Electric Mirror LED Mirrors
November 24th, 2021
During our review, we discussed concerns that 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.
The agency continued:
As discussed, it is appropriate for Electric Mirror to promote the fact that it employs workers and performs certain functions in the United States, and to state that the Company takes pride in its U.S. operations. However, 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.
The FTC told the company based on these actions and other factors, it decided not to pursue the investigation any further.
Electric Mirror is among the first companies to receive a closing letter from the FTC regarding U.S.-origin claims since the agency’s Made in USA Labeling Rule went into effect in August, a direct result of a TINA.org petition for rulemaking filed in 2019. The letter notes that the rule allows the FTC to seek civil penalties of up to $42,792 per violation of the rule.
Find more of our coverage on made in the USA claims here.