FTC: Made In The USA Comments Concerning Martin C. Ritter--P894219

104 Oak Forest Drive
Manchester, CT 06040

June 6, 1997

FTC
Office of the Secretary
"Made in the USA"
Sixth Street and Pennsylvania Avenue, NW
Washington, DC 20580

Gentlemen,

Please reconsider your proposed dilution of the “Made in the USA” labeling guidelines. As a concerned consumer I depend on the label to quickly and easily distinguish those products which are wholly made in this country, which I purchase, from those made elsewhere, which I do not purchase (whenever USA made products are available). I do not wish to have to further research my purchases in order to learn the true country of their origin.

I am not without sympathy for an ostensibly US corporation, such as The Stanley Works, which purchases some forgings for tools overseas and finishes the tools here in Connecticut. However, I feel their "bean counters" should increase the cost of these "bargain" raw materials by the cost of sales lost due to the absence of the "Made in the USA" label and the expense of additional labeling for exported products to arrive at the true cost of these imported goods. Perhaps then the domestic alternatives would seem more competitive.

The issues of honesty and government credibility are really more important than the economic ones. If you reduce the required American content to 75% of the manufacturing costs now, where will you stop? Reading between the lines of public statements of Ms. Elaine Kolish, your associate director for enforcement, I can see the requirement being rapidly reduced to 70% and then to 51% of a variable which can easily be manipulated. Given the greatly lower cost of third world labor and the propensity of large corporations to skirt government regulations, I can foresee a time when a product which is produced overseas is shipped to this country, repackaged, and labeled "Made in the USA" on the basis of the inflated cost of an elaborate package and label.

Finally, I would like to know where a statement of the official mission of the FTC can be found. If it in any way centers on promotion of American business then I would have to ask, "Do not businesses which trade with other American businesses do more to promote American business than those which trade with foreign or multinational corporations?"

Yours truly,