If only the fresh produce industry would embrace generic promotion, imagine the possibilities... Well, to give us a flavor of an industry actually seeking to implement generic promotion, here is a comment found on the www.regulations.gov web site extolling the promise of a promotion order. As the comment describes, the industry has warmed up to the idea of generic promotion. Did the fresh produce industry take enough time to consider the benefits before rejecting a promotion order?
The National Christmas Tree Association (NCTA) welcomes the opportunity to submit these comments in support of the proposed creation of a Christmas Tree Promotion, Research and Information Order. NCTA is the national trade association representing the Christmas tree industry. It represents 1,000 active member firms, 29 state and regional associations and 4,000 affiliated small and family businesses that grow and sell farm-grown Christmas trees and provide related supplies and services. It is estimated that those affiliated with the national organization produce roughly three quarters of the farm-raised Christmas trees in the United States.
SUMMARY: NCTA would like to express agreement with and support of:
* The program is needed and adequate industry discussion has taken place.
* An assessment rate of 15¢ per tree sold is fair and equitable for all growers and importers.
* An exemption for those who sell or import less than 500 trees per year will help keep administrative and
compliance costs manageable while collecting on an estimated 94% of the trees sold in the U.S.
* The proposed makeup of the board, including three regions and 12 directors (including one importer representative) allows for good representation from the major growing areas and for the entire industry.
* A delayed referendum to take place 3 years after assessments begin. NCTA would like for USDA/AMS to consider adjustments as follows:
* Applying for exemptions should be required every five years, not annually.
* An exemption for organically-grown Christmas trees is counterproductive
* To avoid competition with existing farm-grown Christmas tree promotion programs, it is important for state and regional associations to have an opportunity to direct how a portion of the funds will be used
* Administrative costs should be capped at 15% as allowed under the 1996 Act.
* Other minor adjustments in wording as noted below.
NCTA Comments on Proposed Promotion, Research & Information Order February 7, 2011