Federal Trade Commission
Received Documents
Jan 22 1996
B18354900087
Secretary

American Electronics Association   AEA
5201 Great America Parkway, Santa Clara, California 95054. Telephone: (408) 987-4200
1225 Eye Street, N.W., Suite 950, Washington, D.C. 20005. Telephone: (202) 682-9110

January 22, 1996

Office of the Secretary
Federal Trade Commission
Room 159
Sixth and Pennsylvania Avenue, NW
Washington, DC 20580

RE:  Made In USA Policy Comment, FTC File No. P894219

Dear Secretary Clark:

The American Electronics Association (AEA) welcomes this opportunity to comment on the
issues raised by the FTC in the October 18, 1995 Federal Register, p 53923.  The AEA consists
of some 3,000 companies whose products include computers, semiconductors, analytical
instrumentation, aerospace equipment, telecommunications products and consumer electronics. 
Our members have a significant interest in issues of labeling and advertising, particularly as they
relate to country of origin determinations.  The Commission is to be commended for re-opening
the issue of "Made in USA" labeling and scheduling a public workshop to gather views on the
issue.

The above-mentioned Federal Register Notice raises many issues, and requests comments on
several specific questions.  While AEA will not address all of these issues and questions, we do
wish to make our strong views on two particular issues known to the Commission:

     1.   We believe that the Commission's past policy of requiring virtually 100% U.S.
     content in order to be labeled "Made in USA" is not only improper and outdated today,
     but it also produces a result that is contrary to the Commission's goal of creating informed
     consumers, because few U.S.-origin electronics products sold to consumers can qualify to
     be labeled as such, and even those that are predominately U.S. are prohibited from touting
     their heritage.  As a result, consumers who desire to support products that create U.S.
     jobs are not provided the necessary information to do so.  The basic question is: Would a
     consumer who favors U.S. goods not want a product that was predominantly or primarily
     U.S.-manufactured? Such a consumer certainly could not make that informed choice under
     the Commission's past policy, because such a product could not be labeled "Made in
     USA".

     2.   We believe that the Commission's past policy regarding "Made in USA" labels has
     contributed to consumer confusion as well as inordinate administrative costs for
     manufacturers and distributors.  There exist numerous tests for country of origin, used by
     other agencies, and the FTC test is not only inconsistent with all of them, it greatly
     exceeds the requirements imposed by any other country-of-origin standard.  The FTC
     should work to develop a "Made in USA" standard that avoids confusion with such other
     existing standards.  Education of consumers will be essential in such a program.

Finally, AEA would like to request formally an opportunity to participate in the FTC's workshops
on these issues.  We believe that we can be a valuable addition to that proceeding by reflecting the
composite views and concerns of thousands of American companies.

Sincerely,

Gregory T. Garcia
Senior Manager, International Trade Affairs