# Assembled in? Made in?



## jonnie23 (Dec 9, 2010)

Hey everyone,

Can I put "assembled in" instead of "made in" on my labels? Also, do you think it's very important to screen my labels in if I'm going to start out selling very small quantities online? Getting all the different label screens made is very costly.

Example:

Assembled in Mexico from USA fabric


Thanks,
Jonnie


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## splathead (Dec 4, 2005)

Yes, you would have to use wording similar to that. Here are the complete labeling rules: Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts | BCP Business Center


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## jonnie23 (Dec 9, 2010)

Thanks, so can I say assembled in, instead of, made in?


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## splathead (Dec 4, 2005)

"If processing or manufacturing takes place in the U.S. and another country, the label must identify both aspects of production. For example:
Made in Sri Lanka,
finished in U.S.A.
​ Comforter filled,
sewn and finished in U.S.A.
with shell made in Malaysia
​ Assembled in U.S.A.
of imported components"​


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## DiveArtist (Jan 7, 2009)

splathead said:


> "If processing or manufacturing takes place in the U.S. and another country, the label must identify both aspects of production. For example:
> Made in Sri Lanka,
> finished in U.S.A.
> ​ Comforter filled,
> ...


I am using blanks that are made in CHina that I buy from a manufacturer who is in California. I then have the shirts printed with my designs in Florida.Can I say something like:

Made in China
Designed and Finished in USA

or

Made in China
Printed in USA

or 

Designed & Assembled in U.S.A.
of imported components


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## splathead (Dec 4, 2005)

What does the CA manufacturer do to the blank from China?


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## DiveArtist (Jan 7, 2009)

splathead said:


> What does the CA manufacturer do to the blank from China?


I think they just buy them and resell them. The manufacturer is Next Level Apparel. On their labels it reads Made in China.


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## splathead (Dec 4, 2005)

Then that's what yours should say too. They are not assembled in the U.S. and you don't have enough information to know if they were designed here either.


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## DiveArtist (Jan 7, 2009)

splathead said:


> Then that's what yours should say too. They are not assembled in the U.S. and you don't have enough information to know if they were designed here either.


I am referring to my design and the printing. Since they are being printed in the USA shouldn't that be reflected in the label?


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## splathead (Dec 4, 2005)

DiveArtist said:


> I am referring to my design and the printing. Since they are being printed in the USA shouldn't that be reflected in the label?


The labeling law does not address design printing, probably because the vast majority of garments are never printed.

As long as you include the required info, the law does not forbid you from including wording like "designs created & printed in the U.S."


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## BroJames (Jul 8, 2008)

While it may not be illegal to do what the law does not forbid, in regulatory matters such as labelling, I think that a strict interpretation of the law translates to "you should do what the law allows or requires". 

It may not be illegal to put in "Printed in the USA" within the context of post #10 it may be illegal not to put in "Made in China" or "Finished in the USA" if such are the wordings required by law in relation to the link in post #2 and quote in post #4.


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## DiveArtist (Jan 7, 2009)

BroJames said:


> While it may not be illegal to do what the law does not forbid, in regulatory matters such as labelling, I think that a strict interpretation of the law translates to "you should do what the law allows or requires".
> 
> It may not be illegal to put in "Printed in the USA" within the context of post #10 it may be illegal not to put in "Made in China" or "Finished in the USA" if such are the wordings required by law in relation to the link in post #2 and quote in post #4.


Maybe the way to do it is:
Made in China
Finished in USA


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## kimura-mma (Jul 26, 2008)

DiveArtist said:


> Maybe the way to do it is:
> Made in China
> Finished in USA


According to the info you have provided, the shirt is finished in China, not the USA.


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## DiveArtist (Jan 7, 2009)

Then how should I word the label?
Made in China
Artwork designed and printed in USA


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## kimura-mma (Jul 26, 2008)

The label should just have "Made in China." Nothing else is needed.


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## DiveArtist (Jan 7, 2009)

kimura-mma said:


> The label should just have "Made in China." Nothing else is needed.


But I would like to indicate that some of the work is done in the USA. The design and printing (which is the decoration) is done in the US.


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## BroJames (Jul 8, 2008)

For shirts imported from China, "Made in China" is required under your textile and wool act. That act seems to be concerned more with the materials or fibers used and not decorative printing. I think there should be no problem in adding "Artwork designed and printed in USA". A visit to your local trade commission office should be prudent.


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## kimura-mma (Jul 26, 2008)

DiveArtist said:


> But I would like to indicate that some of the work is done in the USA. The design and printing (which is the decoration) is done in the US.


Then you should have that info on your website, hangtag, etc.

There really is no need to clutter your legally required label with non-required information.

But if you are hell bent on doing so, "Artwork designed and printed in USA" is fine.


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## DiveArtist (Jan 7, 2009)

kimura-mma said:


> Then you should have that info on your website, hangtag, etc.
> 
> There really is no need to clutter your legally required label with non-required information.
> 
> But if you are hell bent on doing so, "Artwork designed and printed in USA" is fine.


Thank you. Here's another question: I was reading through the regulations but couldn't get a clear answer on this:
Regarding sewn in labels vs screen printed labels. Is there any restrictions in printing all the information on the inside of the shirt? 

Also, if one of the shirt styles that I am buying is manufactured either in Nicaragua and some in Mexico. How Do I handle labeling for that?


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## splathead (Dec 4, 2005)

DiveArtist said:


> Thank you. Here's another question: I was reading through the regulations but couldn't get a clear answer on this:
> Regarding sewn in labels vs screen printed labels. Is there any restrictions in printing all the information on the inside of the shirt?


It has to be somewhere on the shirt, not necessarily inside. Is that your question?



> Also, if one of the shirt styles that I am buying is manufactured either in Nicaragua and some in Mexico. How Do I handle labeling for that?


You would need 2 labels.


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## DiveArtist (Jan 7, 2009)

splathead said:


> It has to be somewhere on the shirt, not necessarily inside. Is that your question?
> 
> 
> 
> You would need 2 labels.


Thanks for your answer but, my question is are printed on the shirt labels ok vs sewn in labels?


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## kimura-mma (Jul 26, 2008)

Printing the label is an acceptable alternative to the sewn in label. All labeling requirements still apply, meaning all info that you would put on the sewn label needs to be on the printed label.


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## chris1 (Nov 10, 2010)

If you want to put 
"Made in China
Artwork designed and printed in USA" 
to market the USA input, then it's allowed. Just don't make the USA statement a bigger bolder font. 

And yes, all that is required is Made in China.

Here's a cut and paste from a blog about labeling. Probably too much information. 

Let’s move to apparel labeling requirements for the USA. I must commend someone in the government for their sense of humor as many of these free informative booklet's have cute titles like this one called_*Threading Your Way Through the Labeling Requirements Under the Textile and Wool Acts*_
Check it out at this link http://www.ftc.gov/bcp/edu/pubs/business/textile/bus21.shtm

I wish the Federal Trade Commission and their _*Writing a Care Label *_http://www.textilecare.com/writing.htm booklet and the Consumer Product Safety folks and their textile *Flammable Fabrics Act *http://www.cpsc.gov/businfo/ffa.pdf (and no this isn't just for children's sleepwear) would all get together and publish one booklet.


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## BroJames (Jul 8, 2008)

DiveArtist said:


> ...if one of the shirt styles that I am buying is manufactured either in Nicaragua and some in Mexico. How Do I handle labeling for that?


I think I read somewhere in the ftc link above that says anything on the shirt that comprises N% or more of the shirt, for example a sewn cape, must be included in the labelling. Something like Shirt Made in Nicaragua, Cape made in Mexico. Do check the links.


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## chris1 (Nov 10, 2010)

For USA -When in doubt, can always ask for a binding ruling. Can search through the data base of ruling called CROSS which stand for Customs Rulings Online Search Systems. Probably find a similar ruling already published. Companies used to be all kinds of games where parts of garments were assembled in multiple countries to skirt around restraint quota barriers. 
Here's the link CROSS Customs Rulings Online Search System try "sewn china print usa" in the search box


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## DiveArtist (Jan 7, 2009)

chris1 said:


> For USA -When in doubt, can always ask for a binding ruling. Can search through the data base of ruling called CROSS which stand for Customs Rulings Online Search Systems. Probably find a similar ruling already published. Companies used to be all kinds of games where parts of garments were assembled in multiple countries to skirt around restraint quota barriers.
> Here's the link CROSS Customs Rulings Online Search System try "sewn china print usa" in the search box


Thank you. I did check the link and I found what I think is the answer at this link: CROSS Customs Rulings Online Search System

Here is the paragraph that I think answers my question:
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C.

1304), provides that, unless excepted, every article of foreign origin imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) 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. Congressional intent in enacting 19 U.S.C. 1304 was that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. 
As provided in section 134.41, Customs Regulations (19 CFR 134.41), the country of origin marking is considered to be conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain. You state that each of the two labels will be sewn into the imported garment in a conspicuous spot as already accepted by Customs based on the type of garment. However, because a sample garment marked with the proposed marking was not submitted for our review, we can not determine whether the origin marking printed on the second label is conspicuously located on the garment. 
Section 134.46, Customs Regulations (19 CFR 134.46), requires that in any case in which the words "United States," or "American," the letters "U.S.A.," any variation of such words or letters, or the name of any city or locality in the United States, or the name of any foreign country or locality other than the country or locality in which the article was manufactured or produced, appears on an imported article or its container, there shall appear, legibly and permanently, in close proximity to such words, letters, or name, and in at least a comparable size, the name of the country of origin preceded by "Made in," Product of," or other words of similar meaning. The purpose of this section is to prevent the possibility of misleading or deceiving the ultimate purchaser as to the actual origin of the imported goods.


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## splathead (Dec 4, 2005)

Look guys, bottom line, once you are sure you've put the required amount of information required by the FTC, you can then put _anything_ else on the label that you want. I have seen labels go half way down the back of the tee with info, stories, history, blah, blah, blah. So just make sure you comply with the FTC and then be creative as you want after that.


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## BroJames (Jul 8, 2008)

Anything so long as the required information remains conspicuous.


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