Consumer Law Library

Disclosure of origin of partly foreign-made textie products

Topics: FTC Act §5: unfair or deceptive actsTextile Fiber Products Identification Act

76 F.T.C. 1097 · July 10, 1969 · Digest No. 355

source volume section (76 F.T.C. 1097)

Text is machine-OCR of the printed volume and may contain errors. Advisory opinions are the Commission's views on proposed conduct, not binding orders.

No. 355. Disclosure of origin of partly foreign-made textie products. The Commission advised a manufacturer of men s and boys slacks that it would not be necessary to disclose the fact that certain assembly and sewing operations are performed in a specified foreign country.

Under the facts presented to the Commission, the slacks consist of cotton and synthetic woven fabrics and threads, and steel hooks and eye enclosures, a11 of which are made in the United States. Said materials are inspected and cut to pattern in the United States and certain assembly steps, such as the sewing of belt loops and the attachment of zipper chains , are also performed domestica11y. Thereafter, they are shipped to the compas plant in a foreign country where they are further assembled and sewn. Finally, they are returned to the United States where the buttonholes are sewn, the buttons attached, and the pants are pressed, inspected, cured, and prepared for shipment to customers. The cost of the foreign assembly and sewing operations is approximately 13. 5 percent of total production costs, and the company wanted to know whether it would be necessary to disc10se

the nature and extent of the foreign operations either under Section 5 of the FTC Act or Section 4 (b) (4) of the Textile Fiber Products Identification Act. It was further understood that the company does not intend to label the slacks as "Made in U. or use any other words of similar import. (File No. 693 7127 Released July 10, 1969)