BILL ANALYSIS                                                                                                                                                                                                    �






                             SENATE JUDICIARY COMMITTEE
                             Senator Noreen Evans, Chair
                              2013-2014 Regular Session


          SB 661 (Hill)
          As Amended January 6, 2014
          Hearing Date: January 14, 2014
          Fiscal: No
          Urgency: No
          TH


                                        SUBJECT
                                           
                          False Advertising: Made in U.S.A.

                                      DESCRIPTION  

          Under existing California law, a product may not be sold in  
          California as "Made in U.S.A." or "Made in America" if the  
          product, or any article, unit, or part of the product, has been  
          entirely or substantially made, manufactured, or produced  
          outside of the United States.  This bill would provide that  
          merchandise made, manufactured or produced in the United States  
          that has an article, unit, or part from outside of the United  
          States may be sold in California as "Made in U.S.A." or "Made in  
          America" if the merchandise meets all of the following  
          requirements:
           the manufacturer of the merchandise certifies that it can  
            neither produce the foreign article, unit, or part within the  
            United States nor obtain the foreign article, unit, or part  
            from a domestic source;
           the article, unit, or part of the merchandise obtained from  
            outside the United States constitutes only a negligible part  
            of the final manufactured product; and
           the determination that the article, unit, or part of the  
            merchandise cannot be produced or obtained within the United  
            States from a domestic source is not based on the cost of the  
            article, unit, or part.
                                           
                                     BACKGROUND  

          The Legislature has long considered consumer protection to be a  
          matter of high public importance.  State law is replete with  

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          statutes aimed at protecting California consumers from unfair,  
          dishonest, or harmful market practices.  The Consumer Legal  
          Remedies Act (Civ. Code Sec. 1750 et seq.), for example, was  
          enacted "to protect the statute's beneficiaries from deceptive  
          and unfair business practices," and to provide aggrieved  
          consumers with "strong remedial provisions for violations of the  
          statute."  (Am. Online, Inc. v. Superior Court (2001) 90  
          Cal.App.4th 1, 11.)  Similarly, California's Unfair Practices  
          Act (Bus. & Prof. Code Sec. 17000 et seq.) has protected  
          California consumers from "unlawful, unfair or fraudulent  
          business act[s] or practice[s]" for over 70 years.  (Bus. &  
          Prof. Code Sec. 17200.)  Consumer protection regarding country  
          of origin labeling is no less a matter of fundamental public  
          policy.  Since 1961, California has expressly required that  
          businesses meet certain standards before they can claim that  
          their products are "Made in U.S.A."  California law prohibits a  
          product from being labeled and sold in California as "Made in  
          U.S.A." or "Made in America" when the product, or any article,  
          unit, or part of the product, has been entirely or substantially  
          made outside of the United States.  California courts have  
          construed the law as requiring that the component parts of a  
          product be entirely or substantially made in the United States  
          in order for a "Made in U.S.A." claim to be permissible.  (See,  
          e.g., Colgan v. Leatherman Tool Group, Inc. (2006) 135  
          Cal.App.4th 663.)

          California's "Made in U.S.A." law not only protects consumers  
          against false or misleading advertising, but also protects  
          domestic businesses and the market value of the "Made in  
          America" label by ensuring that companies cannot gain a  
          competitive advantage through false or misleading advertising.   
          The value of a "Made in America" label in the manufacturing  
          sector is substantial, as demonstrated by the fact that  
          California's largest corporation, Apple Inc., recently shifted  
          production of its Mac Pro personal computer line to the United  
          States as part of a "$100 million 'made in the USA' push."   
          (Burrows, Apple Kicks Off "Made in USA" Push with Mac Pro (Dec.  
          18, 2013) The San Francisco Chronicle  
           (as of January 4, 2014).)   
          Announcing the company's shift to domestic production, Chief  
          Executive Officer Tim Cook said "[w]e don't want to just  
          assemble the Mac Pro here, we want to make the whole thing here.  
           This is a big deal."  (Ibid.)  Apple's decision reflects the  
          market reality that products advertised or labeled as "Made in  

                                                                      




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          U.S.A." have a decisive marketplace advantage over their foreign  
          counterparts.  Indeed, an April 2013 Gallup poll found that 45  
          percent of Americans surveyed had made a recent special effort  
          to buy products that were made in the U.S.A., and that 64  
          percent of those surveyed would pay more to buy an American-made  
          product than a similar product made in other countries.  (Jones,  
          Patriotism, Jobs Primary Motivations for 'Buying American' (Apr.  
          30, 2013) Gallup Economy <  
          http://www.gallup.com/poll/162110/patriotismjobs-primary-motivati 
          ons-buying-american.aspx> (as of January 5, 2014).)

          This bill would provide that merchandise made, manufactured or  
          produced in the United States that has an article, unit, or part  
          from outside of the United States may be labeled and sold in  
          California as "Made in U.S.A." or "Made in America" if the  
          following requirements are met:  (1) the manufacturer of the  
          merchandise certifies that it can neither produce the article,  
          unit, or part within the United States nor obtain the article,  
          unit, or part of the merchandise from a domestic source; (2) the  
          manufacturer's determination that the article, unit, or part  
          cannot be produced or obtained within the United States from a  
          domestic source is not based on the cost of the article, unit,  
          or part; and (3) the article, unit, or part of the merchandise  
          obtained from outside the United States constitutes only a  
          negligible part of the final manufactured product.

          This bill is similar to AB 890 (Jones, 2013), which failed  
          passage in this Committee on a vote of 2-5.  This bill is also  
          similar to AB 858 (Jones, 2012), which failed passage in this  
          Committee on a vote of 2-3.

                                CHANGES TO EXISTING LAW
           
           Existing law  protects consumers and competitors against  
          unlawful, unfair or fraudulent business acts or practices and  
          unfair, deceptive, untrue or misleading advertising.  (Bus. &  
          Prof. Code Sec. 17200 et seq.)

           Existing law  makes it unlawful for any person, firm, corporation  
          or association, or any employee thereof, to make or disseminate  
          before the public in this state, in any newspaper or other  
          publication or in any other manner or means whatever, any  
          statement concerning personal property which is untrue or  
          misleading, and which is known, or which by the exercise of  
          reasonable care should be known, to be untrue or misleading.   

                                                                      




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          (Bus. & Prof. Code Sec. 17500 et seq.)

           Existing law  provides that the following are unfair methods of  
          competition and unfair or deceptive acts or practices:  (1)  
          using deceptive representations or designations of geographic  
          origin in connection with goods or services; and (2)  
          misrepresenting the source of goods or services.  (Civ. Code  
          Sec. 1770.)

           Existing law  makes it unlawful for any person, firm, corporation  
          or association to sell or offer for sale in this State any  
          merchandise on which merchandise or on its container there  
          appears the words "Made in U.S.A.," "Made in America," "U.  
          S.A.," or similar words when the merchandise or any article,  
          unit, or part thereof, has been entirely or substantially made,  
          manufactured, or produced outside of the United States.  (Bus. &  
          Prof. Code Sec. 17533.7.)

           Existing federal law  authorizes the Federal Trade Commission to  
          regulate claims of U.S. origin pursuant to authority granted to  
          it under the Federal Trade Commission Act, which prohibits  
          "unfair or deceptive acts or practices."  (15 U.S.C. Sec. 45.)   
          Existing federal law requires that a "Made in U.S.A." label be  
          consistent with orders and decisions of the Federal Trade  
          Commission.  (15 U.S.C. Sec. 45a.)

           Existing federal policy  provides that a product may be labeled  
          as "Made in U.S.A." if the product is all or virtually all made  
          in the United States, however a product using such a label may  
          contain-in a negligible amount-components made outside of the  
          United States.  (Federal Trade Commission, Enforcement Policy  
          Statement on U.S. Origin Claims, 62 Fed. Reg. 63756, 63765 (Dec.  
          2, 1997).)

           This bill  would provide that, merchandise made, manufactured or  
          produced in the United States that has an article, unit, or part  
          from outside of the United States may be labeled and sold in  
          California as "Made in U.S.A." or "Made in America" if both of  
          the following apply:
           The manufacturer of the merchandise certifies that it can  
            neither produce the article, unit, or part within the United  
            States nor obtain the article, unit, or part of the  
            merchandise from a domestic source.
           The article, unit, or part of the merchandise obtained from  
            outside the United States constitutes only a negligible part  

                                                                      




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            of the final manufactured product.

           This bill  would also specify that a manufacturer's determination  
          that an article, unit, or part of the merchandise cannot be  
          made, manufactured, produced, or obtained within the United  
          States from a domestic source shall not be based on the cost of  
          the article, unit, or part.

                                        COMMENT
           
          1.  Stated need for the bill  
          
          The author writes:
          
            California is the only state in the country that establishes a  
            100 percent threshold [for employing a "Made in U.S.A."  
            label].  All 49 other states and the federal government use  
            the more flexible "all or virtually all" standard for  
            determining when a product is eligible to be labeled as "Made  
            in USA."

            SB 661 updates California's 50-year-old "Made in USA" labeling  
            standard by clarifying that a manufacturer may label a product  
            as "Made in the USA" if a part, which constitutes only a  
            negligible part of the final manufactured product, is  
            physically not available domestically.  The determination that  
            the negligible part cannot be obtained [within] the U.S.  
            cannot be based solely on the cost of the part.
            . . .

            The term "negligible" is intended to provide flexibility to  
            manufacturers who cannot obtain minor parts domestically.  The  
            FTC also uses the term "negligible" for their standard.  Their  
            Enforcement Policy Statement does not set a particular point  
            of reference for the term "negligible."  Instead, a  
            case-by-case analysis is used that includes the review of a  
            number of factors, including the percentage of US vs. foreign  
            costs and how far back in the manufacturing chain the foreign  
            content is.

          2.    Bill would adopt a weaker standard for "Made in U.S.A."  
          claims  

          Since 1961, California law has prohibited products from being  
          sold as "Made in U.S.A." or "Made in America" when the product,  

                                                                      




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          or any article, unit, or part of the product, has been entirely  
          or substantially made outside of the United States.  This bill  
          seeks to expand the use of the "Made in U.S.A." label by  
          specifically allowing manufacturers whose merchandise is made,  
          manufactured or produced in the United States but has an  
          article, unit, or part from outside of the United States to  
          nonetheless label and sell their merchandise in California as  
          "Made in U.S.A." or "Made in America" if, among other things,  
          the article, unit, or part of the merchandise obtained from  
          outside the United States constitutes only a "negligible" part  
          of the final manufactured product.  The bill, however, does not  
          define the word "negligible," which has led to some confusion  
          among stakeholders as to when a product with foreign content may  
          lawfully be labeled "Made in America."<1>  "Negligible,"  
          according to Merriam Webster's Dictionary, means "so small or  
          unimportant or of so little consequence as to warrant little or  
          no attention; trifling."  The author, in contrast, suggests that  
          the definition of "negligible" could be clarified "by adding the  
          phrase 'of up to no more than 10 [percent] of the final  
          manufactured product,' or a variation thereof."  The substantial  
          difference between these two understandings of the word  
          "negligible" - a trifling amount versus up to 10 percent of the  
          final product - reflects the difficulty inherent in defining a  
          relative term that is susceptible of many interpretations.  Just  
          as with the relative term "valuable," the quantity of foreign  
          content "which is considered [negligible] by one court or jury  
          might not be considered so by another."  (U.S. v. Fabro, Inc.,  
          206 F.Supp. 523, 526 (M.D. Ga. 1962).)  The same can be said for  
          manufacturers and consumers, who might also differ over what  
          they consider to be "negligible" foreign content in a particular  
          product.

          Additionally, the bill does not clearly indicate whether the  
          "negligible" foreign content restriction applies only to  
          articles, units, or parts measured on an individual component  
          basis, or whether it also applies to the aggregate sum of  
          foreign content present in a final manufactured product.  One  
          can imagine that a product may contain several components each  
          with "negligible" foreign content when viewed individually as  
          part of a larger whole, but whose aggregate foreign content  
          taken together crosses the threshold of "negligibility."  Could  
          ---------------------------
          <1> Staff notes that the bill would also create a potentially  
          ambiguous "certification" standard for determining when a  
          component of a manufactured product cannot be produced or  
          obtained domestically.

                                                                      




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          such a product lawfully bear a "Made in America" label under  
          this bill?

          Without further delineating and restricting the permissible  
          threshold of "negligible" foreign content, the practical effect  
          of this bill may be to permit products to be labeled as "Made in  
          America" even though they contain appreciable foreign content.   
          Put another way, this bill would permit products sold in  
          California to be labeled as "Made in America" when, in fact,  
          that statement is not true.

          The policy question raised by this bill is whether it is  
          appropriate to lower California's standard for labeling products  
          as "Made in U.S.A." to permit manufacturers whose products  
          contain foreign content to enjoy the economic benefits of the  
          label, but which could result in less truthful and less accurate  
          product labels.  In general, the legislative preference has been  
          to ensure that California laws are strong and sufficiently  
          protect consumers, in this case, against unfair and deceptive  
          business practices, including false or misleading advertising.   
          The effect of the new standard created by this bill would be to  
          essentially weaken California law in a way that allows consumers  
          to be misled by the "Made in U.S.A." label.

          Indeed, depending on how the term "negligible" is interpreted,  
          the new standard set by this bill may end up providing less  
          protection than (and thereby contravene) federal labeling laws.   
          Existing federal law requires that a "Made in U.S.A." label be  
          consistent with orders and decisions of the Federal Trade  
          Commission (FTC), which provides that a product may be labeled  
          as "Made in U.S.A." if the product is all or virtually all made  
          in the United States.  The FTC, in its Enforcement Policy  
          Statement on U.S. Origin Claims, rejected adopting a percentage  
          benchmark approach to determining whether a product is all or  
          virtually all made in the United States, and declined to craft  
          any specific "bright-line" standard for evaluating U.S. origin  
          claims, stating instead that "[g]iven the complex and varied  
          factual scenarios that present themselves in this area, and the  
          wide range of product for which U.S. origin claims may be made,  
          there are necessarily issues that will continue to be more  
          appropriately resolved on a case-by-case basis." (Federal Trade  
          Commission, Enforcement Policy Statement on U.S. Origin Claims,  
          62 Fed. Reg. 63756, 63765 (Dec. 2, 1997).)  If a broader  
          interpretation of the word "negligible" is embraced, this bill  
          may be read in such a way as to create a foreign content safe  

                                                                      




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          harbor in California law which, depending on the product at  
          issue, could exceed the amount of foreign content permissible  
          under the FTC's "all or virtually all" standard.

          DOES AMBIGUITY IN THE DEFINITION OF NEGLIGIBLE AUTHORIZE THE USE  
          OF MISLEADING LABELS?

          3.  Ensuring consumers get the benefit of their bargain and  
            assuring consumer confidence  

          California's "Made in U.S.A." law, along with California's other  
          strong statutes on false advertising and misrepresentation, are  
          intended to protect both consumers and competitors in the  
          marketplace.  Collectively, these statutes promote fair  
          competition and help to ensure that consumers have the  
          information that they need to make informed purchasing  
          decisions.  The key to ensuring that consumers are able to make  
          informed purchasing decisions and get the benefit of their  
          bargain-i.e. get what they pay for-is to make sure that product  
          labels are accurate and truthful, including labels stating that  
          a product is "Made in U.S.A."

          Many consumers have indicated that whether or not a product is  
          American-made is important to them, and market research  
          indicates that they are willing to pay more for a product if  
          they know that it is made in the United States.  These consumer  
          sentiments came to light when, in 1997, the FTC considered  
          revising its "Guides for the Use of U.S. Origin Claims" in a way  
          that would have weakened the federal standard.  Overwhelmingly,  
          consumers opposed the proposed revisions and "generally  
          supported an 'all of virtually all' standard or advocated a  
          specific percentage, usually 90 percent or, more often, 100  
          percent."  (Federal Trade Commission, Enforcement Policy  
          Statement on U.S. Origin Claims, 62 Fed. Reg. 63756, 63758 (Dec.  
          2, 1997).)  The FTC noted that "[s]everal commenters asserted  
          that changing the current standard would confuse consumers who  
          wish to buy American products, leaving them unable to determine  
          whether a product was truly made in the United States."  (Ibid.)  
           One commenter noted:

            If a product is only partially made in our Country, I want to  
            know.  I do not wish to purchase items made in other countries  
            and falsely labeled "Made in America."  I want the entire  
            truth on the label.  I don't want to be tricked into buying an  
            item I think is made here when in fact it is not.  (Ibid.)

                                                                      




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          Another commenter wrote:

            The concept of "Made in the U.S.A." has been specific and  
            definite for the last 50 years.  Please leave it as it is.  If  
            manufacturers want to say an item is "Made in the U.S.A." then  
            make sure it is exactly that.  "Made in the U.S.A." should  
            mean that an item is 100 [percent] manufactured in the United  
            States of America and not in another country.  (Ibid.)

          In January 2011, the California Supreme Court further described  
          the importance of truthful and accurate claims of domestic  
          origin, stating: 

            In particular, to some consumers, the "Made in U.S.A." label  
            matters.  A range of motivations may fuel this preference,  
            from the desire to support domestic jobs, to beliefs about  
            quality, to concerns about overseas environmental or labor  
            conditions, to simple patriotism.  The Legislature has  
            recognized the materiality of this representation by  
            specifically outlawing deceptive and fraudulent "Made in  
            America" representations.  . . .  The object of section  
            17533.7 "is to protect consumers from being misled when they  
            purchase products in the belief that they are advancing the  
            interests of the United States and its industries and  
            workers."  (Sen. Holmdahl, sponsor ? letter to Governor Brown,  
            May 23, 1961) ['There are many Americans who feel that  
            American-made articles are of higher quality, and who rely on  
            the "Made in U.S.A." label'].) . . ."  The Legislature  
            evidently recognized some companies were using or might be  
            tempted to use inaccurate "Made in America" labeling, that  
            some consumers might be deceived by and rely on it, and that  
            consumers and competitors who honestly made their wares in the  
            United States and marketed them as such were being or would be  
            harmed.  (Kwikset Corp. v. Benson (2011) 51 Cal.4th 310, 329;  
            citations omitted.)

          This bill seeks to expand the use of the "Made in U.S.A." label  
          by specifically allowing the label to be used on products with  
          foreign-made components, so long as each foreign component  
          constitutes only a negligible part of the final manufactured  
          product.  The policy question raised by this bill is whether, by  
          adopting a weaker standard that could result in less truthful  
          and less accurate "Made in U.S.A." labels, the bill would impair  
          a consumer's ability to rely on labels and to make fully  

                                                                      




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          informed decisions.  In opposition to the bill, the Consumer  
          Federation of California (CFC) writes:  

            It would be false advertising to offer a product for sale with  
            a "kosher" label if 10 [percent] of the product is pork, or as  
            "vegan" if 10 [percent] of the product is meat or cheese, or  
            as a particular year and vintage of wine if 10 [percent] of  
            the content were grapes of another year and another region.   
            We believe that it is equally false advertising to label a  
            product as "Made in the USA" if 10 [percent] of the product's  
            content or value is not American.  The Kwikset Court pointed  
            out that an economic loss to a consumer occurs if the consumer  
              relied on the truthfulness of the label in deciding to  
            purchase a product that he or she would not have purchased had  
            it borne an accurate content label.

          Accordingly, the practical effect of this bill would be to allow  
          manufacturers to mislead consumers by claiming that a product is  
          "Made in America" when that statement is not entirely true.

          SHOULD MANUFACTURERS BE PERMITTED TO USE INACCURATE COUNTRY OF  
          ORIGIN LABELS ON THEIR PRODUCTS?

          4.  Bill could have the effect of increasing the percentage of  
            foreign labor or foreign materials in goods and products that  
            have the "Made in U.S.A." label
           
          Several proponents of SB 661 argue that existing California law  
          disincentivizes companies from making their products in the  
          United States because California's domestic origin labeling  
          standard is so strict.  For example, the author writes:

               Over 50 years [after the enactment of California's "Made in  
               America" statute, the law] is having the reverse impact of  
               what was intended: it's penalizing California companies who  
               are making products consisting of nearly all US components.  
                Today's global economy is different than the economy in  
               1961.  Modern companies rely on components from around the  
               world.  California companies shouldn't be penalized if  
               almost all of their products' components are from US  
               sources but a small percentage of the product is from  
               foreign sources due to lack of availability in the U.S.

          Despite these assertions, staff notes that because the "Made in  
          U.S.A." label can have such marketing significance, existing law  

                                                                      




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          arguably incentivizes companies to make their products here in  
          the United States, thus creating domestic jobs.  As the  
          California Supreme Court noted in the Kwikset case, "[s]imply  
          stated: labels matter:"

                The marketing industry is based on the premise that labels  
               matter, that consumers will choose one product over another  
               similar product based on its label and various tangible and  
               intangible qualities they may come to associate with a  
               particular source.  An entire body of law, trademark law  
               (see, e.g., 15 U.S.C. � 1051 et seq. [Lanham Act]), exists  
               to protect commercial and consumer interests in accurate  
               label representations as to source, because consumers rely  
               on the accuracy of those representations in making their  
               buying decisions. (Kwikset Corp. v. Benson (2011) 51  
               Cal.4th 310, 328; citations omitted.)

          Given that this bill would permit companies who sell their goods  
          in California to use a certain quantity of foreign-made  
          components in their products and still derive the benefits of a  
          "Made in U.S.A." label, the bill arguably reduces current market  
          incentives for manufacturers to find a way to source 100 percent  
          of their components in the United States.  By reducing these  
          existing market incentives, this bill would likely bring about  
          an overall increase in the percentage of foreign labor or  
          foreign material contained in products labeled "Made in  
          America."

          A key policy question, therefore, is whether California should  
          use its truth in advertising laws to incentivize businesses to  
          manufacture products domestically, or whether it should relax  
          labeling standards and officially embrace a certain threshold of  
          foreign-sourced components in "Made in U.S.A." products.   
          Creating exemptions of the sort envisioned in this bill might  
          undercut existing market incentives that drive domestic  
          production and keep businesses from surrendering to cheap  
          foreign labor costs or lax regulatory environments, and, for  
          those products that are not or have not historically been  
          produced in the United States, might defeat market pressure to  
          innovate and start such production domestically.

          5.  Existing unfair competition laws protect businesses as well  

          California's laws against false and deceptive advertising also  
          protect businesses by ensuring that unfair and deceptive  

                                                                      




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          business practices do not take hold in the marketplace.  As a  
          result, the laws incentivize businesses to engage in truthful  
          and accurate advertising, which is critical to ensuring that  
          businesses play on a level playing field.  This bill would  
          potentially upend that playing field, placing businesses that  
          have found ways to make 100 percent of a product in the United  
          States at a competitive disadvantage with a competitor who  
          outsources a certain quantity of their product's components.

          Furthermore, as noted in Comment 2, this bill is potentially  
          more confusing and deceptive for businesses that rely on the new  
          California standard because products that adhere to the new  
          standard may nonetheless be held in violation of the federal  
          standard.  Although the author argues that this bill is  
          intended, in part, to provide uniformity for companies selling  
          products in all 50 states, the bill would still create a  
          different standard from that of the FTC, leading to potential  
          conflicts between the two standards, and to difficulty for  
          manufacturers who sell "Made in America" products both within  
          and outside of California.

          Finally, it should be noted this bill would not give California  
          businesses any more of a competitive advantage or disadvantage  
          based on product labeling than they currently receive under  
          existing law.  California's labeling laws create a level playing  
          field for all manufacturers who sell goods in this state, and  
          impose no more of a burden on manufacturers who choose to locate  
          in California than on those who choose to locate in another  
          state.  As the Consumer Federation of California, in opposition,  
          states:

               [The law] applies to every product "offered for sale" in  
               our state, regardless of the location where the product was  
               manufactured.  The law establishes a level playing field  
               for all domestic manufacturers.  A business manufacturing  
               products in Nevada, Mississippi or another state that does  
               not have a comparable labeling law gains no labeling  
               advantage over a California-based manufacturer, should that  
               out-of-state manufacturer offer its products for sale in  
               California.  Similarly, a California manufacturer has no  
               labeling disadvantage if it is manufacturing products that  
               will be offered for sale only outside our state.

          6.  Existing law already permits businesses to label their  
            products with a qualified claim  

                                                                      




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          The author asserts that the need for this bill arises, in part,  
          because a business may manufacture nearly its entire product in  
          the United States but if one component of that product is made  
          outside of the United States, California law would prohibit use  
          of the "Made in U.S.A." label.  Although the author correctly  
          asserts that a product not meeting California's high standard  
          for being labeled as "Made in U.S.A." could be required to adopt  
          separate labeling for units sold in the state, it is important  
          to note that there is nothing in existing law which would  
          preclude businesses from employing a truthful qualified claim  
          for products that contain foreign parts.  For example, labels  
          that truthfully state "90 percent Made in the U.S.A.,"  
          "Assembled in the U.S.A.," "Assembled in California," "Designed  
          in California," or "Assembled in U.S.A. with 85 percent U.S.A.  
          content" would all be permissible under California law.   
          California's "Made in America" statute only prohibits use of the  
          pure "Made in U.S.A." label when the product at issue is not  
          truly made in the United States.

          Qualified claims of domestic origin accurately inform consumers  
          that, although the product was mostly made in the United States,  
          parts of the product were made outside the country.  A  
          manufacturer that labels their product with a qualified claim is  
          able to gain the advantage of advertising the degree to which  
          their product was truly "Made in the U.S.A." without deceiving  
          the consumer.  Further, a qualified claim of domestic origin  
          would arguably satisfy both California and federal law, allowing  
          manufacturers who use them to uniformly label products offered  
          for sale in all 50 states.

          7.  Pending litigation  

          In the past, this Committee has raised concerns about bills that  
          interfere with pending litigation.  Any such interference could  
          result in a direct financial windfall to a private party,  
          prevent a court from deciding an action based upon the laws in  
          place at the time the cause of action accrued, or create a  
          situation where the Legislative branch is used to circumvent the  
          discretion and independence of the Judicial branch.  The  
          Committee has received notice of several lawsuits against  
          various out-of-state defendants that allegedly falsely labeled  
          products for sale in California as "Made in U.S.A." in violation  
          of existing state law.  This bill does not specify how it would  
          impact pending litigation.

                                                                      




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           Support  :  4S Industries, Inc.; California Asian Pacific Chamber  
          of Commerce; California Manufacturers and Technology  
          Association; California Retailers Association; California Small  
          Business Association; Made in the USA Foundation; National  
          Federation of Independent Business; Star Milling Co.

           Opposition  :  Consumer Federation of California (unless amended);  
          California Labor Federation; California Teamsters Public Affairs  
          Council; San Mateo County Central Labor Council; United Food and  
          Commercial Workers Union, Western States Council

                                        HISTORY
           
           Source  :  Author

           Related Pending Legislation  :  None Known 

           Prior Legislation  :

          AB 890 (Jones, 2013) would have provided that a product sold in  
          California could carry the label "Made in U.S.A." if it was  
          substantially made, manufactured, or produced in the United  
          States as measured by the following criteria: at least 90  
          percent of the components, parts, articles, or units of the  
          merchandise were manufactured in the United States; United  
          States manufacturing costs constitute at least 90 percent of the  
          total manufacturing costs for the merchandise; and the  
          merchandise was last substantially transformed or assembled in  
          the United States.  This bill failed passage out of the Senate  
          Judiciary Committee on a 2-5 vote.

          AB 858 (Jones, 2012) would have amended California's "Made in  
          U.S.A." law to specify that merchandise has been entirely or  
          substantially made, manufactured, or produced within the United  
          States if the merchandise is a product that is made all or  
          virtually all in the United States, within the meaning of the  
          Enforcement Policy Statement on U.S. Origin Claims issued by the  
          Federal Trade Commission (62 Fed.Reg. 63756 (Dec. 2, 1997)).   
          This bill failed passage out of the Senate Judiciary Committee  
          on a 2-3 vote.

          ABX6 8 (Beall, 2010) which was identical to AB 858, was  
          introduced in the Sixth Extraordinary Session but was never  

                                                                      




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          referred to a policy committee.

          SB 1004 (Holmdahl, Ch. 676, Stats. 1961) codified California's  
          "Made in the U.S.A." law, making it unlawful for any person,  
          firm, corporation, or association to sell or offer for sale any  
          merchandise that advertises itself as being made or manufactured  
          in the United States when any article, unit, or part of the  
          merchandise has been entirely or substantially made,  
          manufactured, or produced outside of the United States.

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