FTC: Made In The USA Comments Concerning Robert C Sharp--P894219 Converse Inc. Rt. 4
Box 850, Lumberton, NC 28358 CONVERSE. July 28, 1997 Office of the Secretary Dear Sirs: Converse Inc. is the largest footwear producer of casual and athletic footwear in the United States and the Converse Lumberton NC plant is the largest footwear plant in the country. At the Lumberton plant, we produce the Converse Chuck Taylor All Star, which is sold as a Made in USA product throughout the world. This product has been manufactured exclusively in this country since 1916 and is the only fabric-upper rubber soled footwear product still produced in the United States. As the Chief Manufacturing Officer of Converse Inc., I and all of the almost 1000 employees of the Lumberton plant fully support the proposed new guidelines recently announced by the Federal Trade Commission. We feel strongly that the standard of 75% domestic content and final assembly in the United States meet the realities of a global economy more practically than does the "all or virtually all" standard. In order to remain a domestic manufacturer, Converse has found it necessary to use a limited amount of materials or components to compete effectively with products imported from low-wage countries; moreover, it is impossible to source some materials or components from domestic sources because they are no longer produced in the United States. A substantial percentage of the Lumberton factory's production is exported throughout the world. Without the Made in USA label, these exports would not be accepted in the market place and export sales, particularly in Europe and Japan would decline significantly. We would see a similar decline in United States sales as well. I have been made aware of H. Con. Res. 80. which promotes the maintenance of the "all or virtually all" standard. The resolution alleges that the proposed FTC Guidelines could lead American manufacturers to move jobs overseas. I'm convinced the opposite is true. As far as Converse is concerned, one of the principal advantages of manufacturing in Lumberton NC is the ability to label our products Made in USA. It is a major competitive advantage. If this advantage is denied to us, we would be better off competitively to move our production offshore to benefit from the much lower labor and material costs available to us elsewhere. I commend the Federal Trade Commission for recognizing that a problem exists with the "all or virtually all" standard and for proposing intelligent and realistic alternatives to it. Sincerely, Robert C SharpRobert C. Sharp |