FTC: Made In The USA Comments Concerning James S. Scott--P894219
The "TOUGH GUY"
Office of the Secretary
SUBJ:FTC PROPOSED NEW STANDARD FOR "MADE IN USA" CLAIMS
This letter is in response to your request for public comment. Our company, a fabricated metal product producer, has been in business since 1904. At that time our name was Sterling Wheelbarrow Co to reflect our initial product line, which continues on today as one of our primary product lines.
It's with frustration that we see low priced, competitive brand wheelbarrows at Mass Merchandisers, claiming to be "Made in USA," when their major components such as handles, trays, wheels, etc. are not made in USA.
Certainly we realize we're in a global economy, and, there may be certain product components, which are no longer made in the US so that a manufacturer has no choice but to go outside the US.
However we are most concerned that by loosening "Made in USA" terminology, it's possible for a foreign product, requiring little or no assembly to merely be pre-labeled &/or pre-packaged to achieve the Made in US" standard. This means lost jobs for US workers.
Therefore, we disagree with the "two safe harbors" definition. In our opinion, in Safe Harbor 1 US Manufacturers' cost should constitute no less than 90% of total cost. Safe harbor 2 is completely unacceptable. If a product is made entirely of foreign parts, it is not "Made in USA".
Thank You for allowing us to express our views on this subject of new standards. Should anyone wish to discuss this further, please do feel free to contact me by phone or fax at numbers given on above letterhead.