FTC: Made In The USA Comments Concerning Bruce DeBon--P894219
July 31, 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 guidelines would replace the present all or virtually all US content standard, a standard many American luggage and leather goods manufacturers cannot meet, with a modestly improved "substantially all" standard. The substantially all standard is defined as 75% US content (labor and materials).
DeBon Leather believes that the 75% content standard will be relatively difficult for a great many US manufactured products to meet. However, the FTC's proposed standard is an important breakthrough because it acknowledges present day marketplace realities. Today, US producers operate in a global economy and contend with a dwindling supplier base. Also, US producers must compete against foreign suppliers whose wage rates and other production costs fall well below US standards. Most important, US manufacturers must have the ability to advertise Made in USA to compete against foreign goods and keep US factories open.
DeBon Leather urges the Commission to continue its efforts to reach a standard for unqualified Made in USA origin claims that strikes a balance between consumer expectations and the realities of today's marketplace.
MANUFACTURERS OF QUALITY