Advisory opinion letter

Dear Sir:

In accordance with Sections 1.1 through 1.4 of the Federal Trade Commission Procedures and Rules of Practice, we hereby respectfully request the Commission to advise us with respect to a course of action which we propose to pursue.

Opinion 84 F.T.C.

Metal Cookware Manufacturers Association, Inc. (““MCMA”) is a notfor-profit corporation organized under the laws of the state of Illinois and whose principal offices are located in Fontana, Wisconsin. MCMaA is a trade association, presently composed of 21 member companies engaged in the manufacture and sale of metal cookware, ovenware and kitchen accessories. Our association includes all of the major domestic manufacturers of those products and, we estimate, that our members sales of those products in this country constitute approximately 90% of all such sales.

In the case of many products manufactured and sold by members of our association, the packing box or carton for the particular item of cookware is as much as double the size that it might otherwise be because the handle of the particular item is attached to the vessel, requiring a package of almost twice the size merely to cover a handle which is quite small by comparison to. the bulk of the vessel. If the handle were detached from the vessel, it could be packed in the box or carton large enough to accommodate the vessel alone and the size of the package could be reduced by as much as 50%.

Various members of MCMA have expressed an interest in exploring customer and consumer attitudes as to the packaging of their cookware products with handles disassembled. They believe that, assuming no significant consumer or customer resistance and having solved any safety problems that may exist the shipping of their product with handles disassembled could result in significant savings in freight costs, warehouse costs and packing material costs. The individual cost of doing the market research necessary to reach meaningful decisions is expected to be significant if each manufacturer who is interested in pursuing the question launched its own investigation. MCMA therefore proposes to conduct a survey among housewares buyers in an effort to develop and tabulate data which would be disseminated to those member companies of MCMA participating in the survey. Each member company who wishes to participate has reviewed and edited drafts of the proposed letter to houseware buyers and accompanying questionnaire form, copies of which we have enclosed. Each member has been invited to and most members have submitted to MCMA a list of names and addresses to whom the questionnaire is proposed to be mailed. Each member’s list of names and addresses is held in confidence by MCMA and is not available to any other member. Following the mailing to approximately 125 housewares buyers, we propose to develop statistics concerning various responses to the questions set forth in the questionnaire and deliver the results of the survey,