Monday, August 12, 2013

Agathon Associates Comments on FTC Strategic Plan

On August 8th, David Trumbull submitted the following comments regarding the United States Federal Trade Commission ("FTC") Stragetic Plan for fiscal year 2014 through 2018.
I write on behalf of my clients who are engaged in every stage of the wool trade -- from fiber, to yarn and fabric, to apparel. The U.S. is one of the most important markets for wool and animal hair consumer products, and I applauded the Commission's activities directed toward reducing consumer fraud and unfair competition in the market for these products.

I am pleased to see that, among the Commission's three Strategic Goals, consumer protection is listed first. I am also pleased to see, listed as objectives under that Strategic Goal, the Commission's Strategic Plan: (1) "Identify and take actions to address deceptive or unfair practices that harm consumers" and (2) "Provide the public with knowledge and tools to prevent harm to consumers."

In particular, I direct the Commission's attention to the task, currently being undertaken by the Commission, of revising the Rules and Regulations Under the Wool Products Labeling Act of 1939 (File No. P124201) to address the amendments made by the Wool Suit Fabric Labeling Fairness and International Standards Conforming Act. The amendments went into effect in 2007 and the trade is anxious to see the revised Rules and the Commission's responses to industry's specific suggestions for implementing the amendments. In addition, I have recently been alerted to the pervasive mislabeling of wool felt hats in violation of the Wool Products Labeling Act and shall be submitting, under separate cover, a report to the Commission on this problem, which is harming consumers and honest retailers and is a source of unfair competition for producers of properly labeled felt hats.

I also look forward to the finalizing of the revisions to the Rules and Regulations Under the Textile Fiber Product Identification Act and am pleased to see that the suggestions made in joint industry comments have been, largely, adopted in the proposed Rule.

Comments are due by August 16th. For more information or to see the Stragetic Plan, visit the FTC website by clicking here.

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