Made In USA Closing Letter Addresses Retailer Obligations – Media, Telecoms, IT, Leisure

As we have famous in different posts, an FTC rule prohibits firms
from stating or implying {that a} product is made within the USA until:
(1) the ultimate meeting or processing of the product happens within the
USA; (2) all vital processing that goes into the product
happens within the USA; and (3) all or nearly all elements or
parts are made or sourced within the USA. It may be a problem to
determine whether or not a product you make meets that customary, however
it is even more durable to determine that out for merchandise you did not
make.

This month, the FTC revealed a closing letter in an
investigation about “Made in USA” claims that Crate and
Barrel made about numerous merchandise that have been made by different
firms. Though the case does not break new floor, the
steps that Crate and Barrel promised to take associated to “Made
in USA” claims on its website may present some useful steerage
about what the FTC expects retailers to do when making claims about
different firms’ merchandise.

Crate and Barrel promised to:

• solely make U.S.-origin claims if the accountable producer or
  provider has signed and submitted applicable documentation
  substantiating the declare;




• impose contractual obligations on distributors to replace
  substantiation as circumstances require; and




• immediate distributors to verify and re-certify origin claims on a
  common foundation.

Retailers needs to be cautious about merely utilizing “Made in
USA” claims offered by suppliers with out performing some degree of
due-diligence. Taking the steps outlined above ought to present a
good begin.

The content material of this text is meant to offer a normal
information to the subject material. Specialist recommendation needs to be sought
about your particular circumstances.