Federal Trade Commission Received Documents June 24, 1996 P894219 B18354900169 CONGRESS OF THE UNITED STATES HOUSE OF REPRESENTATIVES Washington, D.C. 20515-3311 June 7, 1996 Mr. Robert Pitofsky Chairman Federal Trade Commission Pennsylvania Avenue at Sixth Street, NW Washington, D. C. 20580 Dear Robert: I am writing to convey my strong support for the Commission's standard for using an unqualified "Made in USA" claim and to express my strong belief that the Commission should not weaken the current standard, which supports investment in U.S. manufacturing at all levels an creates secure, high paying jobs in this country. Diluting the "all or virtually all" standard would negatively impact many American workers and their families. For years, the Commission has consistently held that a "Made in U.S.A" claim is an affirmative representation that "all or virtually all" of a product in question is of U.S. origin. Therefore, the Commission has considered the use of such a claim with respect to a product that contains more than a de minimis foreign content to be deceptive. The Commission would retain the current rule. The widespread interest in the Commission's review of "Made in USA" claims is evidence of the powerful marketing edge that the Made in USA label provides. Weakening the Made in U.S.A standard would eliminate the incentive to meet the all or virtually all standard. Many companies that today rely on U.S. manufacturing would be compelled to shift to foreign sources to compete on price and other factors. The Commission's rules do not create an "all or nothing" dilemma for investment in U.S. manufacturing. On the contrary, the Commission specifically authorizes the use of qualified claims, such as "Made in U.S.A from foreign and domestic components." Thus, companies that have substantial U.S. manufacturing but do not meet the all or virtually all standard may use non-deceptive, qualified Made in USA claims to inform consumers of their products' U.S. content. Also, it is worth noting that a company's use of the Made in USA claim is purely a discretionary choice. For these reasons, I urge the Commission not to alter current standard for unqualified Made in USA claims. The rule provides a critical incentive to invest in U.S. manufacturing and to maintain valuable American jobs in the era of globalization of sourcing. Sincerely, Charles H. Taylor Member of Congress CHT/cc