FTC: Made In The USA Comments Concerning Sheffield Steel Corporation--P894219 SHEFFIELD Robert W. Ackerman August 11, 1997 Office of the Secretary Re:Comments of Sheffield Steel Corporation Dear Sir/Madam: On behalf of Sheffield Steel Corporation, I am responding to the Federal Trade Commission's (the “Commission”) request for comments on its proposed “Guides for the Use of U.S. Origin Claims” (the “Proposed Guides”). Sheffield Steel is a manufacturer of bar products with mills in Sand Springs, Oklahoma and Joliet, Illinois. We employ approximately 700, 65% of whom are represented by the U.S. Steelworkers Union. In our markets, which include the full range of consumer and industrial steel consuming sectors and the surface transportation industry, the importance of the “Made in USA” representation is very great. As a result, Sheffield strongly opposes the Commission's proposal to weaken the standard for “Made in USA' claims from “all or virtually all” U.S. content to "substantially all' U.S. content. Weakening the standard will lead to consumer deception. It will also deny Sheffield Steel the marketing advantage attributable to "Made in USA" products. It's my understanding that the Commission has found that respondents to its surveys expect a high degree of the content for products given this designation to be produced in this country. For instance, in the 1991 FTC Copy test it was found that 77% of consumers expect a “Made in USA” product to have all or almost all U.S. content. Reducing the standard will deceive a substantial percentage of consumers. The Proposed Guides include two alternative safe harbors which may permit products with substantially less than 75% U.S. content to be labeled “Made in USA”. The first requires a manufacturer to trace only the origins of input that are likely to have significant foreign content. The second permits a manufacturer to average its costs to determine whether a product line meets the substantially all standard. In both instances, these safe harbors will foster significant compromises in the intent of the Proposed Guides. For these reasons, Sheffield Steel strongly urges the Commission to reaffirm the “all or virtually all” standard and not to weaken the "Made in USA" standard. In addition, the Commission should modify the Proposed Guides relating to qualified U.S. origin claims within the existing “all or virtually all” standard to increase the information available to consumers regarding the U.S. content of products. Respectfully submitted, Robert W. Ackerman cc: Don Gaddy, Danaher Corporation Sheffield Steel Corporation * 220 North Jefferson * P.O. Box 218 Sand Springs, Oklahoma 74063 *(918) 241-6596 * An HMK Group CompanyPage Two |