Labeling of material composed of leather fibers imported in their entirety

No. 225. Labeling of material composed of leather fibers imported in their entirety.

The Conllnission rendered an advisory opinion in regard to the legality of the following five terms to label material composed of pulverizedlea.ther :

1. Pulverized Le,ather.
2. Reconstituted Leather.
3. Imported Bonded Leather-Fibres.
4. Bonded Leather-Fibres.
5. 100% Leather-Fibres.

Imported from Europe, the material "ill be sold to manufacturers of luggage, handbags and various other leather goods. The pulverized leather will be bonded with an adhe,sive and coated either with SOllle type of la,cquer or vinyl co.ating.

ADVISORY OPINION DIGEST 1325 In its opinion, the Commission ruled that it had no objection to' labels which describe the nlaterial as "Pulverized Leather" or "Bonded Leather-Fibres." It rejected, however, the tenn "Reconstituted Leather" since the word "Reconstituted" creates the impression that the material is le.ather which has been reprocessed in some lnanner when in fact it is nothing more tha,n pul verizedleather held together by an acUlesive.

,Vith respect to the third proposed label, the COnlll1ission expressed the opinion that it would be deceptive t0' use the word "imported" without disclosing the specific country of origin of the material. Even though the word "imported" is not used, the Comnlission said that would still be necessary to disclose the origin of the material since it is entirely inlported.

According to its opinion, the Commission also ruled that it would percent"be improper to represent that the material consists of "100 leather fibres, since it contains a substantial amount of adhesive as ,\yell as being coated either with a lacque-r or vinyl coating. The requesting party was further advised, however, that there would be no objection to using a, percentage figure which factually portrays the mnount of pulverized leather present in the material. ,Vith further reference to the fifth and final proposed label, the Commission stated that the words "Leather-Fibres" either standing alone or when coupled with the leather appearance of the material, could create the impression that the material is wholly the hide of an animal or at least something more than pulverized leather. To dispel this erroneous impression, the COnlll1ission said it would be necessary to use qualifying language, such as "Bonded Leather-Fibres." "Leather fibres and an adhesive " etc., in connection with the "words "LeatherFibres. Finally, if the seller decided not to reveal the composition of the material, the Comlnission pointed out that it would be necessary to disclose that it is not leather by such language 'as "Not Leather Imitation Leather ~' or "Simulated Leather.~' The reason for this the Conll11ission said ~ is that the material has the appearance of leather and in order to remove the potentilal deception inherent through its appearance it is necessary to disclose the fact that it is not Ie,ather. (File No. 6837055, released Apr. 4, 1968.

origin ofNo. 226. Necessity for disclosing foreign country of imported honing stones.

The Conlmission was requested to furnish 'Rll advisory opinion as to the necessity for disclosing the country of origin of imported honing stones which will be affixed to plastic handles in this country. The name of the applicant, an American company, \\ould appear on the handle. 1326 FEDERAL TRADE CO:\BIISSIOX DECISIONS The opinion advised that in the Commission s view the country of origin of the honing stone must be diselosed in a clear and conspicuous manner on the product itself. (File X o. (-)7:37046 released Apr. 4 , 10G8. No. 22'7. Necessity for disclosing- foreign country of orig'in of repackag-ed imported nails.

The Commission ,vns requested to furnish nn ncl\-isol'Y opin ion as to the necessity for disclosing the countr)' of orig-in of imported nails ,,'hich ,"rill he imported in bulk nndl'epacka c:ed in this country. The opinion advised that in the Commission s vie\\' the country of origin of these nails must be c1i:;:closeel in 11 clenr anel conspicuous manner on the package in which they are sold and that neither directly nor indirectly could the importer imply that the nails are made in the United States. (File X o. H7:) 7017 , released A Pl'. 4, 1968.