06/10/96 - 160 - Comments for Hager Hinge Company by August Hager, III.

Federal Trade Commission
Received Documents
June 10, 1996
P894219
B18354900160

June 6, 1996


Office of the Secretary
Federal Trade Commission
Sixth and Pennsylvania Avenues, N.  W.
Room 159
Washington, DC 20580

Dear Sirs:

The Hager Hinge Company of St. Louis is the second oldest manufacturing
concern of that city.  It has grown from a blacksmith making iron tires for
Conestoga wagons to one of the largest hinge and related builders' hardware
companies in the world.  The current business includes the global
manufacturing, sales, and distribution of both domestic and imported products
in three primary areas, Commercial, Residential, and Consumer hardware.

We believe strongly in the American consumer's right to know and in truthful
representation of the country of origin of our industry's products.  This
information is essential to making an informed purchasing decision.  We also
believe that it is the responsibility of the government of the United States
to protect that consumer right through regulation and enforcement to prevent
false representations which, in effect, dupe the American citizenry.

As both a manufacturer and distributor with a product mix of domestic and
imported goods, we are particularly sensitive to country of origin markings.
We proudly stamp USA in the brass or steel of those products that we have
manufactured in this country of domestic materials.  Likewise, imported
products are clearly marked as to their origin either, on the products
themselves, or, in the case of consumer retail, on the packages.  In
preparation for NAFTA, we have developed an extensive data base of all our
products, components, and suppliers to ensure complete compliance with the
trade agreement's country of origin requirements.  We have nothing to hide.

Our experience with customers has led us to believe that there is, indeed,
perceived value in the "Made in the USA" marking, at least in our industry.
We do not feel that this perception is unwarranted.  It is apparent that
others also feel that this cognomen adds value to their products.
Office of the Secretary
Federal Trade Commission
June 6, 1996
Page Two



Otherwise, why would they mismark imported goods or launch campaigns to change
the law allowing something less than 100% USA content to be so marked?

Simultaneously, we also recognize that we have entered into a global economy
of sorts.  As a result, the absolute, 100% USA content position may be in need
of adjustment.  Raw materials are often foreign sourced.  Plastics, electrical
energy, lubricants and fuel sometimes come from foreign oil.  This is
unavoidable because of finite US resources or the conservation of finite
resources for future generations.  And, many raw materials simply do not exist
in the United States.

On the other hand, some components are of both high quality and less cost when
foreign sourced primarily because of less stringent environmental and
occupational health and safety regulations.  But, are we to contribute to the
universal problems of environmental pollution and the abuse of basic human
rights to save a few dollars?  Is our greed and the profit motive so great
that we can turn a blind eye to practices that one day might impact the air we
breathe and the political freedom we supposedly cherish?  There are many of us
who feel strongly enough about these and similar issues that we base decisions
relative to our actions on how such decisions impact the issues, both long and
short term.  Thus we rely on "Made in the USA" to mean just that, not 50%, not
60%.

Compromising the reality of global resources with individual personal rights,
responsibilities, and ideals is not a simple task.  It can only be done by
establishing a relatively high domestic content requirement for products
bearing the "USA" or "Made in the USA" mark.  95% is not an unreasonable
minimum.  Further, the calculation should be made on a labor and material cost
basis only, including direct overhead.  Profit is an entirely separate issue
and should not be a part of the calculation.

Yours very truly,

HAGER COMPANIES


August W.  Hager, III
President and
Chief Executive Officer

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