![]() ![]() With their help, Tupperware is now found in more than 90 percent of U.S. Our consultants recruit and train other consultants and we currently have an average active sales force of 152,000 in the United States representing the Tupperware and BeautiControl brands. Our products are sold to consumers outside traditional retail store channels, with independent contractor sales consultants comprising the vast majority of the sales force. I am proud to note the lifetime guarantee on our products, which also helps distinguish us from competitors and many of the companies whom the Commission is trying to regulate through this rulemaking. By way of background, we are a publicly traded global direct seller of premium innovative products, including our Tupperware brand of kitchen and home products and beauty and personal care products sold through brands such as BeautiControl. In the explanatory statement accompanying the RNPR, the Commission stated that it believes it has other authorities to regulate conduct of multi-level marketing companies and we encourage you to finalize the BOR by clarifying further the exemptions and exclusions already provided in the revised text. ![]() Accordingly, I wish to refer you to our written comments, which provide several suggested ways to make entirely clear to whom the Commission intends to apply the Rule. While Tupperware does not believe that the Business Opportunity Rule will apply to our company, we operate in an environment where regulatory certainty is critical to a billion dollar business such as ours. We were pleased to see last Spring that the Commission specifically stated in the Federal Register Notice that the revisions narrowed the scope of the proposed rule “to avoid broadly sweeping in sellers of multi-level marketing opportunities” and that your agency intended to avoid inadvertently including in the new regulatory regime companies using traditional product distribution arrangements. At the outset, I want to reiterate our appreciation for the effort of the Commissioners and staff to narrow the scope of the proposed Business Opportunity Rule. Accordingly, I will focus most of my remarks on our remaining definitional concerns with regard to the RNPR. We understand that you are holding this workshop to gather additional insight and not to hear a recitation of the written comments we submitted last May and June. Tupperware welcomes the opportunity to amplify further its comments on the Revised Notice of Proposed Rulemaking (RNPR). ![]() Assistant General Counsel, The Americas Tupperware Brands Corporation FTC PUBLIC WORKSHOP ON THE BUSINESS OPPORTUNITY RULE COMMENT, Project No. ![]()
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