FTC: Made In The USA Comments Concerning Union of Needletrades, Industrial and Textile Employees--P894219
Made in USA Policy Comment
UNITE, the Union of Needletrades, Industrial and Textile Employees, views the Made in USA label as an important tool in the fight to keep jobs in the United States. Any change in the meaning of that label, which could cause confusion to consumers, makes the label a less powerful tool.
Many of the garments made in the USA are made by members of UNITE. Although labeling of garments is covered by separate Federal Trade Commission rules and would not be directly affected by the current action. UNITE nevertheless opposes any change in the meaning of the Made in USA label.
Throughout our history, honest, meaningful labeling has been of vital importance to the union. Since UNITEs predecessor unions, the International Ladies Garment Workers Union and the Amalgamated Clothing Workers of America, were founded at the turn of the century, they fought to have their union labels sewn into the garments made in their shops. In fact, when 11 garment workers met in New York City on June 3, 1900 to form the ILGWU, the first thing they did after adopting the name of the new union was to adopt a label for it.
For almost 100 years, these honest labels have assured American consumers that the products they bought were manufactured domestically under decent working conditions. If a garment did not meet these standards 100%, it would not bear the union label. The union reinforced the meaning of the label through a multimillion dollar advertising campaign launched in 1975, urging consumers to Look for the Union Label.
Honest labeling and other forms of consumer education make consumers less likely to buy apparel made in sweatshops. This helps to elevate conditions for all workers in the garment industry.
The Made in USA label has an equally illustrious history. For the last 50 years, the Federal Trade Commission has held firm to its stance that products must be all or virtually all made in America for them to bear the Made in USA label. When American consumers see this label, they believe that the product they are purchasing was made under decent conditions by workers with legally recognized rights. If the standard is changed as proposed, some products which do not meet the all or virtually all standard will still bear the Made in USA label. As consumers learn of the change, they will no longer know what to believe about a product bearing the Made in USA label.
The FTC should continue to focus on providing consumers with the most accurate information possible, to help them make purchasing decisions. If a product was not all or substantially all produced domestically of domestic parts, it could appropriately be labeled, for example, Made in USA of imported fabric, or 60 percent domestic content. This degree of specificity is already required by law for automobiles and textile products. Other companies have voluntarily adopted similar labeling policies.
The FTCs proposed change in labeling standards is a step backwards for consumers rights and education. The Commission should provide the most accurate information possible regarding country of origin and other issues within its purview. When consumers decide which factors they wish to consider in making their purchasing decisions, they should be able to have confidence in the information provided to them.
The FTC supports its plan to water down country-of-origin labeling standards with the argument that the all or virtually all domestic parts and labor standard is not what consumers expect in an increasingly global economy. It is undeniably true that we are living in an increasingly global economy and that consumers have come to realize that fewer and fewer products are being made in the USA. There is no credible evidence, however, that American consumers expect the
Made in USA label to mean that products were produced somewhere else.
Consumers do care. According to polling data, when consumers are informed that a product is American-made, they are more likely to buy it even if it costs 10% more (International Mass Retail Association). If globalization results in fewer products meeting this standard, an educated consumer will still be able to select those products with the highest American content. If consumers interest in buying American-made goods is communicated to manufacturers, more production might be brought back to the United States.
Consumers will only be educated if labels are honest and informative. The best way for the FTC to insure that consumers are able to buy American, if that is their preference, is to retain the strict labeling standards it has adhered to in the past.