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When Should Products be Labeled "Made in USA or China"?

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When Should Products be Labeled "Made in USA or China"?

Question

We have vacuum accessory products that we sometimes make here in the states, and sometimes we purchase in China. Can we mark the package "Made in USA or China"?

Answer

Every article of foreign origin (or its container) imported into the U.S., must be marked in a manner that will indicate to the ultimate purchaser the country of origin of the article (see Title 19 of the Code of Federal Regulations (CFR) Section 134.11). The use of the phrase that you suggest, "Made in USA or China," may not allow the ultimate purchaser to know the country of origin of the specific article he/she purchased and, therefore, may not be allowed. Because this is a complicated law with many exceptions and qualifications, we suggest you consult with an attorney on your specific product to determine appropriate labeling.

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We invite you to submit a question related to the regulations of packaging materials to our Keller and Heckman packaging attorneys.
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