FTC: Made In The USA Comments Concerning AAMA--P894219

August 7, 1997

Mr. Donald S. Clark
Office of the Secretary
Federal Trade Commission
Room 159
Sixth and Pennsylvania Ave., NW
Washington, DC 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” issue. AAMA is a national trade association that represents the US apparel industry. Its members produce more than 75% of all apparel made in the US and have operations in almost every state.

The Textile Product Fiber Identification Act (TPFIA) continues to govern the conditions under which apparel firms may label its garments “Made in USA”. There appears to be nothing in the proposed general FTC rules governing “Made in USA” labeling that would modify the TPFIA rules that apply to apparel.

We continue to believe that the provisions of the TPFIA allow our members the flexibility they need to comply with the rules governing the use of “Made in USA”. They can do so without accounting for every button, zipper, spool of sewing thread, etc. The system works without the necessity of determining an absolute single point at which a garment is considered “Made in USA”.

As the Commission knows, the provisions of the TPFIA are being reviewed. This review was undertaken in an effort to harmonize US rules with those of other countries. The concept of “Made in USA” is expected to provide US apparel firms with a marketing advantage as we expand our export involvement in the global market place.

Sincerely,

Carl H. Priestland
Economist