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The case against “Parts Content” labels on new car window stickers

The case against “Parts Content” labels on new car window stickers

It’s the patriotic thing to do. Buying American, that is. This is a great country, with world-class industries and a top-notch, well-educated labor force. The least we consumers can do is to support the home team by buying those products that are clearly identified as “Made in the U.S.A.”

Clearly this is the intent of the American Automobile Labeling Act, that went into effect October 1, 1994. On its face, the AALA seeks merely to inform the car-buying public by requiring that automakers disclose where their cars come from. Auto-buyers thus informed are then armed with the facts and can decide for themselves whether they prefer to “buy American” or to send their dollars overseas.

Oh, if only it were that simple. In an apparent attempt to be fair and precise, the AALA requires disclosure of the following separate items on all new-car window stickers:

1) the percentage (in cost value) of all U.S. and Canadian parts installed on the vehicle;

2) the country where final assembly has taken place;

3) the national origin of the engine and transmission;

4) the names of at least two countries outside the U.S. and Canada where the greatest percentage value of equipment has originated if more than 15 percent of the vehicle is of foreign origin;

That’s a lot of very specific information that manufacturers are now required to post on their window stickers; and if they don’t, their dealers face penalty fines of up to $1,000 per infraction. According to a January 2001 evaluation conducted by the National Highway Transportation and Safety Administration (NHTSA), compliance with the content labeling law cost all manufacturers somewhere between $38 million and $48 million in just the first four years. And in those same four years, according to the NHTSA report, the “Big 3” domestic automakers watched their share of new-vehicle registrations fall by 3.3 percent as registrations of vehicles from “foreign-based companies” grew by that same amount.

Clearly, the AALA has backfired. As Lindsay Chappell pointed out in April 1998 in the trade publication Automotive News, “If shoppers knew how much of that Honda Civic was imported, they would not buy it. Such was the reasoning behind the American Automobile Labeling Act....The outcome: Honda and Acura’s market share rose to 10 percent last year.” According to the bare-knuckled prose of the NHTSA report, “The principal finding was a disconnect between consumers’ ignorance of the labels and their belief in the importance of buying a U.S./Canadian product.” In other words, NHTSA seems to be saying that consumers either don’t know about the new content labels or they don’t know how to interpret them. It’s hard to avoid the implication that otherwise they’d probably be “buying American” like they’re supposed to.

Or maybe the collective intelligence of our nation’s auto buyers isn’t being given enough credit. Perhaps many consumers have an instinct to see through all the red tape that these content labels represent. If so, they may detect the lobbying efforts of our domestic automakers to create something of an unlevel playing field for their foreign-based rivals. For example, while the national origin of the value of parts is required to be posted, the “added value” of the labor applied to those parts is nowhere mentioned. A window sticker on a 2003 Mitsubishi Eclipse, then, designates U.S./Canadian content at 60 percent and Japanese content at 33 percent, but surely the car’s assembly in Illinois represents a significant monetary value as well—not to mention the all-American jobs and salaries and benefits and taxes associated with Mitsubishi’s U.S. operations.

As with any bureaucratic exercise, unintended consequences of the AALA are inevitable and, occasionally, ridiculous. Because of tortuous wording and complex rules, the AALA originally resulted in vastly different content valuations for virtually identical vehicles like the Chevrolet Prizm and Toyota Corolla or the Chevrolet Tracker and Suzuki Vitara. Before an amendment in 1998, in fact, the same car with identical parts might show U.S./Canadian content of either 11 percent or 53 percent, depending solely on whether parts suppliers operated independently or were wholly owned by the automaker.

Even more egregious is the instance in which the Ford Crown Victoria and Mercury Grand Marquis sedans conveniently “switched” citizenship in order to game the system. As reported in August 1994 in Automotive News, Ford sought relief from fuel mileage regulations in the early ’90s, so it installed “Japanese shocks and Mexican axles” on its large sedans as a way of designating them “import cars.” This resulted in improvements in Ford’s domestic-car mileage ratings under corporate average fuel economy (CAFE) rules. After passage of the content labeling law, Ford conveniently “moved production of the rear axle to the United States,” thereby returning the Crown Vic and Grand Marquis twins to the company’s domestic-car stable (where, by the way, Ford had improved its domestic fuel economy ratings).

Other anomalies continue to complicate efforts to define a vehicle’s precise national origins. Passage of the North American Free Trade Agreement (NAFTA) has encouraged a dramatic increase in parts-making and vehicle assembly activities in Mexico, and yet the labeling law continues to recognize Mexican content as “foreign.” On the other hand, Canadian content is somehow deemed “domestic.” Moreover, while the label law has been in effect, the NHTSA report fails to find evidence of any “resurgence of U.S./Canadian content” in North American vehicles overall. Nevertheless, the growing minority of transplant vehicles, as U.S.-assembled foreign models are known, have “substantially increased their U.S./Canadian parts content...[to] levels that rival some Big 3 vehicles.” It doesn’t seem to matter: “Much of the public is still unaware that transplants are assembled in North America and contain significant proportions of U.S./Canadian parts.”

So it would seem that, far from promoting a patriotic surge to buy American, the AALA content label legislation has achieved the twin accomplishments of irrelevance and needless complication in a single stroke. According to the government’s own evaluation, “most consumers are unaware of the existence of the AALA labels,” whereas those who are aware of them “do not rely extensively on the AALA labels to pinpoint the make-models with high U.S./Canadian content.” Most telling of all, perhaps, is a finding that “most manufacturers and their dealers rarely use the AALA information as a selling point.” In a final analysis, perhaps the most patriotically automotive thing that can be said about parts content legislation is that it gives regulators and bureaucrats a reason to get up and drive to work in the morning.

  • The case against “Parts Content” labels on new car window stickers

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