FTC: Made In The USA Comments Concerning Jocelyn Ghanime--P894219 SiSACOCHE
INTERNATIONAL, INC “GRAPHIC” August 5, 1997 Office of the Secretary Washington, D.C. 20580 Dear Mr. Secretary: The US Federal Trade Commission recently proposed new guidelines to govern unqualified "Made in USA” origin claims. The proposed guidelines would replace the present “all or virtually all" US content standard, a standard many American luggage and leather goods manufacturers cannot meet, with a modestly improved “substantially all" standard. The substantially all standard is defined as 75% US content (labor and materials). Sacoche International believes that the 75% content standard will be relatively difficult for a great many US manufactured products to meet. However, the FTC's proposed standard is an important breakthrough because it acknowledges present day marketplace realities. Today, US producers operate in a global economy and contend with a dwindling supplier base. Also, US producers must compete against foreign suppliers whose wage rates and other production costs fall well below US standards. Most important, US manufacturers must have the ability to advertise “Made in USA" to compete against foreign goods and keep US factories open. Sacoche International urges the Commission to continue its efforts to reach a standard for unqualified "Made in USA” origin claims that strikes a balance between consumer expectations and the realities of today's marketplace. Sincerely, Jocelyn GhanimeJocelyn Ghanime |