FTC: Made In The USA Comments Concerning Alan Grunwald--P894219 Belair"MADE IN USA" POLICY COMMENT: FTC File # P894219 August 7, 1997 Office of the Secretary Gentlemen, I am submitting these comments in response to the proposed "FTC Guides on U.S. Origin" on behalf of Belair Time Corporation, a New Jersey corporation involved in the manufacture of watches, and our affiliate corporation, Belair Quartz Incorporated, a United States Virgin Islands corporation involved in the manufacture of watches and watch movements. Considering that all of the watches we sell are manufactured by our affiliate, Belair Quartz, in the U.S. Virgin Islands, I am extremely interested in the outcome of "Proposed FTC Guides on U.S. Origin Claims". I am very pleased to see that the FTC has put forth these (proposed) Guides, which will ultimately serve as a guideline to American industry, as to what is and what is not of U.S. origin. By abandoning the outdated "all or virtually all" standard, the FTC has taken an important step in modernizing its outlook and in recognizing the reality of the globalization of manufacturing. There are of course those who would contend that the "all or virtually all" for "Made in U.S.A." standard serves to protect American jobs. I vehemently disagree with this narrow, protectionist viewpoint. In today's competitive world economy, it is critical for American companies to be on equal footing with foreign competitors. To continue to subject American companies to standards which are much more stringent then foreign countries impose on their industries, would be a mistake of grand proportion. Without a level playing field, American industry will lose ground to foreign competition, both here and abroad. Ultimately this will result in the loss of countless American jobs, plus the further erosion of our balance of trade, and ultimately our world leadership. Because the consumer often relies upon the origin of a product to make their purchasing decisions, and considering that it is inconceivable and totally confusing to present the consumer with a multiplicity of origin markings, the FTC has recognized that there must be a general basis for the determination of (one) origin, whenever possible. To date, no other formula has presented a fairer and more viable way of accomplishing this than the "substantial transformation" test, used by U.S. Customs for years. The "tariff shift" method of determination of origin (essentially a "substantial transformation" test), is the used by NAFTA as well as most of the international community. The FTC has recognized that it is especially important to formulate, not only a basis of determination of origin, but to present to American companies a clear and concrete set of "safe harbors" for the making of such unqualified (and also qualified) claims of U.S. origin. It is important that the FTC continues to take the lead in setting these standards. Besides the Guides for U.S. Origin, the FTC has recently put forth new comprehensive Watch Guides. While we are still in the process of reviewing these new Watch Guides, it is obvious to me that the FTC has really done their homework this time. On behalf of Belair Time and Belair Quartz, I applaud your efforts in both undertakings, and I support in totality the issuing of the Guides for U.S. Origin as proposed, without revision. Congratulations on a job well done! Sincerely, Alan GrunwaldAlan Grunwald AG/bm BELAIR TIME CORPORATION
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