Federal Trade Commission
Received Documents
Jan 22 1996
B18354900086
Secretary
               BEFORE THE FEDERAL TRADE COMMISSION
                                                                 
                         COMMENTS OF THE
        BICYCLE MANUFACTURERS ASSOCIATION OF AMERICA, INC.
                     REGARDING "MADE IN USA" 
                 CLAIMS WITH RESPECT TO BICYCLES
                                                                 
                   "MADE IN USA" POLICY COMMENT
                       FTC FILE NO. P894219
                                  Michael R. Kershow
                                  Judith L. Oldham
                                  Collier, Shannon, Rill & Scott
                                  3050 K Street, N.W.
                                  Suite 400
                                  Washington, D.C.  20007
                                  (202) 342-8400
                                  Counsel to the Bicycle Manufacturers
                                   Association of America, Inc.
January 22, 1996               BEFORE THE FEDERAL TRADE COMMISSION
                         COMMENTS OF THE
        BICYCLE MANUFACTURERS ASSOCIATION OF AMERICA, INC.
                     REGARDING "MADE IN USA" 
                 CLAIMS WITH RESPECT TO BICYCLES
                   "MADE IN USA" POLICY COMMENT
                       FTC FILE NO. P894219
     These comments are submitted on behalf of the Bicycle Manufacturers Association of
America, Inc. ("BMA") in response to the Federal Trade Commission's notice soliciting public
comment on the FTC's policies relative to "Made in USA" and similar claims made in connection with
the labeling and advertising of products.  See 60 Fed. Reg. 53,922, 65,327 (1995).  In a letter
accompanying this submission, representatives of BMA have requested an opportunity to participate
in the Commission's upcoming public workshop on this issue.  
     BMA is a non-profit trade association representing the interests of U.S.-based manufacturers
of bicycles and their suppliers.  A copy of its membership list is attached.  The three manufacturer
members of the association  Huffy Bicycle Company, Murray, Inc. and Roadmaster Corporation
 account for approximately 95 percent of the bicycles made in the United States.  In calendar 1995,
these three firms produced over 8.4 million bicycles in seven separate U.S. facilities employing more
than 6,500 workers in connection with the manufacture of bicycles.{1}  The association also has 18
supplier members which supply the BMA manufacturer members and other U.S. bicycle producers
with materials and components.  While several of these supplier member firms are based offshore and
supply bicycle manufacturers throughout the worldwide bicycle industry, many others are relatively
small U.S.-based firms that depend heavily on their sales to Huffy, Murray and Roadmaster. 
Collectively, BMA's supplier members account for nearly 1,300 additional U.S. manufacturing and
related jobs.
     In the first of its two Federal Register notices, the Commission outlined an extensive list of
specific questions that it would like the public to address during the upcoming workshop.  Most of
these issues have already been addressed by BMA in comments it filed in connection with the
Commission's proposed Consent Agreement with Hyde Athletic Industries, Inc., the withdrawal of
which stimulated the Commission's decision to convene the upcoming workshop.{2}  In that
submission, BMA urged the Commission to discontinue its general policy of restricting "Made in
USA" claims to products that are "all, or virtually all" of U.S. material and labor content in favor of
a more commercially realistic standard  that is, contribution of at least 50 percent of a product's
value (using the specific formula prescribed by the North American Free-Trade Agreement
("NAFTA")).  BMA further argued that, at the very least, this should be the operative standard for
products, like bicycles, which are assemblies of discrete components that can be (and frequently are)
separately labeled with their own countries of origin.  Indeed, BMA showed that the Commission
effectively recognized this basic principle in a 1961 stipulated order involving bicycles.{3}
     From an examination of the public record in the Hyde proceeding, it appears that the positions
expressed in BMA's November 22, 1994 submission are consistent with those expressed by
representatives of a number of other U.S. industries.  Since that submission addresses most of the
central policy issues raised in the Commission's Federal Register notices in connection with the
workshop, we wish simply to incorporate our November 22, 1995 submission herein by reference and
to focus in this submission on the unique circumstances of the U.S. bicycle industry and how those
circumstances affect the application of "Made in USA" claims in the context of bicycles.  The nature
of the product itself (and how it is manufactured) and conditions of competition in the U.S. bicycle
market distinguish bicycles from virtually every other consumer product to which a "Made in USA"
claim could be applied.  Viewed in this context, there is nothing at all deceptive about affixing an
unqualified "Made in USA" label to a bicycle that is assembled in the United States and which
contains a substantial percentage of U.S. material and labor content.  
     Anyone visiting the manufacturing facilities of Huffy, Murray and Roadmaster would not
confuse them with simple "screwdriver" operations.  All three firms fabricate bicycle frames and forks
 the "heart" of every bicycle  from steel tubing that is either purchased in bulk or rolled from steel
sheet.  This process involves extensive cutting, forming and welding operations.  All three firms also
fabricate such components as seat posts, handlebar stems, handlebars, rims and some sprockets. 
Wheels are built using specialized machinery and frames and other parts are painted and finished
largely by hand.  Finally, these fabricated components are assembled together with various purchased
parts into substantially complete bicycles, with certain parts (e.g., the front wheel, the handlebars, the
pedals and the saddle) packaged separately in the carton for ease of shipment.  While the amount of
in-house component fabrication may differ for particular bicycle models as commercial factors dictate
 for example, for some individual models, the rims or handlebars might be purchased, rather than
made in-house  the U.S. material and labor content of bicycles manufactured by Huffy, Murray and
Roadmaster always exceeds 50 percent of total product cost.  In many cases, U.S. material and labor
content accounts for a very large majority of product cost.  Since (as discussed below) many essential
bicycle components are simply not available from U.S. sources, this is no small feat.  
     Fundamentally, a "Made in USA" claim on a bicycle does nothing more than distinguish it
from bicycles labeled "Made in Japan," "Made in Taiwan," or "Made in China."  As the employment
figures cited above attest, the manufacture of bicycles in the United States contributes importantly
to domestic employment among both bicycle manufacturing firms and their U.S.-based material and
component suppliers.  For this (if no other) reason, U.S. bicycle manufacturers should have the right
to distinguish their products clearly from bicycles "Made in Taiwan" or "Made in China."  Using a
straightforward, unqualified "Made in USA" statement to do so cannot be regarded as deceptive
when viewed from the perspective of the relevant "reasonable" consumer.
     BMA is well aware of the Commission's 1991 "Print Advertising Study," in which better than
half of the randomly-surveyed individuals interpreted the "Made in USA" statements in a print
advertisement for Huffy bicycles as meaning that over 90 percent of the parts and labor used in the
bicycle were of U.S. origin.  While the survey also showed that almost half of those polled interpreted
the Huffy ad as meaning that some lesser percentage of Huffy bicycles' labor and material content
were of U.S. origin, the results of the Print Advertising Study are of little, if any, relevance to the
question of how consumers of bicycles  as opposed to "consumers" as a generic class  perceive
"Made in America" claims as they apply to bicycles.  It is hardly surprising that a substantial number
of individuals plucked at random from the corridors of various American shopping malls and asked
to view an advertisement for a Huffy bicycle or a Smith Corona typewriter (or virtually any other
consumer product imaginable) would interpret a "Made in USA" statement made in such ads, in
isolation, as implying a high percentage of U.S. content in those products.  
     But few, if any, bicycles are purchased by mail order solely in response to print
advertisements; bicycles are ordinarily purchased in mass merchant stores or in specialty shops, where
any "Made in USA" claims will necessarily be viewed in the context of the designations of origin on
competing products.  When consumers of bicycles confront such claims during the course of making
actual purchasing decisions in retail stores, few, if any, of those consumers would interpret a "Made
in USA" claim as necessarily implying "all, or virtually all" U.S. content.  Rather, consumers spending
even a modest amount of time scrutinizing and comparing the bicycles offered for sale in retail
establishments would unavoidably interpret "Made in USA" on a bicycle  just as they would interpret
"Made in Taiwan" or "Made in China"  as signifying only that the final assembly of the bicycle
occurred in that country and that a substantial portion (e.g., 50 percent) of the material and labor
content of the bicycle originated in that country.  There is, in short, no basis for concluding that
consumers interpret "Made in USA" as different in concept from other statements of origin (e.g.,
"Made in China").  Both statements of origin simply refer to where the bicycle was "brought into
being," and neither implies that "all, or virtually all" of the components of the bicycle necessarily
originated in the United States or China.
     BMA's members are committed to producing bicycles with as high a percentage of U.S. labor
and material content as economically feasible.  Precluding unqualified "Made in USA" claims in the
bicycle industry would cause the proliferation of a bewildering variety of qualified claims that would
increase the possibilities for consumer deception and dilute valid claims by domestic manufacturers. 
For example, a claim that a bicycle was "Assembled in the USA from 75% US parts and labor" would
not communicate the simple, accurate "Made in USA" message that Huffy, Murray and Roadmaster
are entitled to convey:  that their bicycles are produced in American factories and represent the
highest commercially feasible level of American materials, labor and craftsmanship at a certain price
level.  As the Commission noted in discussing the "Smith Corona test," which in part involved Huffy
bicycles, "the Made in USA claims were quite modest and made no express uniqueness or superiority
claims regarding U.S. content."  See 60 Fed. Reg. at 53,929 n.13.  If U.S. bicycle companies are
prevented from distinguishing their products from competing foreign-made products on even this
modest basis, the domestic bicycle manufacturers, U.S. component suppliers and American
consumers would all be adversely affected.
     A simple unqualified "Made in USA" statement is appropriate for labeling bicycles assembled
in the United States that contain substantial U.S. material content because of a number of factors
relating to the way that bicycles are made and sold, which in combination distinguish bicycles from
virtually all other consumer products.  These distinguishing factors are as follows:
     1.   Imported bicycles account for a substantial share of the U.S. market.
     One factor relevant to assessing "Made in USA" claims as applied to bicycles is the fact that
imported bicycles have long accounted for a significant share of the U.S. bicycle market.  In 1994,
imports accounted for 42 percent of apparent domestic consumption of bicycles in the United States;
in past years, imports have captured over 60 percent of the market.  Thus, imported bicycles are
widely present in the marketplace.  Indeed, in the "specialty shop" or independent bicycle dealer
("IBD") segment of the market  which accounts for 25-30 percent of the bicycles sold in the United
States each year  imports are extremely dominant, with only a handful of U.S. firms  most
prominently, Trek and Cannondale  supplying bicycles to that channel.
     Although the U.S. bicycle market is certainly not the only consumer product market in which
imports occupy a prominent role, this factor does distinguish the bicycle market from those product
markets in which imports account for only a small percentage of apparent domestic consumption. 
The prominence of imports in the U.S. bicycle market presents U.S. manufacturers with an immediate
challenge:  how to distinguish their bicycles from the large number of bicycles labeled "Made in
China" and "Made in Taiwan."  The most obvious and straightforward way of doing so is for U.S.
manufacturers to label their bicycles "Made in USA."  As the Commission noted in summarizing many
comments received in the Hyde proceeding, depriving U.S. manufacturers of the ability to utilize an
unqualified "Made in USA" label could prevent use of "a selling tool that could help preserve
American jobs."  60 Fed. Reg. at 53,924.
     2.   Many imported bicycles are labeled in such a way as to suggest that they are of
          U.S. origin.
     The need for U.S. bicycle manufacturers to distinguish their products from imported bicycles
is particularly acute because imported bikes frequently bear brand names or other labeling that tends
to suggest U.S. origin.  In some cases, this is simply because certain brand names are commonly
associated with U.S. manufacture.  Perhaps the best example of this is Schwinn:  even though
Schwinn has manufactured only a very small portion of its bicycles in the United States over the past
decade and dutifully labels its foreign-sourced bicycles as "Made in China" or "Made in Taiwan," it
appears that the majority of Americans continue to believe that Schwinns  the "great American bike"
 are still manufactured in the United States.  Still other importers attempt to create an "American
image" by adopting English-language brand names (e.g., Giant, Specialized, Diamondback, Royce
Union, etc., as opposed to Fuji, Bianchi, etc.){4} or brand names that directly reference the United
States or a particular U.S. locality (e.g., "Pacific USA," "Marin"-brand mountain bikes), or by affixing
American flag decals to their bicycles.  Last but not least is the widespread practice of labeling
imported bicycles prominently with statements such as "Designed in USA" (or some locality).  Even
though these statements might be technically correct, anecdotal evidence suggests that many
consumers interpret these statements as meaning that the bicycle was made in the United States,
particularly in cases where required country-of-origin markings are positioned far less conspicuously
on the bicycle frame.  
     3.   A bicycle is a complex assembly of discrete components, most of which are
          recognized as separate articles of commerce.
     All bicycles have a frame and fork, wheels (consisting of rims, hubs, spokes, and spoke
nipples), natural or synthetic rubber tires (and usually, inner tubes), brakes, a saddle and seat post,
handlebars and a handlebar stem, pedals, crank, chain, chainwheel, one or more rear sprockets,
reflectors, and grips.  Typical options include multiple speeds (which require front and/or rear
derailleurs coupled with a multiple sprocket cluster or a rear hub with an internal gear-changing
mechanism, one or more shift controls, and cables), caliper or cantilever brakes either in lieu of or in
addition to coaster brakes, tape on the handlebar in lieu of grips, handlebar extensions of various
kinds (e.g., bar ends or aero-bars), mudguards, luggage carriers, one or more water bottle holders,
and a kickstand.  
     While many consumer products are similar to bicycles in being assemblies of discrete
components  an automobile or a television set are obvious examples  we are aware of no such
product in which the principal component parts are recognized as separate articles of commerce with
a unique value of their own.  Consider, for example, an automobile.  A consumer buying a car will
ordinarily examine the car as a whole and consider the reputation of the automobile manufacturer,
but will generally have little or no knowledge of or interest in who supplied the engine or the sheet
metal used in the automobile body, nor will he or she have thoughts of eventually upgrading the
drivetrain.  For many retailers of bicycles as well as consumers, by contrast, whether the shifters are
made by GripShift or the derailleur by Shimano is becoming increasingly important, even in the
extremely price-sensitive mass merchant segment of the market.  Moreover, consumers frequently
replace individual bike components for performance or aesthetic reasons.  In short, product-based
competition in the bicycle market is largely component-driven.  The overall value of a bicycle is
largely determined by the quality  real or perceived  of the individual components with which the
bicycle is equipped.
     4.   Many of the same components are found on both imported and U.S.-origin
          bicycles.
     Over the past four or five decades, bicycle production around the world has become less and
less vertically integrated.  The production process today is more or less the same everywhere in the
world.  Generally, the bicycle companies manufacture such components as the frame and fork, the
wheel rims, the handlebars, the handlebar stem and seat post; these primary components are then
assembled with other components purchased from specialized manufacturers, including tires and
tubes, derailleurs, brakes, chains, pedals, sprockets, hubs and reflectors.  Invariably, the bicycle
manufacturer's brand name will be placed on the bicycle frame (and perhaps, less commonly, on other
components (e.g., the saddle)); but most of the major purchased components (e.g., the brakes,
derailleurs, rims, hubs, and crank) will typically be labeled with the brand name of the component
manufacturer and perhaps, the country of origin (if the component is imported).
     This characteristic of the manufacturing process has a direct impact on the nature of
competition in the worldwide bicycle market.  One of the principal ingredients in any bicycle
manufacturer's competitive strategy is how it "specs" its bicycles  that is, what combination of
components it selects for its individual bicycles.  While for certain consumers, the color of the paint
on the frame might be the primary factor in a decision to buy, more sophisticated consumers will
frequently decide between two different brands of bicycle based on the component packages available
with each.  
     Increasingly over the past several decades, U.S. bicycle manufacturers have been forced to
rely upon foreign-based component suppliers.  Four or five decades ago, U.S. firms produced
virtually every specialized component needed to assemble a bicycle.  Over the course of this period,
specialized component manufacturers sprang up in the Far East  first in Japan and then in Taiwan
and other lower-cost countries.  Gradually, individual U.S. firms found themselves unable to compete
with these Far Eastern firms, with the result that by 1972, entire categories of components were no
longer available from U.S.-based suppliers.  Congress responded by passing a series of temporary
"duty suspension" bills over the next twenty years in order to give U.S. bicycle manufacturers duty-free access to those imported components that simply could not be sourced domestically.  By the time
these tariff reductions were made permanent in the Uruguay Round of multilateral trade negotiations
on January 1, 1995, the list of bicycle components on the "duty suspension" list was quite long, and
included derailleurs, caliper and cantilever brakes, coaster brakes, cable and casing for derailleurs and
brakes, three-piece cotterless cranks, multiple freewheel sprockets, bicycle chain, tires and tubes,
aluminum quick-release hubs, and multi-speed hubs with internal gear-changing mechanisms.  Thus,
for the past quarter century, bicycles made in the United States have necessarily contained some
foreign components for the very simple reason that many components have simply not been available
from domestic sources.
     U.S. bicycle manufacturers also have been forced to rely on foreign component suppliers
because of the extremely strong brand positions developed by a number of firms.  Simply stated,
"spec'ing" certain brand-name components is a prerequisite to competing effectively in the bicycle
market, particularly in the higher-end "specialty" shop segment of the market.  In recent years, for
example, Shimano, a Japanese-based bicycle component manufacturer, has accounted for as much
as 60 percent of the value of worldwide bicycle component sales (principally, drivetrains, hubs and
brakes).  Shimano components  which are manufactured primarily in Japan and Singapore  are
widely found on bicycles manufactured in both the United States and the major bicycle exporting
countries supplying the United States  that is, Taiwan and China, which currently account for more
than 95 percent of the bicycles imported into the United States.  No amount of creative marketing
will allow a Trek or a Cannondale  the two largest U.S. bicycle manufacturers selling through the
IBD segment of the market  to sell bicycles unless they are Shimano-equipped.  And while many of
the bicycles made by Huffy, Murray and Roadmaster are targeted at consumers for whom price is the
predominant purchasing criterion, competitive pressures require these companies to compete on the
basis of component "specs" as well, particularly on their higher-end models.  If Huffy, Murray and
Roadmaster wish to compete with higher-end imported bicycles, they have little choice but to "spec"
Shimano derailleurs (for example).  Again, many of these higher "spec," branded components are
simply not available from domestic sources.
     While it might not initially be apparent to the consumer where precisely the Shimano-brand
derailleur, the Lee Chi-brand brakes, or the Cheng Shin tires on a particular bicycle were made, any
reasonable consumer would infer that these components were likely not manufactured in the United
States.  If this were not obvious enough from the Asian-sounding names of these brands or the
presence of country of origin markings, it would quickly become apparent from the fact that
consumers would likely find that very same derailleur, the very same set of brakes, or the very same
tires on several brands of bicycles labeled as having different countries of origin  for example, on a
Roadmaster labeled "Made in USA" and on a Magna or Pacific-brand bicycle marked "Made in
China."  Could a consumer confronted with such competing products reasonably infer that the
Roadmaster bicycle was entirely of U.S. content?  The answer, clearly, is no.  Nor, for that matter,
could the consumer reasonably infer that the Pacific and Magna bikes are "all, or virtually all" of
Chinese content, notwithstanding their being labeled "Made in China."  For upon closer examination
of those bicycles, the consumer likely would notice components variously labeled as "Made in
Singapore" and "Made in Taiwan," with perhaps none of them individually labeled as "Made in
China."  Consumers confronted with bicycles labeled with different countries of origin, yet having
many of the same components, at least some of which might be labeled with countries of origin
different from that of the bicycle, would quickly come to the conclusion that a statement of where
a bicycle is made  whether it be the United States or some foreign country  is not intended to say
anything about where any of its specific components might have originated.  Rather, in context, such
claims can only be interpreted as indicating where the bicycle itself "came into being" and where a
substantial portion  but not necessarily "all, or virtually all"  of the material and labor content of the
bicycle originated.
                            CONCLUSION
     In light of these distinguishing factors  that is, the prominence of imported bicycles in the
market; the fact that many imported bicycles are labeled in such a way as to suggest U.S. origin; the
fact that a bicycle is a complex assembly of discrete, commercially-recognized components; and the
fact that many of the same foreign-origin components can be found on both imported and U.S.-origin
bicycles  a number of basic conclusions can be drawn.  First and foremost, it is apparent that, in
context, a "Made in USA" label on a bicycle cannot reasonably be interpreted by a consumer as
implying that "all, or virtually all" of that bicycle's material and labor content are of U.S. origin. 
Fundamentally, a "Made in USA" label is simply the only straightforward way of distinguishing a
bicycle fabricated in the United States from a combination of U.S. and (unavoidably) foreign
components from the large number of bicycles labeled "Made in Taiwan" and "Made in China" that
appear on store shelves.  Consumers spending even a short time comparing domestically-made and
imported bicycles would quickly appreciate that, in both cases, the bicycle might well be equipped
with individual components originating in countries other than the stated country of origin of the
bicycle as a whole.  The consumer is no more misled or deceived as to the origin of a bicycle labeled
"Made in USA" that contains a Shimano drivetrain made in Singapore or Japan than he is by a bicycle
labeled "Made in China" which contains that very same Shimano drivetrain.  The two origin claims
will necessarily be interpreted as conceptually identical  that is, as simply signifying the country in
which the bicycle as a whole "came into being."
     In a market where bicycles with little or no American material or labor content have frames
emblazoned with names like "Schwinn" or "Pacific USA" in large block letters, perhaps accompanied
by American flags and a far less conspicuous label saying "Made in Taiwan" or "Made in China," how
are consumers harmed if firms offering bicycles fabricated in U.S. facilities using a relatively high
percentage of American labor and material content wish to distinguish their products by labeling them
as "Made in USA?"  The suggestion that such a straightforward statement is misleading in the context
of bicycles is simply specious, for as noted above, any consumer who attends to how bicycles are
made and sold will understand that a "Made in" statement on a bicycle frame  whether referencing
the United States or some foreign country  is not intended to indicate the origin of "all, or virtually
all" of the bicycle's material content.  Any initial misconception along these lines will quickly give way
to an awareness that a bike equipped with a Shimano drivetrain (for example) but labeled "Made in
USA" is not "all, or virtually all" of U.S. content.  On the other hand, we believe that consumers will
fairly and reasonably interpret such a statement to mean that that bicycle represents an investment in
American labor and material that is dramatically different from that represented by a bicycle labeled
"Made in China" or "Made in Taiwan."
     BMA's representatives look forward to discussing and expanding upon these comments during
the upcoming workshop.
                                   Respectfully submitted,
                                   Michael R. Kershow
                                   Judith L. Oldham
                                   Collier, Shannon, Rill & Scott
                                   3050 K Street, N.W.
                                   Suite 400
                                   Washington, D.C.  20007
                                   (202) 342-8400
     
                                   Counsel to the Bicycle Manufacturers
                                    Association of America, Inc.
January 22, 1996Footnotes:
{1}  Huffy produces bicycles in Celina, Ohio and Farmington, Missouri.  Murray manufactures
bicycles in Lawrenceburg, Tennessee.  Roadmaster's four bicycle manufacturing facilities are in Olney
and Effingham, Illinois; Delavan, Wisconsin; and Opelika, Alabama.
{2}  See Comments of the Bicycle Manufacturers Association of America, Inc. Regarding the
Commission's Proposed Consent Agreement with Hyde Athletic Industries, Inc. Concerning Hyde's
Use of "Made in USA" Claims in Connection with the Sale of Footwear (File No. 922 3236) dated
November 22, 1994.
{3}  Standard Cycle Co., Stip. No. 9460, 59 FTC 1492 (1961).
{4}  By contrast, the Nishiki brand, formerly made in Japan, is today manufactured in the United
States by Raleigh USA (albeit using imported semi-finished frames).        BICYCLE MANUFACTURERS ASSOCIATION OF AMERICA, INC.
                       Manufacturer Members
Huffy Corporation                  Murray, Inc.
P.O. Box 1204                      219 Franklin Road
Dayton, OH  45401                  Brentwood, TN  37027
(513) 866-6251                     (615) 373-6500
Roadmaster Corporation
P.O. Box 344
Olney, IL  62450
(618) 393-2991
                         Supplier Members
American Cycle Systems, Inc.       Excel International Group
245 Eighth Avenue                  328 East Main Street
City of Industry, CA  91746        Barrington, IL  60010
(818) 961-3942                     (708) 428-1350
Falcon Cycle-Parts Co., Ltd.       Hartford Bearing Company
P.O. Box 1-57                      1022 Elm Street
Feng Yuan, Taichung                Rocky Hill, CT  06067
Taiwan, R.O.C.                     (203) 571-3602
886-4-5623316
Hunt-Wilde Corporation             Inland Container Corporation
2835 Overpass Road                 912 Nelbar Street
Tampa, FL  33619                   Middletown, OH  45042
(813) 623-2461                     (513) 425-0830
KMC Chain Industrial Company       MARWI USA
No. 41, Chung Shan Road            1 Union Drive
Hsin Hua Town, Tainan              Olney, IL  62450
Taiwan, R.O.C.                     (618) 392-2000
886-6-5900711                      The Clarksville Division,          Persons-Majestic Manufacturing Co.
Metal Forge Company                21-31 Hamilton Street
5555 Parkcenter Circle             Monroeville, OH  44847
Dublin, OH  43017                  (419) 465-2504
(614) 764-1413, x-736              
Resentel Company, Ltd.             Sate-Lite Manufacturing Co.
1825 Avenue Industrielle           6220-30 Gross Point Road
Quebec, Canada  J0L 1J0            Niles, IL  60648
(514) 658-2483                     (708) 647-1515
Selle Royal                        Shimano American Corporation
Via Vittorio Emanuele, 141         One Shimano Drive
36050 Pozzoleone                   Irvine, CA  92713-9615
(Vicenza) Italy                    (714) 951-5003
011-39-444-462021                  
Sturmey-Archer Limited             Sun Metal Products, Inc.
Triumph Road                       2146 North Detroit Street
Nottingham NG7 2GL                 Warsaw, IN  46580
England                            (219) 267-3281
011-44-1159-420800                 
Vari-Wall Tube                     Wald Manufacturing Company
1350 Wardingley Avenue             P.O. Box 10
Columbiana, OH  44408              Maysville, KY  41056
(216) 482-0000                     (606) 564-4078