FTC: Made In The USA Comments Concerning Allegiance Healthcare Corporation--P894219
August 11, 1997
Office of the Secretary
Re: Made in USA Policy Comment FTC File No. P894219
Allegiance Healthcare Corporation's V.Mueller unit is a leader in manufacturing precision surgical instruments. The sourcing of raw materials for these instruments is from a variety of countries including the United States of America.
We believe that the current "all or virtually all" domestic content standard used by the FTC to govern unqualified "Made in USA" labeling/advertising is no longer a realistic benchmark in today's global economy. Informed consumers also understand this to be the case.
The FTC's proposal to adopt a 75% domestic level goes a long way to recognize today's realities. We applaud this proposal and support the change.
We believe that consumers, for all types of products, have a preference for U.S. goods and that labels or advertising that promote "Made in USA" play an important role in some consumer's purchasing decisions. The ability to capitalize on this preference can also favorable influence a company's decision to continue producing in the United States. A 75% requirement for domestic value content would allow a manufacturer with a high level of domestic content in its products to use "Made in USA" labeling and advertising. The current standard is virtually impossible to meet even for a company who believes strongly in manufacturing operations in the United States.
The FTC's proposed change helps all of us and keeps the spirit of the phrase "Made in USA" alive and well. We support the change.
Should you have any questions, please telephone me at 847/578-6663. Thank you for the opportunity to present comments.
John L. Crenshaw