Like members of Congress and the general public, our membership is very split on the FTC's guidelines. The Foundation's opinion is that guidelines are badly needed and that any guideline must be a compromise among many industries and companies. The Foundation would simplify the guidelines. The same for the keyboard, mouse, motherboard and so forth. By putting these substantially transformed components together in the United States, the computer manufacturer meets the safe-harbor of two levels substantial transformation.
Substantial transformation is a real problem for consumers.
However, in reality a pair of shoes marked made in Italy could have virtually no Italian content.