Origin of imported brush for hair roller

No. 386. Origin of imported brush for hair roller. The Commission issued an advisory opinion with regard to the question of whether it is necessary to disclose the origin of the imported brush which is assembled with American made components to form a hrush hair roller. It is proposed to produce a hair roller in the United States. The roller consists of three components: spiral spring, netting, and brush insert. The brush insert is manufactured in a foreign country. The spiral spring and netting are manufactured in the United States. All assembling is done in the United States. The cost of the brush accounts for less than 25 percent of the total cost of the hair roller as marketed. The question involved is whether the foreign origin of the brush must be marked on the printed card which wil be used in packaging the roller. The Commission expressed the opinion that, in the absence of any affrmative representation that the product is made in the United States, or any other representation that might mislead the public as to the country of origin , and in the absence of other facts indicating actual deception, the failure to mark the origin of the imported component would not be regarded by the Commission as deceptive. (File K o. 703 7028 Released October 29 1969)