Federal Trade Commission Received Documents Jan 22 1996 B18354900088 Secretary THE JOINT INDUSTRY GROUP 818 Connecticut Avenue, N.W., 12th Floor, Washington, D.C. 20006-2702 Telephone (202) 466-5490 Fax (202) 872-8696 Chairman David W. Rose Secretariat James B. Clawson January 22, 1996 Mr. Donald S. Clark Office of the Secretary Federal Trade Commission Room 159, Sixth and Pennsylvania Avenue, N.W. Washington, D.C. 20580 "Made in USA" Policy Comments, FTC File No. P894219. Dear Secretary Clark: On behalf of the Joint Industry Group (hereinafter JIG), we respectfully submit the following comments with regard to the Federal Trade Commission's (FTC) request for comments as published in the Federal Register on Wednesday, October 18, 1995 (60 Fed. Reg. N0. 201 53922). For the reasons discussed herein, we submit that the current policy requiring products labeled "Made in USA" to be manufactured entirely or almost entirely with United States materials and labor, is contrary to the clear, common meaning of the phrase "Made in" and is inconsistent with international standards and modern manufacturing practice. Rather, we recommend that the FTC's standard for "Made in USA" labeling should be eventually harmonized with international standards for country of origin determinations and, in the interim, with the standards administered by the United States Customs Service. JIG is a coalition of over 100 companies, associations and firms actively involved in business and trade. JIG examines the concerns of the business community, relative to customs-related policies, actions, legislation and regulation and undertakes to improve them through proactive dialogue with US Customs, Congress and other government agencies. JIG commends the FTC for its attention to this important issue and would like to actively participate in the public workshop. JIG POSITION US manufacturers have encountered numerous situations where the multiplicity of origin rules has led to inconsistent results causing increased costs of manufacturing and ensuring legal compliance. For example, several instances have arisen where products manufactured in the US with the use of foreign materials are exempt from marking with a foreign origin pursuant to 19 U.S.C. Section 1304; however, the FTC's rules prevent the goods from being marked with the affirmative representation that they are "Made in USA." The products are thus marketed in the US with no statement concerning their origin. At the same time, when these products are exported to Canada or Mexico, they are required by the NAFTA to be correctly labeled "Made in USA." To meet these conflicting requirements, US companies are often required to establish special packaging and re-labeling facilities, and to design and manufacture multiple forms of packaging for different destination markets. If the FTC's rules were consistent with the country of origin marking requirements administered by US Customs, these additional costs could be avoided, and consumers could be advised of the origin of the goods which they purchase. In this regard, the Commission's goal should not be to measure what consumers think a "Made in USA" label means (or should mean), but instead the goal should be to ensure that the criteria for labeling products as "Made in USA" are consistent with the criteria for labeling products with any other indications of national origin. When a consumer buys a product labeled "Made in Japan," the consumer should have the same understanding of that product's origin as one labeled "Made in USA." That is, the clear, literal meaning and purpose of the phrase "Made in" is to identify the geographic location where the product was made. However, the Commission's current policy adds a second, silent and more limited meaning to the phrase, i.e., "Made with," contrary to the true, full meaning of the phrase. CONCLUSIONS/RECOMMENDATIONS JIG members agree with the FTC that the "Made in USA" designation is commercially valuable and its integrity should be preserved. However, the current standard, which only allows products which contain "all or virtually all" domestic labor and materials to benefit from this designation, is contrary to the meaning of the phrase and international standards, and is unrealistic making it commercially not viable. As mentioned in the FTC's notice, a much smaller percentage of goods produced in the US today is comprised of "all or virtually all" US materials and labor, compared to previous decades. JIG members agree that this trend will continue, increasing the need to revisit the current standard. Companies should not be presented with an additional regulatory standard addressing country of origin marking information. Such a new regulation would impose a repetitive and costly compliance burden on both the business community and the FTC. Companies are already using established statutes and procedures to determine origin such as the existing NAFTA marking rules and US Customs country of origin marking rules. The FTC should participate in the international harmonization work program now underway to develop harmonized rules of origin for the determination of country of origin. The FTC "Made in USA" standard should eventually be harmonized with those rules. In the interim, the rules could be harmonized with the current international standards administered by the US Customs Service. Application of the Customs rules for "Made in USA" claims makes sense in that they bring benefits of predictability, transparency and enforceability to the process. In closing, JIG members appreciate this opportunity for comment and look forward to the prospect of participating in the public workshop. The attachment provides a background analysis of the "Made in USA" standard and the responses to most of the specific questions set forth by the Commission in its request for comments. Respectfully submitted, James B. Clawson Secretariat ATTACHMENT JIG SUBMISSION TO FTC FOR FILE No. P894219 BACKGROUND In furtherance of its obligation to protect consumers from unfair or deceptive advertising claims, the FTC has long taken the position that a product not be labeled with an unqualified "Made in USA" claim unless it is entirely, or almost entirely, composed of US materials, and unless it is entirely, or almost entirely manufactured with US labor. As a consequence of this extremely demanding standard, few manufactured products can lawfully be labeled as "Made in USA." Indeed, the FTC has ruled that the presence of any significant foreign constituent materials precludes an article from being labeled "Made in USA" even where those materials are subjected to significant further processes in the US that result in a US origin article.{1} The FTC threshold for the "Made in USA" claim was difficult to meet decades ago, when the standard was adopted. In recent years, as manufacturing has expanded and diversified globally, US companies have adopted global sourcing strategies. This trend exists in the chemical, automobile, hand tools, processed food, textile and apparel, and electronics industries as well as many other sectors of the economy. As new technologies are developed, older technologies have been shifted to more efficient manufacturing sites. Specialized materials, components and subassemblies for worldwide use are produced in single plants which can achieve economies of scale. As a result, there are fewer products on the market today whose constituents are all made in the US. The trend for global sourcing will continue for the foreseeable future, driven by economic dictates and aided by multinational reductions in tariff and nontariff barriers. This is not to say, however, that products made in the US with the use of foreign-origin constituents do not contain a high degree of US value added. Product research, design and engineering activities are conducted in the United States. Capital-intensive and labor-intensive manufacturing operations performed in the US transform domestic and imported materials into new and unique articles of commerce, with names, characteristics and uses different from those of the materials. These products are "Made in USA" under generally recognized international and commercial standards, and may be labeled as such when exported to foreign markets. The FTC's labeling standard should be modernized to conform with international standards and reflect the current manufacturing and sourcing practices of United States companies. In addition to the FTC's "Made in USA" labeling rules, imported foreign products, or their packages, are required to be marked with their country of origin in accordance with the requirements imposed under Section 304 of the Tariff Act of 1930 [19 U.S.C. Section 1304] and administered by the US Customs Service. Section 304 requires that all foreign goods imported into the US, or their packages, be marked permanently, legibly and in a conspicuous place so as to indicate to the "ultimate purchaser" in the US (i.e., the US consumer) the country of origin of the good. The courts have stated {2} that consumer information is the purpose of this statute. It provides information so that at the time of purchase, the US consumer may, by knowing where the goods were produced, be able to buy or refuse to buy the goods if the country of origin is an influence on the consumer's decision. This is not unlike the FTC's mission of ensuring that labels and advertising provide the consumer fair and truthful claims. It is important to note that foreign products or materials are exempt from such Section 304 marking requirements when they will be "substantially transformed" in the US into new articles of commerce, having a different name, character, or use. They are exempt because they have become USA products. Goods of Canada and Mexico, imported into the US are exempt from marking to indicate their foreign origin if, after importation, they undergo working or processing sufficient to work a change in tariff classification as noted in the NAFTA Marking Rules, 19 C.F.R. 102.20. There are numerous other provisions or rules which contain country of origin as an element and are frequently mistaken for, but are not themselves country of origin rules. These generally relate to procurement requirements, tariff preference agreements, and similar measures which grant a preference to goods of a particular country of origin when those goods satisfy direct or indirect economic contribution or input criteria. The Buy America Act, NAFTA and General System of Preferences are examples of such provisions. However, the country of origin of the good remains the same whether or not it satisfies the additional criteria to receive the preference. US manufacturers have encountered numerous situations where this multiplicity of rules and criteria have led to inconsistent results and consumer confusion and misunderstanding. This multiplicity also leads to increased costs to both manufacturers and consumers to ensure legal compliance. For example, several instances have arisen where products manufactured in the US with the use of some foreign materials are exempt from foreign origin marking pursuant to 19 U.S.C. Section 1304; however, the FTC's rules prevent the goods from being marked with the affirmative representation that they are "Made in USA." The products are thus marketed in the US with no statement to the consumer concerning their origin. At the same time, when these products are exported to Canada or Mexico, they are required under NAFTA rules to be labeled "Made in USA." This is also the case with exports to some other countries, and in all export situations they must be identified on documentation and reported to the Bureau of Census as US products. To meet these conflicting requirements, US companies are often required to establish special packaging and re-labeling facilities, and to design and manufacture multiple forms of packaging for different destination markets. With respect to the consumer's perception, the Commission's goal should be to measure whether consumers understand the meaning of country of origin and whether there currently is a difference in how this meaning is or is not conveyed to consumers with a "Made in Canada or England" label verses a "Made in USA" label. Under the current FTC requirements a product eligible for the "Made in USA" label and a functionally identical product produced in a foreign country even if it contains US materials must be labeled using totally different criteria and standards. Consumers are currently being mislead by one or the other. A harmonization of these rules, standards and criteria with the clear, common meaning of the phrase "Made in" will remove this contradiction. Recognizing the commercial importance of merchandise origin rules, the US and other members of the World Trade Organization (WTO) recently signed an Agreement on Rules of Origin which calls for a three year study to develop internationally harmonized rules of origin for products. One of the Agreement's disciplines is that the rules shall not discriminate between the goods of WTO members, irrespective of the affiliation of the manufacturers of the goods concerned. The rules that apply to imports and exports are not to be more stringent than the rules that apply to determine whether or not the good is domestic. In our view, the Commission's goal and policy should be to ensure that the criteria for labeling and advertising products as "Made in USA" are consistent with the criteria for determining and labeling the country of origin of products of any other nationality. The WTO Agreement will provide an internationally recognized standard for this objective in a few years. In the interim, JIG members believe the Commission should use the well established "substantial transformation" doctrine for this purpose. As an adjunct to these standards, the Commission should develop objective, definitive standards that US manufacturers could use to supplement "Made in USA" country of origin labels and advertising. These standards should be based on measures of US economic input attributable to the US product. FTC QUESTIONS Question 1: When consumers see product advertisements or labels stating or implying that products are "Made in USA," "Made in America" or the equivalent, what amount of US parts and labor do they assume are in the products? and Question 1.,b: How has increased consumer knowledge of foreign imports or foreign components affected such perceptions? How much knowledge of foreign sourcing of components do consumers have? Combined Answer While JIG has not conducted empirical research to measure such consumer perceptions, members believe that consumers are more aware of imports in general. JIG members believe that consumers generally accept that imports are an integral part of products sold in the marketplace today. Last year, US consumers purchased $663 billion of imported goods (exports for that period were $512 billion.) Today's consumer is constantly surrounded by imported products and enjoys the high quality and choice afforded by an integrated marketplace. US consumers exemplify their knowledge of imports by buying imported products. JIG members believe that this globalized marketplace has increased the knowledge consumers have with regard to foreign sourcing and consider the American consumer to be sophisticated enough to realize that "Made in USA" product claims vis-…-vis the "all or virtually all" standards are unrealistic. No consumer believes that a "Made in Japan" claim on a product ensures that the product is "all or virtually all" of Japanese origin. As mentioned in the FTC's notice, a much smaller percentage of products manufactured in the US today is comprised of "all or virtually all" US parts and labor, compared to previous decades. JIG members agree that this trend will continue, increasing the need to revisit the current standard. Question 2 : What are the costs and benefits of an "all or virtually all" threshold for "Made in USA" claims versus a lower threshold (e.g., 50%)? The most obvious drawback associated with the current "all or virtually all" threshold is that many companies which produce goods within the US using some degree of foreign materials cannot advise consumers that substantial manufacturing has occurred in the US. These companies cannot take advantage of using the valuable "Made in USA" claim for marketing, advertising or other purposes. At the same time, the Customs laws recognize that where a product is manufactured in a foreign country with materials sourced in many different nations, the country of origin, for marking purposes, is the last country where the article underwent a "substantial transformation" prior to entering the US. Thus a product labeled "Made in Japan" or "Made in Germany" might contain a substantial number of materials from countries other than the named countries of origin. Why should products "Made in USA" be held to a different standard? Today's global marketplace has resulted in increased competition, which in many instances has created a commercial environment where certain goods or materials are not available within the US. In fact, in very many cases, domestic suppliers for products simply do not exist. Foreign sources are the only ones available to US manufacturers in many industries. US trade law specifically recognizes this fact by allowing for the suspension of customs duty on products not available within the US. The trade laws of other nations (e.g., the European Union) allow for similar practices as well. A lower threshold (e.g. 50%) would provide the benefit of recognizing global sourcing and allow US companies to take advantage of "Made in USA" claims, however, lowering the threshold would impose a new standard on companies in order to account for that level of US production. JIG believes these additional compliance costs would outweigh any advantage afforded by lowering the 100% threshold. Further, any such percentage standard would be arbitrary and not conform to the recognized meaning of country of origin and "Made in." Instead, JIG believes that the FTC should align the "Made in USA" standard to those already in existence within US trade law, (see question #3). There are many instances in which an article derives its character from the production process, rather than from any one or more of its materials. This is particularly true in the electronics industry where specialized and non-specialized materials are arranged into virtually infinite configurations which perform unique functions. JIG members submit that a product should be truthfully labeled as "Made in USA" if it is "substantially transformed" in this country into a new and unique article or commerce, pursuant to Customs and US courts' country of origin determination precedents. The Customs and courts' requirements recognize that a new article of commerce must be created in order for the product to be excepted from marking as a product of a foreign country. This requirement will be sufficient to prevent mere "pass through" operations from being deemed sufficient to permit an article to be labeled "Made in USA". Quantitative tests of origin based on value, the sole criteria for determining whether articles are made in USA, should not be considered, as they are contrary to the common standard for country of origin and are too difficult to administer. Typical problems encountered in the developments and administration of these tests include the following: * Determining whether the local value contribution requirement should be calculated as a percentage of materials costs, of "direct cost of manufacturing," of total cost of production, or some other formula; * Determining whether intermediate products produced in the US in whole or in part from imported materials should be treated as domestic or foreign (i.e., the treatment of "roll up"); * Determining how "self-produced" materials should be valued; * Determining whether producers should be required to calculate local content on a product-by-product basis, or whether they should be permitted to "average" production costs over a stated period of time; or, * Determining how to allocate US sales, general, administrative and similar overhead costs and expenses which may relate to the production of more than one product. In addition to being arbitrary, value-based rules are difficult and expensive for companies to administer. Minor changes in a producer's sourcing patterns, in the price for a given material, and variances in depreciation, units produced and other fixed and variable dependent cost allocations can change the result of a country or origin marking determination. Furthermore, two companies producing identical products using identical origin materials and performing the same operations in the US may receive different labeling determinations simply because they may have paid different prices for a given material, or have different labor, depreciation, production volumes or other variable cost factors. The selection of any quantitative basis for an advertising or labeling rule is necessarily arbitrary. If a 50% local content rule is adopted, there is likely to be no appreciable difference in goods featuring 49.5% and 50.5% local content, respectively -- although the goods would have different labeling and advertising requirements under such a test. Question 2., a: What are the precise benefits of being able to make unqualified "Made in USA" claims for lower domestic-content products? JIG believes that there are other benefits to being able to make an unqualified "Made in USA" claim for US products containing a lower domestic content. One benefit is that companies will be able to provide true and accurate country of origin information to consumers. Another one is the ability of companies to comply with the actual country of origin standard and, as such, simplify the ability of the US government to monitor compliance. Question 2.,c: What are the costs and benefits of alternative thresholds (e.g., 50%, 75%, products "substantially transformed" in the United States)? JIG believes that any origin threshold based on a "domestic content" standard, such as one calculated on domestic value, would pose enormous regulatory problems for JIG members and other domestic manufacturers. Under such systems, companies would be required to conduct detailed internal cost analyses in order to accurately determine the exact domestic content for their products. Furthermore, as sourcing patterns shift, and prices of materials, labor, and other fixed and variable cost allocations change, companies would be required to constantly update their cost/value analyses. The experience of the US under the US-Canada Free Trade Agreement, the Buy America Act and other regimes demonstrates that value-based content tests can be extremely cumbersome to administer. The cost of such administration can only be justified when it is clearly demonstrated that manufacturers, consumers and/or the US economy as a whole receive a benefit exceeding the cost. Formulating a value-based test is itself a difficult exercise. For instance, should such a test be based solely with reference to the article's materials' cost (as in the Buy America Act), or should it include labor and overhead costs as well? If the former is chosen, there is a possibility that an article which derives substantially all of its value in the United States might not qualify as "Made in USA" due to the presence of foreign materials. On the other hand, if the latter is chosen, there is a possibility that labor-intensive goods, or goods with high value added, might qualify for a "Made in USA" claim even if they contain no domestic materials. In either case, there remains the question whether the consumer is receiving accurate and meaningful country of origin information. Finally, a "domestic value" standard would require enormous US Government resources in order to be adequately enforced. In this environment of shrinking government resources, this does not seem to be a realistic solution. Question 3: What are the costs and benefits for using the same tests for "Made in USA" claims as those imposed by US Customs requirements ("substantial transformation"), the Buy America Act (50% cost) or other domestic content statutes or rules? There are many benefits for using already established statutes and procedures to determine country of origin for "Made in USA" claims, including predictability; transparency; and enforceability. JIG members believe that as an interim standard, country of origin determinations under the substantial transformation doctrine, as interpreted by court precedents and enforced by US Customs are appropriate for use with "Made in USA" country of origin marking. First, this standard is already familiar to, and generally accepted by, the business community. Furthermore, companies now keep records to substantiate their country of origin marking claims. In fact, the US Customs Service has established the Recordkeeping Compliance Manual to provide specific guidelines for importers to follow in the retention of all import records dealing with the classification and value of merchandise. This provides government with an already established "paper trail" for enforcement purposes, while providing companies with the requisite transparency needed for compliance. FTC is now considering lowering the threshold for "Made in USA" but it has not yet determined an appropriate level for that threshold. JIG members believe that the substantial transformation doctrine and, when completed and adopted by the US, the WTO internationally harmonized rules for determining country of origin will adequately establish the threshold and will provide consumers accurate "apples-to-apples" country of origin comparison information for all products. Lowering the "Made in USA" threshold across the board (e.g., 50%) is not only inappropriate considering the FTC's mission and resources, but will place undue burden on the private sector. As described above, a value-based lower threshold will affect products differently, and result as extremely costly to companies and cumbersome to enforce. The substantial transformation doctrine is well developed and supported by years of court precedence, technical and legal analysis, as well as a multitude of US Customs administrative rulings for specific products, processes and other circumstances. The WTO internationally harmonized rules for determining country of origin will be specific to the products for which they will apply. That is, each product will be subject to a rule unique to each product category as determined by international technical experts in customs administrations, industry and trade that is adopted by consensus agreement by each WTO member. These rules will embody an international trade classification-based change methodology based on the long-standing doctrine of "substantial transformation." "Substantial transformation" means production in a country which results in a "new and different" article of commerce with a name, character, or use different from any constituent materials foreign to the country of production. Moreover, the WTO rules will gauge "substantial transformation" using the internationally agreed Harmonized System (HS) Description and Coding System that each WTO member country uses for the trade classification of all products. The rules will require that each foreign material incorporated in a product must undergo a specified classification-based change in the country of production for the product to result in that country as its origin. Thus, for "Made in USA" purposes, each product will have its own classification-based threshold rule based upon judicially tested criteria and international consensus. The "Buy America Act" is designed solely for the purpose of US Government procurement. It is not designed to determine country of origin or to be applied to products across the board. While this value-based system may be appropriate to confer a preference for government procurement purposes, it will simply not be adequate for determining country of origin for "Made in USA" purposes. JIG suggests that the FTC not consider these rules for "Made in USA" claims. Question 4: Do foreign customs officials prohibit the addition of qualifying phrases on Made in USA labels? If so, does the traditional FTC requirement that labels make disclosures of substantial foreign content add significant manufacturing costs where sellers wish to sell a single item in domestic and foreign markets? Would an option of stating qualifying disclosures only on packages, hangtags, etc. at time of sale in the US market significantly reduce such costs? Country of origin marking requirements differ from country to country. Most foreign customs agencies do not require (as the US does) that all products imported into their countries provide country of origin marking information. Qualified origin statements are often times not recognized as legitimate claims resulting in customs delays or denied entry of merchandise. As more trade agreements, such as the Uruguay Round GATT Agreement, lower tariffs internationally, many countries are using non-tariff measures such as country of origin marking as barriers to trade. A US system that is complicated and divergent as portrayed in the Hyde Athletic Industries Consent Agreement, will only exacerbate problems that US manufacturers are already experiencing with foreign customs authorities. Qualified "Made in USA" claims do in fact contribute to expensive manufacturing inefficiencies. For example, under NAFTA a company can, and must, mark its products as "Made in USA" if they meet the specified NAFTA requirements.{3} The "Made in USA" mark, particularly in Mexico, is extremely advantageous to US manufacturers, as Mexican consumers associate US products to be of high quality and value. That same product, however, cannot be sold in the US with the same marking unless "all or virtually all" of the product is domestic. Since the NAFTA requirements which rely on the "classification-based change" methodology do not comport with the FTC standard, manufacturers are faced with a costly and inefficient dilemma wherein they must run separate production runs and retain different inventories for the same products. Companies must also monitor the re-importation of their products from Mexico to avoid marking complications. This commercial environment is not advantageous to US manufacturers or consumers. JIG members believe that the use of hangtags or other qualifying mechanisms should be used only as a last resort. They believe that by adopting a single standard, such practices will be unnecessary. Question 5., 5.a-g: How should the proportion of domestic content be measured with respect to "Made in USA" claims? An unqualified "Made in USA" claim should not be measured by domestic content but via "substantial transformation" as established under judicial precedence, which will be embodied internationally within the classification-based change methodology. As described above, value-based systems are contrary to the recognized standard for country of origin determinations, are onerous, inaccurate, costly, and difficult to enforce and are not applicable to products across the board. However, if the Commission decides to permit manufacturers to supplement their "Made in USA" claims with domestic content statements, these statements should be subject to objective criteria which should consider all quantifiable domestic economic input contributions. Objective, quantifiable statements would be like the standards that apply for the use of "light, low fat, no fat, fat free, etc." on packages and advertising for food products. Question 6., 6.a: What form of guidance should the commission offer with respect to "Made in USA" claim? JIG members believe US manufacturers will be able to look to the Customs Service for guidance regarding marking requirements, for example through the Service's existing administrative ruling database and pre-importation rulings program, if the FTC adopts a "Made in USA" standard consistent with the internationally recognized meaning of country of origin. Should the FTC "codify" its country of origin standards using the WTO harmonized origin rules when adopted and implemented by the United States, US companies may be able to discharge their legal obligations by applying those codified rules and future Customs administrative rulings and judicial precedence, minimizing the need for the FTC and Customs to expend agency resources on case-by-case administration. Once an objective and administerable rule has been published, the FTC can take any necessary enforcement action on a case-by-case basis. CONCLUSION As mentioned in the FTC's notice, a much smaller percentage of products manufactured in the US today are comprised of "all or virtually all" US parts and labor, compared to previous decades. JIG members agree that this trend will continue, increasing the need to revisit the current standard. Companies should not be presented with an additional regulatory standard addressing country of origin marking information. Such a new regulation would impose a repetitive and costly compliance burden on both the business community and the FTC. Companies are already using established statutes and international recognized procedures to determine country of origin and will continue to do so when the WTO internationally harmonized rules are completed and adopted by the United States. Application of these rules for "Made in USA" claims makes sense in that they bring benefits of predictability, transparency and enforceability to the process. Rather than changing the "all or virtually all" threshold to an across the board percentage (e.g., 50%), domestic origin should be determined and measured via "substantial transformation" taking place in the US as will be embodied within the internationally harmonized "classification-based change " methodology. Value-based systems are too onerous, inaccurate, costly, inflexible, difficult to enforce and inapplicable to all products. To implement these recommendations, perhaps a basic country of origin and supplement statement hierarchy is a possible solution, whereby all US products could clearly identify their origin as such, and where US manufacturers could elect to identify their economic input contribution.{4} We believe that the current hierarchical system of qualifying statements as set forth in Hyde is insufficient and confusing to consumers and manufacturers. One possible solution may be to adopt a system as follows: Any US country of origin product "Made in USA" US country of origin products meeting quantifiable US economic contribution criteria "Made in USA with (or at least)(specific or minimum) xx% US input" US country of origin products meeting current "all or virtually all" standard "Wholly Made in USA" Footnotes: {1} See, e.g. FTC Advisory Opinion 2998 and Advisory Opinion 20. {2} See, e.g. 27 C.C.P.A. 297, 302 {3} Mexican labeling regulations specifically require that the country of origin be imprinted on articles for import into Mexico. These rules do not include unqualified origin statements. {4} For some industries, however, even this solution may not be appropriate and a case-by-case approach should be employed.