Federal Trade Commission
Received Documents
Jan 19 1996
B18354900065
Secretary

American Wire Producers Association
"Steel Wire and Wire Products for America and the World"

515 King Street
Alexandria, VA  2314-3103
Phone: 703/549-6003
Fax: 703/684-6048
Kimberly A. Korbel
Executive Director
                                
                                
                        January 19, 1996

HAND DELIVERED

Office of the Secretary
Federal Trade Commission
Room 159
Pennsylvania Avenue & 6th Street, N.W.
Washington, D.C.  20508


               Re:  "Made in USA" Policy Comment
                         File No. P894219                      

Dear Sir/Madam:

     On behalf of the members of the American Wire Producers Association, we respectfully
submit the following comments regarding the use of "Made in USA" or "Made in America"
claims in product labeling and advertising.  We understand that these comments will be considered
by the Commission in preparation for a public workshop on this subject.

     The American Wire Producers Association ("AWPA") is a trade association which
represents American manufacturers of steel wire and wire products, including barbed wire, wire
strand and rope,  woven and welded wire mesh and fabric, nails, springs, and wire coat hangers. 
The members of the AWPA purchase carbon, stainless and other alloy steel wire rod from
domestic and foreign sources, and they process or  "draw" the wire rod into steel wire which may
then be further processed into wire products.  Major consumers of steel wire and wire products
include the automotive, agricultural and construction industries.  The AWPA also includes
virtually all U.S. and Canadian manufacturers of steel wire rod as well as 70 to 80 percent of all
U.S. manufacturers of wire and wire products and wire producers in Canada and Mexico.

     The 89 members of the AWPA operate 220 plants in 35 states, and they employ 60,000
American workers.  It is estimated that total annual shipments by AWPA members exceed $15
billion in value.  

     The members of the AWPA have been actively involved with the U.S. Customs Service
for more than twelve years in its formulation of rules of origin for foreign and domestically
produced steel wire and wire products.  These origination rules have generally held that steel wire
which is processed in the United States from imported wire rod is not "substantially transformed"
and, therefore, remains a product of the country in which the wire rod was produced.  The
origination rules of the U.S. Customs Service also generally provide that the manufacture of wire
products in the United States constitutes a "substantial transformation" of the underlying steel wire
and wire rod, making the United States the country of origin of the finished product.

     Recently, members of the AWPA were involved in a ruling by the U.S. Customs Service
concerning the origination rules and marking requirements for steel wire manufactured from
imported wire rod.  This ruling addresses the "Made in USA" issue being considered by the
Commission.  Briefly, the U.S. Customs Service has interpreted its origination rules to require
domestic producers of steel wire which is processed from foreign-source wire rod to mark such
wire as a product of the foreign country in which the wire rod was produced.  The U.S. Customs
Service took this position even in those cases in which domestic wire producers performed
significant and multiple manufacturing processes on the imported wire rod.   Nevertheless, the
U.S. Customs Service has also allowed domestic wire producers to label or mark such wire as
"Processed in USA" and "Drawn in USA" in addition to the required labeling or marking of
"Product of (country)" of rod production.

     Attached for the Commission's review and information are (1) a copy of the ruling  request
concerning the marking of steel wire processed in the United States from imported wire rod and
(2) a copy of the ruling by the U.S. Customs Service in response to that request.

     The members of the AWPA appreciate this opportunity to  submit these comments to the
Commission for its consideration, and we look forward to working with the Commission toward
the goal of establishing clear, consistent and predictable standards for "Made in USA" labeling
of our products.  We invite the Commission to contact us if it has any questions about these comments or if the members of the AWPA can be of further assistance.  We intend to apply for
participation in the Commission's workshop when a formal notice and request for applications are
published in the Federal Register.


                         Very truly yours,



                         John S. Mueller
                         President