Federal Trade Commission
Received Documents
July 30, 1996
P894219
B18354900340

                  Congress of the United States
                     House of Representatives
                    Washington, DC 20515-0920

June 25, 1996                    
The Honorable Robert Pitofsky
Chairman
Federal Trade Commission
Washington, D.C. 20580

Dear Chairman Pitofsky:

  I understand the Commission is conducting a review of the standards for the use of "Made in USA"
advertising and labeling claims.  I hope the Commission will consider several important issues as it continues this
review.

  First, I urge the Commission to carefully consider the impact on manufacturers currently meeting the existing
standard of any change to that standard.  Many American companies are able to meet the "all or virtually all"
requirement by investing in American jobs and manufacturing facilities.  These companies have premised their
investment in higher-cost U.S. manufacturing plants on the benefits of the "Made in USA" label.  If the current
standard is relaxed so that unqualified "Made in USA" claims are available for use by companies which do not
meet the "all or virtually all" requirement, those companies who do, indeed, manufacture "all or virtually all" of
their product within the United States will be put at a tremendous competitive disadvantage.  The result
undoubtedly will be a shift away from U.S. manufacturing in favor of increased utilization of foreign labor and
foreign content.  For American companies and American workers, this would be an extremely unfortunate result.

  Second, I question whether changing the existing standard will clarify consumer perception.  I strongly
believe that relaxing the current standard will have the opposite result intended: it will deceive consumers who
understand and expect that "Made in USA" actually means that a product is made in the United States with
American workers and materials.  It would defy common sense to suggest that "Made in USA" means anything
less than "all or virtually all" U.S. made.

  The use of qualified advertising and labeling claims would further encourage accurate consumer perceptions
about the origin of the products which they buy.  Under the
Commission's present system, companies which do not meet the "all or virtually all" standard may use qualified
claims that provide truthful, non-deceptive information about the American materials and labor used to make their
products.  In this way, consumers are ensured accurate information with which to make informed purchasing
decisions, while companies are able to promote the value added to their products in the United States.

  Finally, I hope the Commission will carefully consider whether the increasing globalization of our economy
is, in fact, a valid justification for weakening the existing standard for "Made in USA" claims.  I have discussed
this issue with many companies that continue to manufacture in the United States using U.S. materials and labor. 
I concur with their view that the "Made in USA" label has an even greater value in today's global economy both
to American companies and to consumers who care more than ever about the origins of the products they
purchase.  I therefore urge the Commission to retain the existing standard for the use of "Made in USA"
advertising and labelling claims.

                                   Sincerely
                                   Peter Deutsch
                                   Member of Congress

PD/amw