FTC: Made In The USA Comments Concerning Peter S. Vaughan, III--P894219 Peter S. Vaughan, III 31 July 1997 Office of the Secretary RE: “Made in USA Policy Comment," FTC File No. P894219 Dear Mr. Chairman, The Federal Trade Commission's responsibility to the consumer and manufacturer alike, is to prohibit “unfair or deceptive acts or practices." In order to fulfill this requirement in the area of claims of origin, the commission can only legitimately allow claims in advertising and labeling that are in fact true. Betraying this trust, by abandoning a 67 year old sanction that requires claims of “Made in USA" to in particular be based on a “All or Virtually All" standard, is unfair to both consumer and manufacturer. Creating a new “safe harbor" for those who would benefit from the marketing advantage an unqualified claim of "Made in USA" for products that are only 75% is a legal fiction and a breach of public trust. 75% does not mean 75% in the proposed guides. Exceptions allowed for "computation purposes” can reduce the over all percent of U. S. content to as low as 56%. Manufacturers that make products in the United States and over seas and honestly label the percent of domestic content of an item are placed at an unfair advantage. It is difficult to think the Commission can concur with marketers that call a partially full glass full. There is further disappointment in FTC belief that it is in the best interest of the people and industry of the United States to not have full disclosure as to content of it's products. Basing a material weakening of this standard on the mistaken belief that “substantial minorities take contradictory meanings from 'Made in USA' claims" is without merit and will lead to a less informed consumer and skewed market conditions. Marketers must in a free society be allowed to sell products of various "inputs" and consumers have a right to buy products of their own choice. But citizens can not make an informed decision if full disclosure as to content is not made at the point of sale. Sincerely, Peter S. Vaughan IIIPeter S. Vaughan III |