Federal Trade Commission
Received Documents
Jan. 23, 1996
B18354900109

BROTHER
200 Cottontail Lane
Somerset, N.J. 08875

                         January 22, 1996

BY HAND DELIVERY

Office of the Secretary
Federal Trade Commission
Room 159
Sixth Street and Pennsylvania Avenue N.W.
Washington, D.C. 20580
Attention:  Donald S. Clark, Secretary

     Re:  Made in USA Policy Comment, FTC File No. P894219 and Made in USA
     Workshop--Request to Participate, FTC File No. P894219

          Brother International Corporation ("BIC") and Brother Industries (USA), Inc.
("BIUSA") (collectively "Brother") hereby submit these comments in response to the
Commission s request for comments regarding "Made in USA" claims in product advertising and
labeling, 60 Fed. Reg. 53922 (October 18, 1995).  Brother also hereby requests an opportunity to
participate in the public workshop regarding such claims which is scheduled for March 26-27,
1996.
          BIUSA, located in Bartlett, Tennessee (near Memphis), is America s largest
manufacturer of portable electronic typewriters and personal word processors in the United
States.  BIUSA s plant in Bartlett employs almost 500 workers.  Much of Brother s worldwide
product research and development work is also done at Bartlett.  BIUSA s products are made in
the United States, as are many of the components for those products.  Some domestic
components are purchased from outside vendors.  Others, including sophisticated printed circuit
boards, are made in the BIUSA plant to exacting specifications, with designs dependent on the
specific model in which the circuit board will be incorporated.
          BIC, located in Somerset, New Jersey, is the distributor of products made
worldwide by Brother and sold in the Western Hemisphere.  BIC has four distribution centers in
the United States and employs, together with its subsidiaries, nearly 1,500 people.
          Brother directs these comments to two limited issues identified in the
Commission s October 18, 1995 request for comments:  (I)  whether and to what extent qualified
"Made in USA" claims such as "Made in USA of domestic and imported parts" unduly burden an
advertiser s domestic content message; and (ii)  whether such qualified claims present practical
problems which need to be considered (60 Fed. Reg. at 53925).
          Brother believes that qualified "Made in USA" claims provide an effective and
nonburdensome alternative for advertisers who do not wish to undertake whatever burdens may
apply now or in the future with respect to unqualified claims or products that are not made
entirely with U.S. labor and U.S. components.  Brother has long used a qualified statement similar
to those cited with approval (60 Fed. Reg. at 53923, 53925) in the Commission s request for
comments.  We believe that such a statement on a product, at least with respect to typewriters
and word processors, provides information which is useful and informative for both consumers
and advertisers.  Our experience also suggests that use of such a qualified claim does not present
any other significant problems.  Thus, whatever the action the Commission may take or
recommend regarding use of unqualified "Made in USA" claims, it should be aware that a
qualified claim of the type discussed above provides a useful, practical, and non-burdensome
alternative which meets the needs of both consumers and advertisers, as well as the Commission s
enforcement objectives.

Respectfully submitted,

BROTHER INTERNATIONAL CORPORATION
BROTHER INDUSTRIES (USA), INC.
          
By        __________________________________
                       Jeffrey G. Glaser
                       Associate General Counsel


                              January 22, 1996

BY HAND DELIVERY

Office of the Secretary
Federal Trade Commission
Room 159
Sixth Street and Pennsylvania Avenue N.W.
Washington, D.C. 20580
Attention:  Donald S. Clark, Secretary

          RE:  "Made in USA" Claims, FTC File No. P894219

Dear Sir:

          Consistent with the extended due date established by the Commission, enclosed are
six copies each of the "Made in USA Policy Comment" and "Made in USA Workshop--Request
to Participate" of Brother International Corporation and Brother Industries (USA), Inc.  A
computer disk containing the same document is also enclosed.

                                   Sincerely yours,

                                   Jeffrey G. Glaser
                                   Associate General Counsel