Three other little words

Think of these three little words that many people long to hear. “I love you?” No. This is a business blog, which is going to be weird. We’re talking about “Made in the USA.” Proposed FTC settlements with promotional product marketers, including financial judgments, remind companies of the need to substantiate their “Made in the USA” representations.

Gennex Media LLC and owner Akil Kurji sell branded wristbands, lanyards, temporary tattoos and other gadgets and gadgets that are often distributed at trade shows or given to customers or employees. Gennex (also doing business as Brandnex, BrandStrong, PMGOA and Promotional Manufacturing Group of America) prominently promotes its promotional items on its website, social media and YouTube as “Made in the USA,” “Made in the USA,” and “Made in” U.S! ” But in many cases, the products were imported entirely from China, according to the FTC.

The proposed settlement resolves, among other things, ineligible claims (claims without limitation) and qualified claims (claims that include explanatory information).Going forward, Gennex and Kurji are prohibited from making unqualified U.S. origin claims unless they have evidence that final assembly or processing (and all significant processing) of a product occurs in the United States and that all or substantially all ingredients or components are manufactured in the United States and purchase

For a declaration of conformity to be made, the extent to which the product contains foreign matter, ingredients, components or processing must be clearly disclosed.

If they want to say that a product is assembled in the United States, then they have to make sure that the product was last substantially modified in the United States, that its primary assembly takes place in the United States, and that there is a significant amount of assembly operations in the United States.

The order includes $146,249 in financial compensation. Once the proposed settlement appears in the Federal Register, the FTC will accept public comments for 30 days.

The Federal Trade Commission’s Enforcement Policy Statement on U.S. Origin Claims provides guidance for making “Made in the USA” claims. Please visit the Made in the USA page of the Business Center for more resources.