Submission Number: 00007
Received: 10/12/2012 6:16:55 PM
Commenter: Brett Bartleson
Agency: Federal Trade Commission
Initiative: 16 CFR Part 301: Regulations Under the Fur Products Labeling Act; FTC Matter No. P074201
Attachments: No Attachments
Subject: Fur Rules Review, Matter No. P074201, Require "Raccoon Dog" on fur labels
To Whom It May Concern,
Regarding Fur Rules Review, Matter No. P074201: Raccoon dogs are among the most mistreated animals for their fur, and consumers deserve to know when fur from raccoon dogs is trimming garments. Inaccurate trade names like "Asiatic raccoon" and "Finn raccoon" are misleading and serve only to disguise the live skinning and other mistreatment of raccoon dogs. Please make sure raccoon dog fur is called raccoon dog fur in advertisements and on labels.
The fur industry has a long history of misrepresentation in order to sell its products. The Fur Products Labeling Act and the recently signed and passed The Truth in Fur Labeling Act were enacted to specifically address this issue. Now the fur industry wants to be allowed to sell Raccoon Dog under the deceptive euphemism of "Asiatic Raccoon" or "Finn Raccoon", so that unsuspecting and unaware consumers are not informed of the actual name of fur product in question, and no doubt so consumers won't make the connection to the live skinning and other abuses of this animal that have been well documented.
The Raccoon Dog, Nyctereutes procyonoides, is a member of the Canidae (Dog) family and is NOT, as the fur industry name "Asiatic Raccoon" implies, a member of the Procyonidae (Raccoon) family. All reputable governmental and scientific sources, including the U.S. Fish and Wildlife Service, the Natural Resources Conservation Service, the Smithsonian Institution, National Geographic, PBS Nature (Season 31/Episode 1) “Siberian Tiger Quest” (October 10, 2012), call this animal the Raccoon Dog.
The FTC Report “Regulations Under the Fur Products Labeling Act” (September 17, 2012) stated in its “Analysis” that the term “Asiatic Raccoon” is consistent with the fact that the animal “has a raccoon-like fur pattern around its eyes”. However, a Spectacled Bear also has "has a raccoon-like fur pattern around its eyes". That does not make a bear a raccoon. A Panda has rings around its eyes. That does not make it a raccoon.
With all due respect do you not understand the concept of an adjective?
Tiger Shrimp, Tiger Sharks and Tiger Lillies can not be called Tigers simply because they have stripes!
Whale Sharks are not Whales. They are sharks!
Catbirds are not Cats!
Butterflies are not Butter!
Raccoon Dogs are not Raccoons. Raccoon Dogs are Dogs! Canids! It's right there in their family name. Canidae!
The Fur Act prohibits misbranding and false advertising of fur products. The labeling of Raccoon Dog of the family Canidae, as a "Raccoon" of the family Procyonidae is a violation of the prohibition on misbranding and false advertising of fur products. The FTC and its members would be party to a violation of the law and could be held civilly and criminally liable, for enacting deceptive and misleading terminology, or for refusing to enact or enforce names and labeling requirements consistent with the intent of the Act.
The stated mission of the FTC is "To prevent business practices that are anticompetitive, deceptive, or unfair to consumers". Referring to the Raccoon Dog, a Canid, or Dog, as a Raccoon is deceptive to consumers, in direct violation of your stated mission. If you choose to use the name "Asiatic Raccoon", you are explicitly choosing to mislead consumers, away from the animal’s common name and scientific relationship to the Dog family, and to a non-existent relationship to the Raccoon family.
In support of the stated mission of the FTC to prevent business practices that are deceptive to customers, and to avoid violation of the Fur Act which prohibits misbranding and false advertising of fur products, please refer to the Raccoon Dog by its correct name, and require that the fur industry use the correct name in their labeling of fur products.