Red, White and Gray
• A made-in-the-USA claim can also be qualified or unqualified. Unqualified means an expressed claim has been made, it meets the “all or virtually all” standards and does not need further modification. A qualified claim includes labels such as “assembled in the USA from foreign parts” or “30 percent U.S. content,” as opposed to the catchall “made in the USA.”
• According to Consumer Reports, “Marketers can land in hot water with the Federal Trade Commission if they use vague, stand-alone terms such as ‘created in the U.S.’ to describe, say, a product invented in Seattle and made in Bangladesh, because consumers are likely to interpret ‘created’ as all-inclusive.”
CHECKS AND BALANCES
Terminology aside, the main thing to remember is to be as clear as possible to avoid misleading the end-user.
Gaida was quick to note that although 90 percent of LarLu’s products are made in the U.S. (and are marketed and labeled as such), Display-Tec’s line of promotional clocks are assembled in the U.S. with some foreign components. It could be argued that, since the imprint is a promotional product’s essential element (as considered by this industry), and the clock is merely the vehicle for the imprint, it could pass muster for a qualified “made in the USA” label. Yet, “[It] is something that I’m not comfortable putting on our Display-Tec catalog pages because the key part of the clock is … imported,” he explained.
Once they iron out labeling protocol, of course, suppliers that keep their entire product lines on this side of the pond are in a good place right now. “‘Made in America’ marketing messages seem to be growing again,” Finn noted, pointing to rising unemployment, the poor economy and national press on quality and safety concerns with imports as the main reasons for this occurrence.