Location of foreign origin disclosure

No. 252. Location of foreign origin disclosure. Responding to a request for an advisory opinion, the Commission said that the disclosure of the foreign c.ountry of origin of imported fishing reels must be made in a location where it would be readily observed by prospective purchasers. Under the factual situation presented to it in the advisory opinion the imported fishing reels are plainly marked as to their specific foreign country of origin. It is anticipated, hO\1;"eyer, that the reels will be paekaged for resale in the lTnited States in a vinyl zipper case and (\) j ,\, : ; ( .,

ADVISOHY OPI:c\IO~-i DIGEST 1337 then placed inside u. cardboard Garton. Information fiS to the. exact manner in which the reels will be dispbyed at the point of sale was not nxailable.

The question presented to the Commission "\rns ,vhether it "\vould be lleee,ssarv to make the IoreiQ:n origin diselosure of the reels on the case or the ontside of the earc1board cal'ton or on both. tfter pointing out that it could not give a speeific answer as to the exact location of the foreign origin disclosure because it had not been ndyisec1 of the. exact rnanner in which the reels would be displayed at the point of sale, the Commission stated:

hew'n' r an afIjrmntin' dis(:III~l1l't' of IIrig:ill is reql1in,(l in order to )Jre,' ent (leceptioll, the general rule is that the marldng must be legible 11nc1 must. lJe placed in a loci! tion ,"\'here it would be readi!)- oh8(,1'\'ed 11 ': pro811E~ctiye 1)111' (:hnsers mn king' it casun 1 inspection of tlw lllerdullldi8(' prior to, and 11M after nw IJ1ll'c11:1Se thereof. This lJH?flll:': , !If (:o11l'~~e,thnt if tl1C' reels are displayed at th~ point of 8nle in a carc11Joard (:;11'(- 011, 11 ('on81')icnO118 c1i8closn1'e would bn ye to be 111;1(le OIl the outside of the e:1l'tnn, A ~imil:ll' (1i~elosul'e ,YO111d he required on tlJe vinyl case, if the reel s a l'P c1ispln ~- ed onl~- ill (he en Sf', On the 01-1181' hand it follo\ys tha t the c1isC;iosu1'E:' on the reel s \Youl d be ~ntiicien t, vrovic1ec1 tllat tlle reels are (lispla:-ed n t tilt' jJoint of ~;l1e in s11cll n 11l:11lnl':'1'that jlrospediye Imrclla~el's could re;lc1il~' ol,sl'rye tIll' c1is(:losnre tl10r\:'lin lido!' tl) tIle pnl'C'l1nse of tIlE' mE'l'C'hilndis!:', (File K o. G8B 71:21 , l'ele,lsec1l\fny :21 10(;8.