Federal Trade Commission
Recieved Documents
Jan. 16, 1996
P894219
B18354900040
                                   January 12, 1996

Office of Secretary
Federal Trade Commission
Room 159
Sixth and Pennsylvania Avenue, N.W.
Washington, D.C.  20580

Re:  "Made in USA Policy Comment"
     FTC File No. P894219
     Comments of Wright Tool Company

Dear Sir/Madam:

The Wright Tool Company is a family and employee owned business that has been manufacturing
high quality sockets and wrenches since 1927 in Barberton, Ohio.  Our contacts with customers
and prospects in the professional portion of the tool market indicates a strong preference both for
quality and a product made in the United States.  Some people are strong unionists or nationalists
and prefer U.S. made tools per se.  Others know that historically the U.S. tools have been made
to the highest and most comprehensive standards in the world, policed by product liability lawyers
in a very competitive market with many large and small companies involved.  As one of the
smaller companies in the industry, Wright Tool lacks the recognition of our Fortune 500
competitors or the Craftsman brand.  But, we gain an important degree of acceptance with a
perspective customer when we tell them in person, or by advertisement, that we use no foreign
blanks and not even any foreign steel.  Indeed, the forging operation, because of its  importance,
is done by us.

If the definition "Made in U.S.A." were enlarged, it would no longer strictly convey U.S.
workmanship and would appear on lower quality tools and would lose not just part of its meaning
but all of its meaning.  The strict definition of "Made in USA" which now exists is a benefit not
only to US manufactures and their employees, but much more importantly, to our consumers who
have used it as a definite assistance in purchasing.

I recognize that "Made in U.S.A." has a different connotation for other products and other
consumer groups.  The Hand Tool Industry will continue to offer the customer a choice of both
qualities and countries of origin.  I have no quarrel with that or the fact that some customers
choose an imported product or lower quality product.  My concern is that the choice be a
knowing choice.  I would welcome the opportunity to answer any questions based on a lifetime of
experience in both engineering, manufacturing, and selling hand tools. 


Federal Trade Commission      - 2 -              January 11, 1996

I would also like to address the marking issue of separate markings for export under the existing
regulations.  First, the need to mark exported product differently from domestic product, this only
occurs when the product has foreign content.  Much of the product sold in the US today has no
such foreign content and, therefore, those manufacturers have no problem.  The US manufacturer
that is complaining about the marking cost, already has four separately branded product lines in
the US market that in many cases start with the same blank.  So he is already incurring the cost of
multiple marking and finds it acceptable.   Second, marking is either the last or near to the last
operation performed on the product and it is, therefore, perfectly practical to run large lots and
carry most of the inventory in an unmarked condition and incur only a small cost penalty.  It is this
relatively small cost that needs to be weighed against the benefit lost by consumers and by
manufacturers without foreign content.  

                                   Sincerely,

                                   Richard B. Wright
                                   President

RBW:slj

cc:  Fred Ikenson

file:  \finlaw\madeusa