Marking of origin of packaged ball bearings where only bearing races in unfinished form are imported from…

Marking of origin of packaged ball bearings where only bearing races in unfinished form are imported from Japan with all other parts and components produced in the United States.

(File No. 713 7001)
Opinion Letter
August 14, 1970
Dear Mr. Yamashige:

This is in reply to your request for an advisory opinion on behalf of NTN Bearing Corporation of America relative to the proper marking of the country of origin of packaged ball bearings where only the bearing races in unfinished form are imported from Japan with all other parts and components produced in the United States. In addition, all grinding, finishing and assembly of the packaged bearings will bo done in the United States. You have supplied projected bearing production cost analyses indicating the race material and forming represents 22.5 percentile of the production cost of the completed bearings. The Commission has given careful consideration to this matter and is of the opinion that in accordance with the facts as outlined (a) the packaged bearings may not be marked as “Made in U.S.A.” since such marking would constitute an affirmative representation that the finished product. was made in its entirety in the United States, which is contrary to fact; and (b) in the absence of any affirmative representation that the bearings are made in the United States, or any other representation that might mislead the public as to the country or origin, and in the absence of any other facts indicating actual deception, the failure to mark the origin of these packaged bearings will not be

regarded as deceptive.
By direction of the Commission.
Supplemental Letter Relative to Request
| April 8, 1970

Dear Mr. Steinbach :

In reply to your letter of March 24, 1970, requesting more detail on the cost breakdown of the finished bearings to indicate the ratio of the cost borne in United States, we are still endeavoring to obtain this information at this time. Soon as we have more detailed information, we will furnish them for your consideration. Thank you.

Very truly yours,
George K. Yamashige
Letter of Request