Federal Trade Commission Received Documents Jan. 16, 1995 B18354900036 American Pet Products Manufacturers Association, Inc. 255 Glenville Road * Greenwich, CT. 06831 * (203) 532-0000 * FAX (203) 532-0551 January 15, 1996 Office of the Secretary Federal Trade Commission, Room 159 Th Street and Pennsylvania Avenue, N.W. Washington, D.C. 20580. Re: Made in USA Policy Comment, FTC File No.P894219 Dear Secretary: The American Pet Products Manufacturers Association (APPMA.) is a trade association representing approximately 450 pet product manufacturers. Our industry employs more than 25O,000 individuals in the manufacturing, distribution and marketing of specialty pet products, many of which are necessary for the continued comfort of the pet. Additionally, California Aquarium Supply Corp, a recent national survey showed that there are approximately 256 million pets in the United States and that 58 percent of American households have at least one pet. While APPMA will not be submitting a position paper at this time, many of our members have exhibited a strong interest in the standards applied to the use of "Made in USA" claims. In fact, Ms. Alice G. Bean Andrenyak from one of our members, G.G. Bean, Inc., requested that I transmit a copy of the attached December 28, 1995 letter to you. Again, I would like to emphasize that this opinion is that of the company represented and not of the trade association as a whole. However, because of the importance of this issue to our members, I am by this letter requesting that APPMA be permitted to participate in the workshops to be held on this issue. Thank you for your consideration. Sincerely yours, Avis W.Effinger, Esq., General Counsel Enclosure G.G. BEAN, Inc. P.O. DRAWER 638, BRUNSWICK ME 04011 207 729-3708, fax- 207 725-6097 M E M 0 TO: Avis Effinger, APPMA RE: Made In America FROM: Alice G. Bean Andrenyak DATE: 28 December 1995 Our comments concerning "Made in America" or "Made in USA" labeling followed: 1. If "Made in America" or "Made in USA" shows on a label then 100% of labor producing the product and at least 90% of the finished product should be produced in America. Raw materials are not always available within the USA but manufactured goods should be manufactured within the USA to have such labeling. 2. Benefits to Companies not fully manufacturing products in the USA but using "Made in America" or "Made in USA" labeling confuses the consumer into believing they are purchasing products wholly "Made in America" or "Made in USA" as opposed to products that are finished outside of the USA or have the majority of their components produced outside of the USA. This can dramatically increase their profits by the inaccurate labeling. 3. The American consumer is proud of their citizenship and would like to support their fellow citizens in their endeavors to earn income and not give so much work to other countries at the expense of their countrymen. As a byproduct of that patriotism, some other countries products might receive less direct sales if price was the only criteria. However some countries such as Switzerland for watches, Japan for pearls and electronics have notoriety for superior quality and quality control which the U.S. needs to recognize. 4. The domestic content should be at least 90% produced to be labeled "Made in America" or "Made in USA." 5. Guidance that the Commission should offer in respect to "Made in America" or "Made in USA" labeling should include a policy statement with consumer education as well as manufacturer information being available. Labeling should include information as to content of labor and product content being "Made in America" or "Made in USA" if less than 90% compliance is adopted. Consumers should have the right to choose between seemingly similar products based such information so they now do for products made of recycled materials.