassware since 1815