Office of the Secretary
Federal Trade Commission
Room 159
Sixth & Pennsylvania Avenue, NW
Washignton, DC 20580
RE: Made in USA Policy Comment, FTC File No. P894219
WASHINGTON, DC, August 11 --The National Consumers League strongly opposes the
Commission's proposed "Guides for the Use of U.S. Origin Claims." We believe that the
current "all or vitually all" standard for the use of the "Made in USA" label reflects an
honest claim to consumers. Any diluding of the standard will lead to consumer
misinformation and deception.
Founded in 1899, the National Consumers League is America's pioneer consumer
advocacy organization. Its mission is to identify, protect, represent, and advance the
economic and social interests of consumers and workers.
NCL actively represents consumers and workers in fair labor standards, health care, food
and drug safety, technology and telecommunications, and fraud. For nearly 100 years,
the League has vigorously worked to protect consumers from deception -- in
telecommunications, in labeling, and other forums where consumers may be
misinformaed or misled.
NCL is a member of the Made in USA Coalition which is comprised of consumer groups,
businesses, and labor unions. Coalition members united under the goal of maintaining
the current FTC standard for use of the "Made in USA" label on packaging and
advertisements.
The NCL believes that the FTC proposed guidelines are founded upon three inaccuracies:
Consumer research supports a change to the new guidelines....As the FTC
is charged with upholding truth in labeling, it is imperative that new standards are not
instituted without an exhaustive review of consumer perceptions about the "Made in
USA" label.
no indication of what is deceptive...
Consumers will support a lowering of the standard because they realize that if
they don't, fewer products will be able to carry the label in the emerging global
marketplace.
Consumers, businesses, and government recognize the need for a new standard,
given that the U.S. is participating in an increasingly global marketplace.