Domestic origin marking on product containing foreign made components

No. 295. Domestic origin marking on product containing foreign made components.

The Commission responded to a request for an advisory opinion in regard to the following two questions: 1. What percentage of imported components may be used in the finished product (bearings) without the necessity of disclosing the foreign country or origin thereof? 2. Would it be proper to stamp the two types of bearings which are partly made in a foreign country, as "Made in USA" Because the party seeking the opinion did not know the cost of the imported components in relation to the total cost of the finished product, the Commission said that the first question appeared to be somewhat hypothetical in that it does not involve a specific proposed course of action. Under these circumstances the Commission concluded that the question was not the proper subject of an advisory opinion.

With respect to the second question, the Commission concluded as follows:

::'* the "Made in eSA" mark ,vQuld constitute an affrmative representation that the bearings are made in their entirety in the United States. If the bearings did in fact contain foreign made components of a substantial nature , it would be improper to mark the finished product as " Jadc in USA" without a clear and conspicuous disclosure indicating the foreign country of origin of the imported components.

(File No. 693 7001, released Oct. 8, 1968.