FTC: Made In The USA Comments Concerning I. L. Wein--P894219
August 8, 1997
Office of the Secretary
RE: MADE IN USA POLICY COMMENT: FTC FILE #P894219
We are commenting on the proposed "FTC Guides on U.S. Origin" on behalf of Benrus Watch Company, a Delaware Corporation, and its affiliate Hampden Watch Company, a U. S. Virgin Islands Corporation, both involved in the manufacture and distribution of watches.
We are pleased to note that the proposed Guides recognize the international origin of components for the watch industry inasmuch as this has been a fact for many years.
As we understand it, the mission of FTC control over markings and advertisement is primarily to inform and protect the consumer from misleading or misinformation that would affect product purchases or perception of quality.
Since most watches contain parts manufactured or subassembled in many different countries, it is truly impossible for a consumer to rely on quality from anyone other than the final assembler of the product, who assumes responsibility for its quality.
For years other countries have accepted final assembly of the movement as the country of origin of the finished product, and the U.S. Customs has accepted this standard.
In our case, assembling our watch movements and watches in the U. S. Virgin Islands, as a U. S. company, we take responsibility for the quality of the product and the consumer is entitled to know and count on the reliability of our company and the trademark we stand behind.
By abandoning the "all or virtually all" standard, proposed Guides recognize the reality of the globalization of manufacturing in the U.S. The"substantially all" standard based on the U.S. Customs transformation will enhance the competitiveness of U.S. manufacturers that must rely on foreign parts.
The watches manufactured in the U.S. Virgin Islands meet the "double substantial transformation" safe harbor standard and the correct designation for watch movements and watches assembled in the Virgin Islands should be Made in U.S.A.
I. L. Wein
I. L. Wein
1550 West Carroll Avenue · Chicago
· Illinois · 60607