Necessity to disclose foreign origin of strain release device if servomotor is labeled as "Made in U."

No. 20. Necessity to disclose foreign origin of strain release device if servomotor is labeled as "Made in U. The Commission has issued an advisory opinion in which advised a manufacturer that it would be improper to label its servomotors as "Made in U. " since that wou1d constitute an affrmative representation they were entirely made in this country, which is not the fact, unless the label also discloses in a clear and conspicuous manner that the strain release device is imported from West Germany. The Commission s opinion was rendered in response to a factual situation where all components of the servomotor, except the strain release device, are of domestic origin. The strain release device is to be imported in an assembled state from West Germany, and it represents approximately 5 percent of the total cost of all the components. The servomotors wil be s01d in the United States and in foreign countries.

In its opinion the Commission also took the position that the disclosure requirement would also be applicable, even though the manufacturer decided at a later date to import the strain release device unassembled and assemble it here in the United States. Finally, the Commission s opinion noted that it would have authority to impose the same requirement in connection with the sale of servomotors in foreign countries, provided they were being sold in competition with other American manufacturers. (File No. 663 7041, released Mar. 29 1966.