AAFA Comments on FTC Made in USA Proposed Rule
The Federal Trade Commission proposed a rule for Made in USA that is very similar to the standard that has existed for years, using the “all or virtually all” U.S.-made content requirement to use the Made in USA label. AAFA outlines in this comment the contradiction with U.S. law under Customs on rules of origin that would be created if the FTC proceeds with the proposed rule as written. We propose that the Commission take this opportunity to promote alignment and harmonization within U.S. by adopting the rule of “substantial transformation.”
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