Federal Trade Commission
Received Documents
July 2, 1996
P894219
B18354900198

James P.  Palmquist Office of General Counsel
Senior Counsel



Office of the Secretary
Federal Trade Commission
Room 159
Sixth and Pennsylvania Avenue NW
Washington, D.C. 20580                      Via FAX #202 326-3259




Re:      "Made in  USA" Policy Comments, FTC File No. P894219

These comments from Minnesota Mining and Manufacturing company (3M) should be viewed as being in
addition to that contained in the Ad Hoc group comments. 3M supports the Ad Hoc comments but feels strongly
that two additional "safe harbors" should be considered by the FTC.

1.       "Substantial Transformation: Safe Harbor

         As per comments made during the workshop/hearing, 3M believes that the only way to avoid significant
consumer confusion, and therefore possible consumer deception, is to apply consistent rules for all country of
origin markings/claims used within the United States, both domestic products marked with a U.S. origin as well
as imported products marked with the foreign country of origin.  Given the multi-national nature of business in
today's world, together with the significant marketing strength within the U.S. for certain imported products (for
example leather goods marked "Made in Italy") it is difficult for us to understand why the Commission would
not recognize as one of the safe harbors whatever is the then current country of origin standard being utilized by
U.S. Customs.  If this were not the case then a foreign country of origin marking, as established by Customs,
would nevertheless still be subject to challenge before the Commission provided (1) that the foreign country of
origin mark was shown to be of significance to U.S. consumers and (2) the manufacture process taking place in
the alleged foreign country did not meet the Commission's higher standard of domestic content for avoiding a
finding of unfair or deceptive practice within the U. S.





Minnesota Mining and
Manufacturing Company

PO Box 33428
St. Paul, MN 55133-3428
612 733 1890
612 736 3257 Facsimile

         July 1, 1996
         Page 2


2.       Required Marking by Third Country: "Lessor Mark' Safe Harbor

              3M additionally supports the following provision which is being recommended by a number of the           participants of the Ad Hoc Committee:

              "If a good contains materials, parts or components that are not wholly obtained or produced in the
              United States, but exports of it are nevertheless required by a foreign government to bear a label (on
              the product or package) to the effect that such product's country of origin is the United States it
              would not be deceptive to market in the United States such a product bearing such a required mark so
              long as (i) the product is actually sold in the market that requires the label, and (ii) the label uses the
              formulation "Country of Origin:  USA!' or "Product of the US", (as opposed to the unqualified
              statement "Made in the  USA!'), and (iii) is no larger than is necessary to meet foreign labeling
              requirements, and (iv) the claim is not repeated in U.S. advertising unless it can be substantiated
              using the one or more of the guides above."

         3M appreciates the opportunity to provide supplemental comments on the FTC's current "Made in  USA!'
         standard and look forward to continuing in this process.

         Respectfully submitted,


         James P.  Palmquist
         Senior Counsel
         Made  USA cus.