RE: Made in USA Policy Comment, FTC File No. P894219

Darlene Adkins, Vice President of Public Policy
National Consumers League

August 11, 1997

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 virtually all" standard for the use of the "Made in USA" label reflects an honest claim to consumers. Any diluting 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.