Can the "Made in ..." Labels be Shortened to Only Include the Country of Origin?
We are importing a number of products manufactured offshore for re-sale in the U.S. Some of them are quite small and irregular shaped, and are packed in plastic bags, making labeling difficult. Is a small sticker on the label with just "China", "Taiwan", "Korea", etc. sufficient to serve as manufacturing source, or is the full "Made in China", "Made in Taiwan", "Made in Korea", etc. required?
The Tariff Act of 1930, section 304, requires that "every article of foreign origin . . . imported into the United States shall be marked in a conspicuous place . . . to indicate to an ultimate purchaser in the United States the English name of the country of origin of the article . . . will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article." "Made in," "Product of," and other similar phrases are not usually required. An exception is when the name of a location other than the country in which the article was produced appears on the article or its container.
You mentioned using labels, 19 CFR 134.44 directs that if paper stickers or pressure sensitive labels are used to indicate country of origin, "they must be affixed in a conspicuous place and so securely that unless deliberately removed they will remain on the article while it is in storage or on display and until it is delivered to the ultimate purchaser." Title 19 part 134 of CFR can be found here.
For more specific information concerning your products, please consult an attorney.