FTC: Made In The USA Comments Concerning Robert E. McLaughlin--P894219

CONVERSE.

Converse Inc. 801 N. Bryan Road, Mission, TX 78572
tel 210.519.2022
fax 210.519.2928

July 24, 1997

Office of the Secretary
Federal Trade Commission Room 159
Sixth and Pennsylvania Ave. NW
Washington, DC 20580

Dear Sirs:

As the Plant Manager of the Mission, TX plant of Converse, Inc. I fully support the proposed new guidelines for labeling Made in USA recently announced by the Federal Trade Commission.

In an economy that is becoming increasingly global it is no longer possible to manufacture products with 100% U.S. materials and labor. This is especially so in an industry such as rubber footwear since many domestic suppliers have followed production overseas and many materials and components can no longer be sourced in the United States. Further, our competition is from imports from the low-wage countries of the world and we cannot compete effectively using only high cost domestic materials and components.

Converse Inc. is the largest U.S. producer of casual and athletic footwear and our principal domestically manufactured product Converse Chuck Taylor All Star has been Made in USA since 1916. A significant percentage of our current production is exported to world markets. Without the Made in USA label, these markets, particularly in Europe and Japan would disappear. U.S. sales would also decline. This the Made in USA label is vital to Converse's continued U.S. production and employment.

We are aware of H. Con. Res. 80, which alleges that unless the "all or virtually all" standard is maintained, American manufacturers would move operations overseas. We believe just the opposite is true. In the Converse situation, without the Made in USA label, we would lose our major competitive advantage since we are the only remaining domestic manufacturer of canvas upper, rubber soled, vulcanized footwear. Without the Made in USA label, there is no economic justification for continuing domestic production and employment.

Sincerely,

Robert E. McLaughlin

Robert E. McLaughlin
Plant Manager
Converse, Inc.

REM:grr

Office of the Secretary.doc