Foreign origin disclosure of imported bearings

No. 316. Foreign origin disclosure of imported bearings. The Commission rendered an advisory opinion in regard to the proper marking of imported bearings.

According to the facts presented in the matter, the top of the container in which the bearings will be packaged will carry the following statement: “The (word of a particular foreign country) Bearing”. Also printed on the top of the container is the statement: “Made in (country of origin)”. Etched on the outer race of each bearing is the inscription of the name of the foreign country of origin.

Most of the bearings are sold to domestic manufacturers who use said bearings in their manufacture of heavy earth moving equipment and farm machinery. The bearings normally represent less than 2 percent of the total cost of the finished equipment. Domestic manufacturers who use the bearings in their production

of machinery and equipment compete with one another for both domestic and foreign markets.

Specifically, the following two questions were raised: (1) Are the bearings marked with sufficient clarity to disclose they are manufactured in a certain foreign country? (2) Is it necessary for the manufacturers who use the imported bearings in their machinery and equipment to disclose the country of origin of the bearings? © In response to the first question, the Commission said that its examination of the markings revealed they were adequately marked to show their foreign country of origin. — With respect to the second question, the Commission said that it would not be necessary for the manufacturers who use the bearings in their machinery and equipment to disclose the foreign country of origin of the bearings. (File No. 693 7054, released Jan. 17, 1969.)