FTC: Made In The USA Comments Concerning Gerald Young--P894219 July 21, 1997 Federal Trade Commission OPPOSING: Proposed Guidelines on redefining "MADE IN THE USA" This letter is written to OPPOSE the draft guidelines on when a product is considered to have been "Made in the USA." According to current FTC rules, products must contain all or virtually all U.S. parts and labor to be labeled or advertised as "Made in the USA." This is both a simple rule and one that meets the common sense needs of the consumer public. The proposed rules would allow a product to be labeled "Made in the USA" if U.S. manufacturing costs are at least 75% of total manufacturing costs, and if the product was last "substantially transformed" within this Country. A related proposal would allow such labeling if the product was last substantially transformed in the U.S. and all Its significant parts were assembled in this country. What these rules seem to ignore is that the manufacturing cost of a product may vary significantly from one country to the next. If an athletic shoe company were to assembly most of its product in a country with very low wage rates, the manufacturing cost to produce a nearly complete shoe might be $1.00. If the cost to add laces and a shoebox in the U.S. (to use the most absurd example) were $3.00, the shoe could be labeled as Made in the USA. When I see that New Balance Athletic Shoes is among the proponents of these rules, I think my example may be accurate. When I read that they feet these rules would be a "clear victory for everyone," I loudly disagree. In a global free market economy, businesses are certainly free to take advantage of all that various labor markets have to offer. In doing so, they currently label their products as made in another country, or if appropriate, "Assembled in the USA." If their customers choose to make their shopping decisions on the basis of cost alone, these companies often succeed. This is their right, and I applaud their keen cost management. However, for those of us who choose to place some importance on US or locally produced goods, the accurate labeling of those goods is our primary means of making our consumer choices. So long as anyone is allowed to use the "Made in the USA" label, no consumer should be forced to conduct extended corporate and customs research just to buy a pair of shoes. For the FTC to adopt the proposed rules would make "Made in the USA" a lie and be a slap in the face to patriotic American consumers. I urge you to abandon this proposal. Sincerely, Gerald YoungGerald Young
Rep. Bob Filner |