FTC: Made In The USA Comments Concerning Harold Tuchel--P894219
Enclosed is a letter from one of my constituents who has concern over the administration's policy on the new proposed standards on the "Made In USA" labeling criteria. I respectfully ask you to review the administration's policy on this issue and send me a clarification so that I might be able to respond to my constituent's questions. It would be helpful if you could mark your correspondence with my office to the attention of Daniel Smith.
Thank you in advance for your assistance on this matter.
FIRST AVENUE, NE
E. 4TH ST.
WEST 6TH ST.
email@example.com at internet
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FTC ATTEMPTS TO DECEIVE U.S. CONSUMERS
The FTC commissioners have proposed new standards for made in USA that degrade the worth of such a label. The proposed guidelines themselves introduce a manner of deception and confusion to the consumer unequal to ANY previous FTC standard. The finding of the FTC that consumers may feel that current "Made In USA@(MUSA) items are not entirely made in USA or that consumers have a sense of confusion about the label speaks to the lack of enforcement, supervision, and direction of the current FTC. To dilute the Made in USA label because of poor enforcement and manufacturer abuse is a policy destined to further deceive the consumer. The comments in the MUSA -05/05/1997 news release of the FTC show a clear intent to abrogate the authority to protect and inform the U.S. consumers on MUSA in favor of a "global" view. Clearly such is not and should not be the mandate of the FTC! Consumers who purchase MUSA products clearly desire the highest content of MUSA Production. The current standard demands that such a product be wholly produced in the U.S. This is the standard that should be adhered to!
The proposed rule of 75%. USA gauged an manufacturing cost is clearly deceptive and deceitful to the U.S. consumer. The consumer is not aware of manufacturing costs, and thinks only of physical percent of product. This is exactly the deceit manufactures desire, for the product could be 60%, 70%, or even 80% foreign made components depending on the cost of the American components versus the imported components; as such the FTC is promoting a deception not minimizing confusion since the consumer will never know the true U.S. content!
It should be noted the manufacturing value rule may lead to further exploitation of offshore sources of cheap labor. Manufacturers may try to maximize foreign content by purchasing offshore components at an exploitation price in order to maximize a foreign content and corporate profits. This ruling could persuade manufacturers currently producing components in the United States that it is economical to introduce foreign components in current MUSA products, and therefore cost U.S. jobs. Further job loss in the U.S. by ruling of any agency of the U.S. government should be discouraged! It should be pointed out that many studies show that rather than saving U.S. jobs by allowing easier access to cheap Mexico manufacturing as was earlier theorized, such access actually cost U.S. jobs. A similar effect could be present with this ruling!
A possible effect of the 75% costing regulation would he the interaction between offshore manufacturing facilities and U.S. facilities owned by the same company. It would be possible to utilize creative accounting to maximize the cost of U.S. produced parts and minimize the cost of foreign produced parts. This creative costing would help introduce the greatest physical volume of foreign components into a MUSA product, further creating a drain on the U.S. job base!
new rules. Substantial transformation could amount to plating, hardening, peening, anodizing, sanding and even painting. Although the greatest portion of the product is foreign the final step of a cosmetic or utility operation could be the entire basis for a MUSA label. We have seen this with blanked wrenches and other equipment largely in the fin shed slate that undergo few or one operation before sale. Such operations become the basis for a MUSA label and this is entirely deceptive. Here again creative cost accounting wins approval of the label because the foreign wholesale cost of the semi-finished parts is so low that operations in the U.S. may be padded to add enough cost to win the MUSA label.
It is clear that the new rulings from the FTC are not only deceptive, but seek to appease manufactures who have moved production offshore but wish to continue to utilize a MUSA label. it is not the domain of the FTC to make or endorse trade policy, but to enforce and preserve an effective MUSA policy. In its inception the MUSA label was both a celebration of U.S. productivity and quality and an incentive for manufactures to stay in the U.S. The commissioners have effectively scrapped a policy endorsed by congress in favor of a policy of public deception and wholesale appeasement of multi-national manufacturing. This new policy is not a celebration Of American uniqueness and quality, but a monument to greed and avarice. As such this policy needs direction from congress or the chief executive!