Made In USA Tracker – Media, Telecoms, IT, Entertainment

DATE COMPANY AUTHOR ADDRESSEE/
COPYEE
NATURE OF INQUIRY CLOSING REASON 2/25/2022 Euromarket Designs, Inc., d/b/a Crate and
Barrel
(Made in USA) Julia Solomon
Ensor Staff Attorney

Lashanda Freeman
Federal Trade Investigator

Holly A. Melton, Esq.
Crowell & Moring LLP There were potentially deceptive “Made in
USA” claims for a set of drinking glasses we identified as
containing significant imported content, as well as more general
concerns relating to Crate and Barrel’s process for ensuring
the accuracy of country-of-origin claims across the Company’s
website Crate and Barrel has committed to only making
U.S.-origin claims if the responsible manufacturer or supplier has
signed and submitted appropriate documentation substantiating the
claim. Additionally, the Company confirmed it possessed appropriate
substantiation for, and acknowledged the need to comply with
requirements to disclose, origin on labels and advertising for
products covered by the Textile Act and Rules. Finally, in addition
to imposing contractual obligations on vendors to update
substantiation as circumstances require, the Company committed to
prompting vendors to check and re-certify origin claims on a
regular basis. 12/15/2021 KLOS Innovations LLC
(Made in USA) Julia Solomon
Ensor Staff Attorney

Lashanda Freeman
Federal Trade Investigator

Mr. Adam Klosowiak
Cofounder and CEO
KLOS Innovations LLC, d/b/a KLOS Guitars Marketing materials may have overstated the extent
to which certain guitars are made in the United States.
Specifically, while the Company designs and assembles guitars in
Provo, Utah, KLOS instruments incorporate significant imported
parts. Marketing materials should not convey that
products are “all or virtually all” made in the United
States unless the Company can substantiate that claim. Accordingly,
to avoid deceiving consumers, KLOS implemented a remedial action
plan to qualify its claims. This plan included:
(1) updating the Company website and social media accounts,
including LinkedIn, YouTube, Facebook, Instagram, and Kickstarter
pages; (2) reviewing and updating Facebook and Instagram
advertisements; (3) updating Amazon product listings; and (4)
training staff. 12/15/2021 Neaties Home LLC
(Made in USA) Julia Solomon
Ensor Staff Attorney

Lashanda Freeman
Federal Trade Investigator

Armen Manasserian, Esq.
Chora Young & Manasserian LLP Marketing materials may have overstated the extent
to which Neaties hangers are made in the United States.
Specifically, although most Neaties plastic hangers are “all
or virtually all” made in the United States, Neaties also
offers several lines of imported hangers. Accordingly, product
inserts and banners on the Neaties website and Amazon storefront
stating “Made in USA” or “American Made” were
overly broad. To the extent materials apply to all Company
products, Neaties should avoid creating the impression that all its
products are “all or virtually all” made in the United
States, unless that becomes true. To avoid deceiving consumers,
Neaties implemented a remedial action plan. This plan included
removing unqualified U.S.-origin claims from the Company website
and Amazon storefront, and updating product inserts 12/15/2021 Origin USA, Inc.
(Made in USA) Julia Solomon
Ensor Staff Attorney

Lashanda Freeman
Federal Trade Investigator

Brian D. Keisacker, Esq.
Ulrich, Scarlett, Wickman & Dean, PA Marketing materials may have overstated the extent
to which the Company’s metal doors and windows are made in the
United States. Marketing materials should not convey that
products are “all or virtually all” made in the United
States unless the Company can substantiate that claim. To avoid
deceiving consumers, Origin removed U.S.-origin claims from all
marketing materials and notified staff and accredited agents of
this change. 11/18/2021 Attic Breeze, LLC
(Made in USA) Julia Solomon
Ensor Staff Attorney

Lashanda Freeman
Federal Trade Investigator

Robert D. Stang, Esq.
Husch Blackwell LLP Marketing materials may have overstated the extent
to which certain solar-powered attic fans are made in the United
States. Specifically, while the Company employs workers and
assembles fans in the United States, the fans incorporate
significant imported components. Marketing materials should not convey that
products are “all or virtually all” made in the United
States unless the Company can substantiate those claims.
Accordingly, to avoid deceiving consumers, Attic Breeze implemented
a remedial action plan. This plan included: (1) stickering over
outdated claims on packaging; (2) ordering new packaging with
appropriately qualified claims; (3) updating the company website,
social media accounts, and printed marketing materials; and (4)
communicating changes to distributors and ensuring distributor
marketing materials are updated. 11/18/2021 Designing Fire of South Dakota, Inc., d/b/a
Designing Fire, Inc.
(Made in USA) Julia Solomon
Ensor Staff Attorney

Lashanda Freeman
Federal Trade Investigator

Stacy R. Hegge, Esq.
Gunderson, Palmer, Nelson and Ashmore, LLP Marketing materials may have overstated the extent
to which the Company’s products are made in the United States.
Specifically, although Designing Fire employs workers and performs
manufacturing functions in the United States, the Company’s
Oriflamme Fire Tables incorporate imported tops, and certain
accessories and other products are wholly imported. Marketing materials should not convey that
products are “all or virtually all” made in the United
States unless the Company can substantiate those claims.
Accordingly, to avoid deceiving consumers, Designing Fire removed
unqualified U.S.-origin claims from all marketing materials,
including social media, and required dealers to update marketing
materials consistent with this change. 11/18/2021 Vinotemp International
(Made in USA) Julia Solomon
Ensor Staff Attorney

Lashanda Freeman
Federal Trade Investigator

Mr. Alvin Patrick
VP of Operations
Vinotemp International Marketing materials may have overstated the extent
to which certain wine coolers and wine cellar cooling units are
made in the United States. Specifically, certain marketing
materials were not sufficiently clear that they
applied to particular wine cooling and storage products assembled
in the USA, and may have suggested to consumers that all Company
products underwent significant USA processing. Although Vinotemp
assembles certain products in the United States, it also sells a
line of wholly
imported products. Marketing materials should not convey that
products are “all or virtually all” made in the United
States unless the Company can substantiate those claims.
Accordingly, to avoid deceiving consumers, Vinotemp removed
unqualified U.S.-origin claims from all marketing materials,
including social media, required dealers to update marketing
materials consistent with this change, and trained all staff. 11/18/2021 Electric Mirror, LLC
(Made in USA) Julia Solomon
Ensor Staff Attorney

Lashanda Freeman
Federal Trade Investigator

Justin O’Neill Kay, Esq.
Faegre Drinker Biddle & Reath LLP Certain marketing materials may have
overstated the extent to which certain LED mirrors and accessories
are made in the United
States. Specifically, while the Company employs workers and
performs manufacturing
operations in Everett, WA, Electric Mirror products incorporate
significant imported
components. Marketing materials should not convey that
products are “all or virtually all” made in the United
States unless the Company can substantiate those claims.
Accordingly, to avoid deceiving consumers, Electric Mirror
implemented a remedial action plan. This plan included: (1)
updating the company website, social media accounts, and printed
marketing materials; (2) implementing processes to ensure
U.S.-origin claims are made only after appropriate management
review and approval; and (3) communicating changes to dealers,
auditing dealer marketing materials, and suspending nonresponsive
dealer accounts. 11/18/2021 Netbrands LLC, also d/b/a Netbrands Media
Corporation, 24hourwristbands.com, and  Media Corporation,
24hourwristbands.com, and imprint.com

(Made in USA)

Julia Solomon
Ensor Staff Attorney

Lashanda Freeman
Federal Trade Investigator

Damon W.D. Wright, Esq.
Gordon Rees Scully Mansukhani, LLP First, certain marketing materials including
Google ads and social media materials may have overstates the
extent to which Netbrands offers U.S. origin products. Although
Netbrands offers some U.S. origin products and customizes certain
products in the U.S., it also sells imported products. Second,
certain marketing materials may have failed to comply with
provisions of the Textile Products Identification Act- specifically
on some covered products, materials omitted required origin
information. It is appropriate for Netbrands to promote the
fact that it employs workers in the U.S., sells some U.S. origin
products, and has capacity to customize certain products in the
U.S. However, marketing materials that cover imported products or
products incorporating significant imported components must not
overstate the extent to which those products were made in the
U.S.

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