FTC: Made In The USA Comments Concerning ATMI --P894219 AMERICAN TEXTILE August 11, 1997 Office of the Secretary Re:"Made in USA Policy Comment" FTC File Number P894219 Dear Mr. Secretary: We are pleased to file additional comments with the Federal Trade Commission on the guidelines under review for determining U.S. origin claims. ATMI is the national trade association for the domestic textile industry. Our member companies operate in more than 30 states and account for approximately 80 percent of all textile fibers consumed by mills in the United States. Our views have not changed though the record created by this proceeding has been voluminous. We continue to support the present policy used by the agency to determine the origin of products for labeling and advertising purposes and do not support the newly proposed guidelines. We believe that the origin claims guidelines proposed by the FTC on May 5, 1997, would likely mislead the public by allowing companies to make false claims about components and the assembly of products. The way the agency has defined "substantially all made in the United States" is for a minimum of 75% of the total manufacturing costs of the product to be of U.S. origin, hardly a true indication of the meaning "Made in USA." In our opinion, the 75% level falls far short of the descriptive term "substantially" and will mislead the U.S. public. Though many varied products are affected by these proposed guidelines, origin labeling of most textile products is regulated by rules under the Textile Fiber Products Identification Act (TFPIA). Only a few textile products, such as sewing thread which is exempt from the TFPIA, will be affected by this guideline. The U.S. thread market exceeds $800 million annually. Though we are in a world economy, as stated numerous times throughout this proceeding, we do not believe this is a valid reason to dilute the meaning and value of "Made in USA." Our manufacturing base in the U.S. has worked hard to provide real meaning to this origin designation and we believe that redefining this term as suggested will be mislead U.S. consumers. Though the Commission points out that these guidelines are not binding and are not enforceable as regulations, they will set a precedent for a new agency position which, if approved, will weaken the meaning of "Made in USA" substantially. We hope the Commission will take our views into consideration as the final decision is made on origin claims and we will be pleased to answer any questions. Sincerely, Hardy B. Poole AMERICAN TEXTILE August 14, 1997 by FAX: 202-326-3013 Ms. Beth Grossman Re:"Made in USA Policy Comment" FTC File Number P894219 Dear Ms. Grossman: The purpose of this letter is to expand upon the types of textile products that will be covered by the agency's decision on "Made in USA" guidelines affecting claims in advertising and labeling. Earlier we focused on sewing threads as the primary textile products affected by this proceeding but there are other important industry sectors which will be affected too. In addition to sewing thread, numerous industrial products are manufactured by the U.S. textile industry which are not regulated by the Textile Fiber Products Identification Act. Therefore, these products appear to fall within the guidelines now under review. For example, automotive safety restraint airbag fabrics and the airbags made from these fabrics would be affected by the guidelines. Awnings, and other outdoor cover fabrics; parachute fabrics and parachutes; textile substrates for computer circuit boards; tent fabrics and tents; wallcoverings and many other novel uses of textile fabrics would be covered by the guidelines. Our industry has worked hard to develop high-performance and unique products to serve customers worldwide. The "Made in USA" label on these items is an indication of high quality products for customers around the world and diluting the meaning of this label by reducing the standard for its use would be a disservice to the U.S. public. We believe that requiring "all or virtually all" of the manufacturing costs of products to be domestic is proper for use of the "Made in USA" label and we encourage the agency to maintain its current high standard for the U.S. consumer. Thank you for the opportunity to clarify our position on this important issue. Sincerely, Hardy B. Poole 1 130
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