FTC: Made In The USA Comments Concerning Joseph Moakley--P894219
Congress of the
"Made in the USA" Policy
Office of the Secretary
We are writing to let you know that we strongly support the Federal Trade Commission's proposed new guidelines governing manufacturers' use of the Made in the USA label.
After reviewing the comments the FTC has received to date, and the volume of correspondence from opponents to reach our own offices, we wanted to make certain you were aware that your efforts to rationalize these rules are understood and appreciated by many on Capitol Hill and across the country.
The federal government should do everything it can to encourage the creation and retention of jobs within our borders. And only those products which are made in the United States should be entitled to make that claim in promotional materials. But we agree with the Commission that the World War Two-era rules that govern these standards no longer work.
It is perfectly reasonable, for example, to require a manufacturer which enjoys the benefit of a "Made in the USA label to produce and assemble its product domestically. But the complexities of global commerce today make it highly impractical, and in some case literally impossible, to trace the precise source or each component in the manufacturing process.
That was why we were impressed by the remarkably methodical and thorough FTC effort -- culminating in a two-day workshop to reach out to all concerned -- to draft new guidelines that make common sense while protecting American industry, workers and consumers.
After working for three years, the FTC has crafted a new "Made in America" standard that grasps the complexities of our increasingly global economy. The proposed standard, in our view, comports with a variety of analogous statutory and administrative standards -- from customs and auto labeling rules, to NAFTA and the Buy America Act.
We are well aware that many of our colleagues have reacted to the guidelines with --to put it mildly -- less enthusiasm. We agree with their goals, but believe their proposed Congressional resolution of disapproval would make matters worse, not better.
Our common national objectives are crystal clear: to keep American industry competitive, to safeguard American jobs, and to deal straight with the American consumer.
We believe the FTC proposed guidelines would help accomplish each of these goals. And we are deeply concerned that the Congressional resolution will effectively discourage the very manufacturers who are already making a good-faith effort to keep jobs in the United States. If the standard is so high that it cannot be met, manufacturers will have no incentive even to try.
The FTC docket is replete with criticisms by dozens of well-meaning people like a Missouri man who, based on what he had been told about the question, wrote: "This is very important to me and I wish not to see any cheapening of the label. Either it is or it isn't. Anything else is dishonest.
Unfortunately, the international economic marketplace, for better or worse, is no longer neatly demarcated. An honest portrait of our own economy is now painted not in black or white, but in shades of grey.
We are most concerned that any retreat from the FTC's proposed guidelines will have the effect of scaring away more domestic jobs than we save. For these reasons, we commend the FTC for its work on this matter, and urge the Commission to implement these guidelines in final form.