FTC: Made In The USA Comments Concerning Edwin H. Polensky--P894219

Duchess Industries, Inc.


399 Main Street, Lodi, New Jersey 07644·(201) 916-1122TELEX 650-299-8264

July 24, 1997

Ms. Jodie Bernstein
Office of the Secretary
Federal Trade Commission
6th and Pennsylvania
Washington, D. C. 20580

Dear Ms. Bernstein:

It has come to our attention that the Federal Trade Commission is considering relaxing the marking requirements of "Made-in-USA" involving merchandise part of which is imported and assembled in the U.S. Our company is the only remaining American- owned manufacturer of metal watchbands that produces products totally of raw materials made and assembled in the U.S. Our business is adversely impacted by foreign-made watchbands which are made abroad with cheap labor and materials. Much of this imported merchandise is passed off as being made in the U.S.A. We consider any product that is partially imported not to be a product that should bear the stamp made in USA and urge you and your commission to prohibit the use of that terminology on products which are not totally made in USA with raw materials made in USA. Our products are more expensive because we buy our raw materials made in USA and our labor costs are much higher than abroad.

Very truly yours,

DUCHESS INDUSTRIES, INC.

Edwin H. Polensky

Edwin H. Polensky
EHP:ra Executive Vice President

Manufacturers of BANDMASTER Watchbands