Order: In the event the Commission’s staff desires additional information or clarification of the proposed…
91 F.T.C. 1173 · Feb. 6, 1978 · File No. 7837004
source volume section (91 F.T.C. 1173)
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.
Order: In the event the Commission’s staff desires additional information or clarification of the proposed course of action, we will be happy to supply such information or consultation as the staff deems
necessary. Thank you for your consideration.
Yours very truly,
VARNUM, RIDDERING, WIERENGO & CHRISTENSON
/s/ J. Terry Moran
1174 ' FEDERAL TRADE COMMISSION DECISIONS Use of the name of the foreign manufacturer on the label of an imported covered product is permissible under the Textile and Wool Acts and their supporting regulations, File 783 7004.
Opinion Letter
February 6, 1978
Dear Mr. Boyett:
This responds to your request for advice concerning name identification requirements relative to imported goods of Sec. 4(b)(3) of the Textile Fiber Products Identification Act and Sec. 4(a)(2)(C) of the Wool Products Labeling Act. You have inquired in this regard whether the foreign manufacturer’s name on labels and hangtags in lieu of the name or tradename (where applicable) or registered identification number of the American importer or distributor, is considered sufficient name identification under these Acts. It is the Commission’s interpretation of both Acts, and their supporting Rules, that the labels of covered products imported into this country may carry the name of the foreign manufacturer or the name or tradename (where applicable) or registered identification number of a person or firm marketing the product in the United States. An election to use the name of the foreign manufacturer, accordingly, is completely permissible. The foreign manufacturer’s name, if used, must be that under which the firm does business. Responsibility for any misbranding of products under these Acts, however, rests with the person or firm introducing the product into commerce in the United
States.
By direction of the Commission
Letter of Request
July 6, 1977