FTC: Made In The USA Comments Concerning Regina Carusone--P894219

Knitted
Textile
Association

386 Park Avenue South, Suite 901, New York, N.Y. 10016(212)689-3807FAX: (212) 889-6160

OFFICERS
President
REGINA CARUSONA
Exec. Vice President, Lee Fashion Fabrics
Executive Vice President
ALFRED GREENBLATT
Pres. Apparel/Home Furnishings
Bus. Unit Guilford Mills
Vice Presidents
JON ADELMAN
V.P., Lida Stretch Fabrics
HANK FINK
Pres. Hank Fink, Inc.
CHARLES FLYNT
Pres., Flynt Fabrics, Inc.
STANLEY KRONBLUM
Knit Div., V.P., Purchasing & Dev.
Concord Fabrics
MARVIN MOSTER
Pres., Claridge Knits
EDWARD MOSKOWITZ
Partner, Fabrictex, Inc.
NAT WEISLER
Pres., Carbert
Treasurer
ARTHUR WIENBERGER
Pres., Arthur Knits
Executive Director
PETER ADELMAN
Counsel
SIDNEY KORZENIK
Past Presidents, Ex Officio
ARTHUR FEINBERG
Chmn., Novelty Textile Mills
PETER FRANK
Div. Mngr., Maiden Mills Industries
STEVE GOTTDIENER
Pres., Andrex Industries
RICHARD LEVY
Marketing Mngr., Fab Industries
ELLEN SCHIFRIN
V.P., Andrex Industries

BOARD OF DIRECTORS
Elected Officers
HOWARD ACKERMAN
C.O.O., & V.P., Maiden Mills Industries
MATTY ARNOFF
Pres., Bojud Knitting
STEVE DAUER
V.P. Mktg., Dyersburg Fabrics
BARRY DICKLER
Merch. Mngr., Claridge Knits
HOWARD ELLIS
Dir. of Knit Styling, Symphony Fabrics
MICHAEL GARSON
C.O.O., JBJ Fabrics
MICHAEL GREENBERG
V.P., Ready to Wear, Guilford Mills
SKIP GEHRING
Dir., Industrial Prod., Gehring Textiles
JOSEPH IURATO
V.P., Mktg. Collins & Aikman Corp.
INA JANOWITZ
Prod. Mngr. of Circular & Woven Goods
Liberty Fabrics
EARL KRAMER
Pres., Concord Fabrics
DAVID KRIVITSKY
Pres., Native Textiles
PETER LAZARE
Senior Acct. Exec., Cleveland Mills
TOM LEOPARD
Bus. Mngr. Circular Knits, Milliken & Co.
GERALD LUBIN
Pres., Ge-Ray Fabrics
JOSH MINER
Pres.,Team Uniform Fabric Co.
Lawrence Mfg.
STEVE MYERS
V.P., Fab Industries
MATT RICHARDSON
Dir. of Development
Milliken Knit Apparel
JAY ROSEN
Sales Mngr., Baras Jersey
RICHARD WOLF
Pres., Richland Mills
MARK WOLTIN
Pres., Markbilt, Inc.

August 8, 1997

Office of the Secretary
Federal Trade Commission
Room 159
Sixth and Pennsylvania Avenue, N.W.
Washington, D.C. 20580

RE: "Made in USA Policy Comment"

Dear Mr. Secretary:

The Knitted Textile Association represents the nations producers and distributors of knitted fabrics. Such fabrics are used primarily for the production of apparel.

This organization urges that the Federal Trade Commission reject the proposal for allowing textile products to be labeled "Made in the USA” even if such a statement is false with respect to twenty-five percent thereof

Such a change is not warranted, as your notice suggests out of "recognition that our policies must keep up with changes in the global economy and ensure that consumers are not deceived” - as if the meaning of the phase is altered by import and export statistics.

On the contrary, it would sanction a deception.

The proposed change would permit a distortion of the plain meaning of the words "Made in USA” with the effect of better promoting the sale of imports. It cannot be justified on the grounds of "flexibility". Any equivocation that produces misleading results might also be described as flexible.

There is a valid consumer interest in knowing where goods so offered for sale here have been produced; especially with the increase in apparel made in countries employing child labor or under other labor conditions abhorrent to American standards and sensibility. These concerns are particularly important to the large sector of the American work force engaged in the nations manufacturing establishments.

 

The Federal Trade Commission should not now depart from the integrity it has represented throughout the decades of its existence.

We, therefore, ask that the proposal for diluting the accuracy of the term "Made in USA” be rejected.

Yours very truly,

Regina Carusone

Regina Carusone
President

CRAFTED
WITH PRIDE
IN U.S.A.