Analysis of Proposed Consent Order to Aid Public Comment  The
Federal Trade Commission has accepted an agreement, subject to
final approval, to a proposed consent order from respondent
Perrigo Company. ("Perrigo").   This matter concerns "Made in
U.S.A." claims on packaging and labeling for Perrigo's aspirin,
acetaminophen, and ibuprofen tablets sold at retail bearing
private brand names. The Commission's complaint alleges that
respondent misrepresented on packaging and labeling that certain
of these products, manufactured for customers such as Kmart,
Wal-Mart, Target, and Safeway, are all or virtually all made in
the United States. According to the complaint, these products
are actually made with significant foreign content. The
products' active ingredients, bulk aspirin, acetaminophen, or
ibuprofen compounds, that respondent processed into aspirin,
acetaminophen, or ibuprofen tablets, are or were made outside
the United States. The imported bulk compounds comprise a
substantial percentage of total manufactu