Federal Trade Commission
Received Documents
July 27, 1995
B18354900288

American Export Association

6009 Richmond Avenue, Suite 212 
Houston, Texas 77057-6218

P.O. Box 420189
Houston Texas 77242-0189

Tel:  (713) 266-4888
 Fax: (713) 266-2468

July 24, 1995

Federal Trade Commission
Office of the Secretary
"Made in the USA"
6th Street and Pennsylvania Ave., N.W.
Washington, D.C. 20580

Dear Secretary:

This article in USA Today has caused me to think of the "Made in the USA" label in an new way.  I think this
is a good question:  what does Made in the USA mean?

I have been in international trade nearly thirty years, fifteen years in export promotion for the U.S.
Department of Commerce.  You may know that its policy (and that of the Export-Import Bank of the United
States) is to require a product (of the American company using its service) to have "51% of value content"
made in the USA.  In our positions, we did not question whether that was a correct or incorrect standard, and
we did not question the definition of value.

I hold deeply the value of Made in the USA.  I formed this company in part with a patriot zeal to sell
American products in foreign countries.  Now, I am running for Precinct Chairman, making the U.S. trade
deficit as my "campaign issue."  Educated people are aware of the deficit, but they do not comprehend its
fullest significance, I believe.  Hence, if the question of "Made in the USA" were made an issue, it would
serve to raise the national awareness of export/import trade and its consequences for our country.  I believe
that the awareness would be positive for our country.

From a practical stand point, it is often difficult to make a product totally of parts made in the USA.  Does
this mean, then, we should permit a product to have a high percent of goods and services be of non US origin
and still qualify for Made in the USA?  I think not.  A practical solution is to set a standard of 80%.  Eighty
percent of the total cost value must be of goods and services made in the USA.  This standard is reasonable
and it maintains the integrity of the Made in the USA label within our country and within the global economy.

Now, how does one determine the cost of a product when such figures are usually confidential?  One cannot.

Therefore, I think the solution, also practical, is for the FTC to create a simple form for a company to self-certify Made in the USA.  Such a form would provide for official, uniform presentation of information.  It
would be free.  A company would complete such a form and keep it on file -- or make it available for
marketing purposes if it wished.  The form would state that, under perjury and subject to civil penalties, the
cost value of the product contains at least 80% of goods and services made in the USA.

In summary:

1.  A Made in USA label may only be attached to a product with 80% of its cost value actually derived in the
USA.
2.  A companies self-certifies its claim, subject to prosecution under law if the claim were legally proven
false.

Sincerely,

James B. Mathes
President

/pt D2F113.WPS

cc:  Congressman Bill Archer

Attachment ["Does  Made in USA' label fit?"] - See Image

Removing barriers to sales - Houston - Monterrey - Maracaibo