Certificate of Conformance for Country of Origin - Made in the USA claim
- Thread starter DonaldC
- Start date
Methinks that is not a CoC question, but a legal one... best to ask counsel...
Would you care to rephrase?
Under a CoC, any object manufactured in China was manufactured in China.
Without a CoC, any object manufactured in China was manufactured in China.
What is it that you are really asking?
...'cause it seems on first blush that you are asking how to commit fraud legally...
I repeat...would you care to rephrase?
Would you care to rephrase?
Under a CoC, any object manufactured in China was manufactured in China.
Without a CoC, any object manufactured in China was manufactured in China.
What is it that you are really asking?
...'cause it seems on first blush that you are asking how to commit fraud legally...
I repeat...would you care to rephrase?
Ninja, I'm asking because a company that a friend of mine works for is having boards made in China, shipped back to the U.S., repackaged, and then shipped out with documents saying that the boards were manufactured in the U.S. When this was brought to the attention of Management, this individual was reprimanded and written up.
It appears to me that the "friend" mentioned in the first post is not the one who promulgated the phony claim. It sounds to me like the friend was blowing a whistle and got punished for it.
Yep. Depending on the application of these boards, the organization could be on the hook for some serious FTC fines (if consumer products) all the way to ITAR violations, with possible imprisonment, if defense related products. Some serious potential liability there if country of origin is falsified.
For Medical Devices, check Medical device country of origin
The basic question is, is it legal to manufacture government contracted circuit boards in China and then repackaged them in the U.S. and ship them out to the customer with paperwork, C of C, etc., stating that the parts were manufactured in the U.S.?
There are no lawyers here, and an internet forum with no lawyers is a terrible place to ask for legal advice. Have a look at Country of Origin for some guidance.
Interesting discussion. I'm not too familiar with Country of Origin (COO) regulations, but from the wikipedia link Jim posted, it says "a product be manufactured in the U.S. of more than 50 percent U.S. parts to be considered Made in USA". For PCBs, that might be a tough requirement to meet given how many electronic components are manufactured overseas these days...
Also, for the sake of argument/discussion, consider the following hypothetical situation:
Also, for the sake of argument/discussion, consider the following hypothetical situation:
- 50%+ PCB components are manufactured in US
- All components are drop-shipped to China for PCB assembly
- Assembled PCBs are then sent back to US headquarters
- Received PCBs are tested and packaged in the US facility
I've worked in Microelectronics for a while (decades)...though with Hi-Rel stuff, not base PCBs...things 'might' be different between them...depends on the final product.
If we bought 99pct of parts from a US distributor, not knowing the original manufacturer (which might be non-US), and we assembled them...the part was made in the USA. Point being that the last step was done in the USA.
Those who push on supply reliability (those who care about where it was made) tend to be auto or government...and they will specifically ask for defense of where the supply chain goes.
ITAR customers always pushed and pushed and pushed, for good reason...not a good idea for a key component to be sourced from a place you might be fighting with later.
I assumed right up front that there was a purpose (need) for making the claim...and the rest flows from that assumption.
If we bought 99pct of parts from a US distributor, not knowing the original manufacturer (which might be non-US), and we assembled them...the part was made in the USA. Point being that the last step was done in the USA.
Those who push on supply reliability (those who care about where it was made) tend to be auto or government...and they will specifically ask for defense of where the supply chain goes.
ITAR customers always pushed and pushed and pushed, for good reason...not a good idea for a key component to be sourced from a place you might be fighting with later.
I assumed right up front that there was a purpose (need) for making the claim...and the rest flows from that assumption.