Federal Trade Commission Received Documents Jan. 23, 1996 B18354900109 BROTHER 200 Cottontail Lane Somerset, N.J. 08875 January 22, 1996 BY HAND DELIVERY Office of the Secretary Federal Trade Commission Room 159 Sixth Street and Pennsylvania Avenue N.W. Washington, D.C. 20580 Attention: Donald S. Clark, Secretary Re: Made in USA Policy Comment, FTC File No. P894219 and Made in USA Workshop--Request to Participate, FTC File No. P894219 Brother International Corporation ("BIC") and Brother Industries (USA), Inc. ("BIUSA") (collectively "Brother") hereby submit these comments in response to the Commission s request for comments regarding "Made in USA" claims in product advertising and labeling, 60 Fed. Reg. 53922 (October 18, 1995). Brother also hereby requests an opportunity to participate in the public workshop regarding such claims which is scheduled for March 26-27, 1996. BIUSA, located in Bartlett, Tennessee (near Memphis), is America s largest manufacturer of portable electronic typewriters and personal word processors in the United States. BIUSA s plant in Bartlett employs almost 500 workers. Much of Brother s worldwide product research and development work is also done at Bartlett. BIUSA s products are made in the United States, as are many of the components for those products. Some domestic components are purchased from outside vendors. Others, including sophisticated printed circuit boards, are made in the BIUSA plant to exacting specifications, with designs dependent on the specific model in which the circuit board will be incorporated. BIC, located in Somerset, New Jersey, is the distributor of products made worldwide by Brother and sold in the Western Hemisphere. BIC has four distribution centers in the United States and employs, together with its subsidiaries, nearly 1,500 people. Brother directs these comments to two limited issues identified in the Commission s October 18, 1995 request for comments: (I) whether and to what extent qualified "Made in USA" claims such as "Made in USA of domestic and imported parts" unduly burden an advertiser s domestic content message; and (ii) whether such qualified claims present practical problems which need to be considered (60 Fed. Reg. at 53925). Brother believes that qualified "Made in USA" claims provide an effective and nonburdensome alternative for advertisers who do not wish to undertake whatever burdens may apply now or in the future with respect to unqualified claims or products that are not made entirely with U.S. labor and U.S. components. Brother has long used a qualified statement similar to those cited with approval (60 Fed. Reg. at 53923, 53925) in the Commission s request for comments. We believe that such a statement on a product, at least with respect to typewriters and word processors, provides information which is useful and informative for both consumers and advertisers. Our experience also suggests that use of such a qualified claim does not present any other significant problems. Thus, whatever the action the Commission may take or recommend regarding use of unqualified "Made in USA" claims, it should be aware that a qualified claim of the type discussed above provides a useful, practical, and non-burdensome alternative which meets the needs of both consumers and advertisers, as well as the Commission s enforcement objectives. Respectfully submitted, BROTHER INTERNATIONAL CORPORATION BROTHER INDUSTRIES (USA), INC. By __________________________________ Jeffrey G. Glaser Associate General Counsel January 22, 1996 BY HAND DELIVERY Office of the Secretary Federal Trade Commission Room 159 Sixth Street and Pennsylvania Avenue N.W. Washington, D.C. 20580 Attention: Donald S. Clark, Secretary RE: "Made in USA" Claims, FTC File No. P894219 Dear Sir: Consistent with the extended due date established by the Commission, enclosed are six copies each of the "Made in USA Policy Comment" and "Made in USA Workshop--Request to Participate" of Brother International Corporation and Brother Industries (USA), Inc. A computer disk containing the same document is also enclosed. Sincerely yours, Jeffrey G. Glaser Associate General Counsel