Federal Trade Commission
Received Documents
P894219
Feb 9 1996
B18354900131
Secretary

National Cotton Council of America

1521 New Hampshire Avenue, NW - Washington, DC 20036
(202) 745-7805 FAX (202) 483-4040 - TELEX 650-252-9879 MCI

PRODUCERS - GINNERS - WAREHOUSEMEN - MERCHANTS - CRUSHERS -
COOPERATIVES - MANUFACTURERS

February 6, 1996

Office of the Secretary
Federal Trade Commission
Room 159
Sixth and Pennsylvania Avenue, NW
Washington, DC 20580

Re:  "Made in USA" Policy Comment, FTC File P894219

Dear Mr. Secretary:

     The National Cotton Council (NCC) appreciates the opportunity to comment to the
Federal Trade Commission (FTC) on the FTC guidelines for evaluating "Made in USA claims in
product advertising and labeling.

     The NCC is the central organization of the U.S. cotton industry, representing all seven
segments of the cotton industry from producers through manufacturers.  NCC producer members
produce the cotton processed by the U.S. textile industry and NCC manufacturer member firms
process into yarns and fabrics about three-fourths of the cotton processed in the United States.

     The NCC supports the country of origin rules contained under the Textile Fiber Products
Identification Act (TFPIA).  We do not believe the present rules should be the subject of this
rulemaking.  Since most textile items are addressed by rules and regulations under the TFPIA, we
will focus our comments to thread since it is exempt from regulation under the TFPIA.

     We strongly support the recommendation made by the American Textile Manufacturers
Institute (ATMI) and regional textile manufacturers associations that the FTC's origin rules under
this act address only the fiber components of threads and not de minimum components such as
dyes and finishes.  Under the TFPIA textile producers only consider the fibrous products (i.e.
natural or synthetic fibers) which are formed into yarns or fabrics when establishing country of
origin.  In order to maintain consistency, threads should be treated the same under the FTC Act.

Again, thank you for the Opportunity to comment.  Please do not hesitate to call if you have any
questions or need additional information.

Sincerely Yours,


Patty Adair
Special Assistant, Technical Services


Phillip J. Wakelyn, Ph.D.
Manager, Environmental Health and Safety