Federal Trade Commission
Received Documents
July 1, 1996
P894219
B18354900190



                      [WELDBEND CORPORATION]

                                   June 28, 1996


Office of the Secretary
Federal Trade Commission
Sixth Street and Pennsylvania Avenue, N.W.  Room 159
Washington, D. C.  20580

               Re:  Made in USA Policy Comment
                    FTC File No. P894219      

Ladies and Gentlemen:

     Weldbend Corporation strongly supports the current "Made in
USA" policy of the Federal Trade Commission.  We believe that no
one should be able to claim that a product is "Made in USA"
unless it is manufactured here in the United States from U.S.-origin materials.

     We produce carbon steel butt-weld pipe fittings at our plant
in Argo, Illinois.  In our industry, being able to make the "Made
in USA" claim is very important.  Our customers want to buy
fittings that are manufactured in the United States from U.S.
steel.  When they choose a fitting that is "Made in USA," they
feel confident about the product's quality and reliability and
they know that they are supporting American jobs.

     At Weldbend, we have made millions of dollars of investments
in plant and equipment to earn the right to call our fittings
"Made in USA."  By combining the most advanced technology and the
most efficient workforce, we have competed successfully against
our competitors from around the world.  We have demonstrated that
it is possible to make world-class fittings right here in
America, without depending on foreign materials or foreign labor.
Because of our efforts, the overwhelming majority of our products
can be marked "Made in USA," and we are constantly increasing
that percentage by expanding our U.S. plant and equipment.

     There are, of course, some in our industry -- and I am sure
in other industries -- who would like to enjoy the benefit of
"Made in USA" claims without working for it.  They would like to
claim that their products are "Made in USA" even though they use
foreign steel or other foreign materials.  
     
     Some of our competitors, for example, would be delighted to
replace the current "all or virtually all" standard with a lesser
standard based on percentage U.S. content or on "substantial
transformation" in the United States.  Adopting either of these
alternatives would replace a clearcut standard with utter
confusion.  Let me explain why. 

     The steel pipe from which a fitting is made represents 100
percent of the materials and a high proportion of the total value
of a fitting, particularly a large fitting.  Therefore, if a
percentage content standard were adopted, larger fittings forged
in the United States of foreign steel might continue not to be
eligible for the "Made in USA" claim, while smaller fittings,
undergoing the exact same processing in the United States, might
suddenly be "Made in USA."  This confusing result makes no sense.

     A "substantial transformation" standard would also be
confusing, in part because "substantial transformation" means
different things.  A "substantial transformation" standard based
on the NAFTA marking rules would enable Weldbend's competitors to
import foreign steel pipe, forge it in the United States, and
call the finished product "Made in USA," even though the imported
steel pipe would represent 100 percent of the materials and a
high proportion of the value of the finished fitting.  Alterna-
tively, a "substantial transformation" standard based on the
marking rules for non-NAFTA products would enable Weldbend's
competitors to import foreign forgings, process them in the
United States, and call the finished product "Made in USA," even
though the imported forging would represent all of the materials
and well over one half of the value of the finished fitting. 
Neither of these "substantial transformation" standards corres-
ponds to the consumer's understanding of "Made in USA."

     Therefore, I urge the Commission to retain the current "Made
in USA" standard and to reject the attempts to dilute it.  Dilu-
tion of the current standard would also dilute the meaning of all
that Weldbend has done to keep the most competitive fittings
producer in the world here in America.  

                                   Sincerely yours,



                                   James J. Coulas, Sr.
                                   President