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What Are the "Made in USA" Labeling Requirements for a Product Manufactered in U.S. and China?

August 25, 2009
Question 

Our product has two components; one is made in China and the other is made in the U.S. We realize that we have to disclose China, so can we simply state "Made in the U.S.A. and China"?

Answer 

When an imported article is combined with another component in the U.S., the label on the final product must include the country of origin of the imported component and include "words or symbols which shall clearly show that the origin indicated is that of the imported article only and not that of any other article with which the imported article may be combined after Importation" (see Title 19 of the Code of Federal Regulations (CFR) Section 134.14). The short answer to your question is "no," however, since there are many exceptions and qualifications to this law, we suggest you consult with an attorney or other qualified consultant on your specific product to determine appropriate labeling.