FTC: Made In The USA Comments Concerning Paul R. Sutter--P894219
"MADE IN USA" POLICY COMMENT: FTC File # P894219
August 8th, 1997
Office of the Secretary
On behalf of Ronda Watch Corporation of America, a New York corporation, and Progress Watch Corporation, a United States Virgin Islands corporation, involved in the manufacture of watches and watch movements since 1978, 1 am submitting the following comments regarding the "Proposed FTC Guides on U.S. Origin claims".
The outcome of the proposal is crucial for our US operation, since it would allow us to rightfully mark our watches as made in the USA, to date this is not possible, due to the old guidelines, although our affiliate company, Progress Watch Co., substantial transforms parts into watches with US labor, US guidelines on wages and safety at the workplace. At present we are penalized for manufacturing in the US, but not being able to claim the product of being made in the US, hence we are at a competitive disadvantage compared to goods manufactured e.g. in China at labor rates and conditions which do not compare to our US standards.
The new proposed guidelines by the FTC would finally set a standard as to what is of U.S. origin in regards to watches and by that would allow our companies to pursue a more profitable and growing business, given the opportunity of labeling our watches as Made in the USA and being on a level playing field with the foreign competition.
The fairest test of determination of country of origin is the "substantial transformation" test used by US Customs for years. Same test is used by NAFTA as well as most of the international community.
The FTC has recognized that it is especially important to formulate, not only on 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 qualified claims of U.S. origin. It is important that the FTC continues to take the lead in setting these standards.
Paul R. Sutter
Paul R. Sutter
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