FR 2021-02471

The document reviewed outlines a proposal from the Federal Trade Commission (FTC) regarding the extension of information collection requirements under the Wool Products Labeling Act of 1939. This law aims to prevent misbranding of wool products, thus helping consumers make informed purchasing decisions. The FTC is seeking public comments on the necessity and efficacy of these requirements, as well as ways to reduce the burden on businesses involved. Comments must be submitted by April 9, 2021, either via an online platform or through the mail.

General Summary

The FTC proposes to extend for another three years the clearance for specific information collection requirements related to wool product labeling. These requirements are crucial in ensuring that consumers are not misled by the branding of wool-related products. The document provides estimates for the burden imposed by these requirements, particularly in terms of labor hours and associated costs.

Significant Issues and Concerns

Firstly, the document estimates an annual labor cost burden of $25,620,000. However, there is no detailed breakdown of how these costs are calculated or what roles contribute to this estimate. This could make it challenging for businesses and the public to ascertain the accuracy of the figures provided.

Additionally, the estimated annual burden in terms of hours is 1,880,000. The document does not compare this with previous years' burdens, leaving questions about whether there has been an increase or a decrease and the reasons for such changes.

Another concern is the use of regulatory jargon and citation of legal statutes such as CFR and OMB numbers without providing simpler explanations. This use of technical language may extract comprehension from individuals not versed in legal or regulatory terminology.

Potential Impact on the Public

Broadly, this document and the proposed rule extension have the potential to maintain the status quo in consumer protection regarding wool products. By ensuring proper labeling, the FTC helps to protect consumers against deceptive practices, which is a positive outcome for the general public.

However, the document also highlights a significant time investment required from businesses to comply, which could result in increased costs passed on to consumers. There is a need for a balanced approach that maintains consumer protection without imposing excessive burdens on businesses.

Impact on Specific Stakeholders

For manufacturers, importers, and marketers of wool products, this proposal can be both a burden and a boon. It requires them to allocate substantial time and resources to comply with labeling requirements, which some may find arduous. However, proper labeling can lead to a higher degree of consumer trust and potentially boost sales.

The call for public comments provides stakeholders, including industry participants and consumer rights groups, with an opportunity to voice their concerns or support for the proposal. Yet, the lack of clear instructions on how these comments will be evaluated or incorporated may deter some from participating.

Moreover, the document briefly mentions considerations due to the COVID-19 public health emergency, but does not provide alternatives for those without internet access. This oversight may limit participation from certain demographics that rely on traditional mail or in-person submissions.

In conclusion, while the FTC's proposal aims to uphold consumer rights through stringent wool product labeling, its execution needs more transparency and accessibility to fully benefit all stakeholders involved.

The document discusses the Federal Trade Commission's (FTC) proposal to extend the Office of Management and Budget (OMB) clearance for information collection requirements under the Wool Products Labeling Act of 1939. This extension is necessary due to the expiry of the current clearance on May 31, 2021. As the document is primarily concerned with the administrative elements of the Wool Rules, several financial references warrant further exploration.

Estimated Annual Cost Burden

The document provides an estimated annual cost burden of $25,620,000, which is solely related to labor costs. This figure implies a substantial investment in maintaining compliance with the Wool Rules, which require firms to engage in activities such as recordkeeping, label content determination, drafting, ordering, and attaching labels to wool products. However, the commentary identifies a notable issue: there is no detailed breakdown of these costs, making it challenging to understand how this total was calculated or which roles contribute to this financial estimate.

This lack of clarity regarding the allocation of the $25,620,000 leaves room for questions about potential efficiencies or cost-cutting measures. Understanding the specific labor roles involved could help businesses manage these costs better and identify areas for improvement. Without this information, businesses may find it harder to optimize their operations in response to the financial demands of compliance.

Calculation of Labor Costs

The document further mentions a "weighted average hourly wage of $6.50 per hour" when discussing the cost of attaching labels for both U.S. and foreign labor. The process described for reaching this figure is not detailed, creating an issue for transparency. Given the significant cost implications, such an average raises questions about how different wage rates—particularly between domestic and international labor markets—interact to form this composite rate. Providing more details on how labor costs are calculated would enhance understanding and potentially address concerns about the fairness or accuracy of this figure for various stakeholders.

Annual Hours Burden

Financial references are also connected to an estimated annual hours burden of 1,880,000 hours. This number is divided between 160,000 recordkeeping hours and 1,720,000 disclosure hours. However, the document does not explain how this current burden compares to previous assessments. A lack of context regarding whether this represents an increase or decrease could impede stakeholders' understanding of whether the burden—and so the financial implications—has elevated or diminished over time. Additional data comparing these hours with past statistics could elucidate potential trends or shifts in compliance costs.

Start-Up and Capital Costs

The document suggests that there are no start-up or capital costs associated with the Wool Rules, noting that labeling processes have long been essential components of manufacturing. Yet, the commentary raises concerns about whether this is overly optimistic. Detailed financial analyses on potential capital expenses—or lack thereof—are necessary to verify this conclusion, ensuring that companies are not underestimating initial compliance investments.

Overall, while the document mentions various financial allocations related to the Wool Rules, it leaves several questions unanswered. Providing further details and context around these financial references would allow businesses, regulators, and other stakeholders to make better-informed decisions regarding compliance with the Wool Products Labeling Act.