Advisory opinion letter

January 9, 1970 Dear Sir ;

We respectfully request for your opinion on marking the country of origin as “Made in U.S.A.” on the ball bearings machined and assembled in United States with its unfinished component parts imported from Japan. The processing from the time of importation to the final finished bearing is as follows:

1. Bearing races in unfinished form imported from Japan. 2. Steel balls, retainers(cage), seals and shields imported from Japan.

3. Bearing races to be ground and polished in United States with American labor.

4. Steel balls, retainers, U.S.-made grease, seals or shields and the inner and outer races to be assembled in United States with American Labor.

5. The finished bearing to be sold in the U.S. market and for export. In other words, majority of the final finished cost will be borne in United States after computing the costs of machining process, labor, engineering, grease operational overhead, transportation, U.S. customs duty, ete. Also, we want to stress that the steel ore itself used for the unfinished bearing races, stcel balls, retainers and shields to be brought in from Japan were originally exported to Japan from the United States.

From the standpoint of the ratio in the manufacturing process itself, majority of the work to complete the bearing will be done in United States.

It is hereby respectfully requested that your approval be given to mark the country of origin as the United States for our proposed

product for the reason stated above.
Very truly yours,
George K. Yamashige
Assistant to the President