Origin Labeling on Kits Containing Imported Beads

No. 406. Origin Labeling on Kits Containing Imported Beads. The Commission rendered an advisory opinion concerning the proper labeling of a product line of craft kits containing imported glass beads.

Under the facts considered, the box containing the various items in the craft kit would be marked “Manufactured by * * *” with the name of an American company and its address although some of the items representing 20 percent of the total cost will consist of glass beads imported from Japan and Czechoslovakia. Additionally, loose beads in glass bottles will be offered for sale, the imported beads here representing about 40 percent of the total cost. Advice was requested as to whether each bottle should be marked with the name of the country from which the beads were imported, snch as “Made in Japan,” “Made in Italy,” or “Made in France” as the case might be. The Commission’s advisory opinion reaffirmed the rule that “Made in U.S.A.” markings are permissible. only on products entirely of domestic origin. Therefore, “Manufactured by * * *” with the name of the American company and its address, being synonomous, would be improper since 20 percent of the components of the kits consist of imported beads. However, in the absence of any affirmative representation as to the origin of the kits and their contents, the Commission ruled that such failure to mark or mention the origin of the components on the outside of the box would not be regarded as deceptive. This ruling will not prevail as to the glass beads being offered for sale to the public separately from the kits. In such circumstances, the country of origin of such items must be fully disclosed. (File No. 703 7060, released Feb. 18, 1970.)