Federal Trade Commission
Received Documents
P894219
Feb 9 1996
B18354900132
Secretary

Porterco, Inc. &                        P.O. Box 1560
The MegaSack Corporation                Magnolia, AR 71753

                                   February 5, 1996
Mr. Robert Easton
Special Assistant - Enforcement
Federal Trade Commission
Mail Drop S-4302
Washington, DC   20580

re: Made in U.S.A. labeling

Dear Mr. Easton:

     Thank you for the opportunity to express my views on the U.S.A. labeling.  Both of the
companies shown above manufacture and market products that are 100% manufactured in
Magnolia, Arkansas, USA.. Even though both companies only use domestic sources for raw
materials, some of Porterco's raw materials are sourced by our domestic suppliers from other
countries, because they are not available here.

     Both of these small manufacturing companies have faced, and continue to face, terrific
pressures from imports.  Porterco, Inc. manufactures and markets sewn, non-apparel consumer
goods - basically bags!  The MegaSack Corporation manufactures FIBC's (Flexible Intermediate
Bulk Containers) which are large bags used by industry to transport dry, flowable items such as
chemicals, seeds and food products.

     We would greatly welcome a fairness in labeling standard, however, this standard must be
simple enough to be understood and enforceable.  With that said, my suggestion would be to
establish a number of clearly defined "terms".  I will offer the following "terms" as my
contribution to your just pursuit of fairness.  In all the examples, source countries of non-USA
labor, materials, subparts or components should be noted, somehow.

1.   Made in the U.S.A. This designation could indicate a final product in which 100% of the
     labor required to manufacture all subparts, components and final assembly was on-shore
     U.S.A. labor.  With at least 50% of all materials used to reach finished product being from
     U.S.A. manufacturers.

2.   Assembled In the U.S.A. This designation could indicate a final product in which 100% of
     all labor required to assemble subparts and components together for final product was on-shore U.S.A. labor.

3.   Made Off-shore in the U.S.A. and Assembled Off-shore in the U.S.A. These designations
     could indicate the same as 1. & 2. above, however, the labor would be from the special
     programs that were established to benefit U. S. possessions, i.e. Puerto Rico, Virgin
     Islands, etc.

     Thank you for your time and consideration of my thoughts.  I hope that you find them
useful.

Sincerely,

Mr. Calvin M. Porter
President and Executive Officer