Federal Trade Commission
  Recieved Documents
  Jan. 16, 1995
  P894219
  B18354900031
                                   January 16, 1996
  
  Mr. Donald S. Clark
  Office of the Secretary
  Federal Trade Commission
  Room 159
  Sixth and Pennsylvania Ave., NW
  Washington, D.C.  20580
                               
                                Re: "Made in USA Policy Comment"  FTC File No. P894219
                                
  Dear Mr. Clark:
  
     AAMA appreciates the opportunity to submit its views on the "Made in USA Policy" issue.  AAMA
  is the major national trade association of the domestic apparel industry.  Its members produce more than two
  thirds of all apparel made in the U.S. and have operations in almost every state.
  
     The Federal Register Notice of October 18, 1995 made several references to the fact that textile
  products and apparel are subject to the rules set forth in the Textile Product Fiber Identification Act (TPFIA). 
  Within the TPFIA, section 303.33 indicates that "(2) Each textile product completely made in the United States
  shall be labeled using the term "Made in USA" or some other clear or equivalent term."
  
     Section 303.45 sets forth a list of items that do not apply to the provision's of the TPFIA.  Specifically
  part 12(a) items (3), (4), (5), and (7) excluded from the determination several items not deemed important in
  the determination of a garment that may be labeled "Made in USA".
  
     Without being specific, these two provisions, keep the concept of "Made in USA" to garments made
  of U.S. fabrics, cut and assembled in the U.S., finished and packaged in the U.S., and ready for consumption by
  U.S. consumers.  Garments made of foreign fabrics or assembled in another country must be identified as such
  - "Made in USA of foreign fabric", or "Assembled in Mexico of US components".  The items excluded under
  303.45 are very minor when compared to either the value or amount of fabric, or the labor content needed to
  cut, sew, finish and package a garment for retail.  The criteria of what constitutes "Made in USA" for apparel,
  as set forth in the Textile Products Fiber Identification Act, is a reasonable set of conditions that the AAMA
  members want to retain.
  
     We believe that the provisions of the TPFIA allow a very small degree of flexibility that requires
  "virtually all" the component parts of garments be made in the US and "virtually all" the labor used in
  assembling and finishing garments to be performed in the US.  This can be done without having to account for
  every button, spool of thread, etc.  For the apparel industry the rule works without an absolute single point at
  which a garment is considered "Made in USA".    
  
     Because of the rather unique rules governing apparel under the TPFIA, we believe that the U.S.
  Apparel industry has some insights into a number of the issues on which the Commission is requesting
  comments.  For this reason, we would like to participate in the work shop discussions of the "Made in USA"
  issue that will take place in Washington D.C., March 26-27, 1996.
  
                              Sincerely,
  
  
  
                              Larry Martin
                              President