Foreign origin disclosure of wearing apparel partly made in a foreign country

No. 315. Foreign origin disclosure of wearing apparel partly made in a foreign country.

The Commission rendered an advisory opinion in regard to the question of whether it is necessary to disclose the origin of textile products processed in Puerto Rico and the Dominican Republic from fabric produced in the United States, and thereafter exported to the mainland United States. Specifically, the Commission ruled upon the following two questions: .

_(1) Must a semimanufactured product with less than 50 percent of the value added in a foreign country be labeled in any way before entering the U.S. territory? (2) If said product is then finished in Puerto Rico and shipped for distribution in the U.S. mainland, can it be labeled “Made in U.S.A. ?”

In response to the first question, the Commission said that. it will not be necessary to disclose the foreign country of origin where less than 50 percent of the value is added to the product insofar as the laws of the Commission are concerned. In regard to the second question, the Commission expressed the opinion that it would be improper to label such a product as “Made in U.S.A.” because this would constitute an affirmative - misrepresentation that the product is made in its entirety in the United States. (File No. 693 7055, released Jan. 17, 1969.)