Analysis of Proposed Consent Order to Aid Public Comment 

In the Matter of Chaucer Accessories, Inc., Bates Accessories, Inc., Bates Retail Group, Inc., 

and Thomas P. Bates, individually and as an officer of Chaucer Accessories, Inc., Bates 

Accessories, Inc., and Bates Retail Group, Inc. 

File No. 2223163 

The Federal Trade Commission (“FTC” or “Commission”) has accepted, subject to final 

approval, an agreement containing a consent order from Chaucer Accessories, Inc., Bates 

Accessories, Inc., Bates Retail Group, Inc., and Thomas P. Bates (“Respondents”). 

The proposed consent order has been placed on the public record for thirty (30) days for 

receipt of comments by interested persons. Comments received during this period will become 

part of the public record. After thirty (30) days, the Commission will again review the 

agreement and the comments received and decide whether it should withdraw from the 

agreement or make final the agreement’s proposed order. 

This matter involves Respondents’ labeling and advertising of belts, shoes, and other 

products as “Made in USA” or “Made in USA from Global Materials.” According to the FTC’s 

complaint, Respondents (1) advertised certain products as made in the United States even 

though, in numerous instances, they were wholly imported or incorporated significant imported 

components, and (2) labeled and advertised certain other products as “Made in USA from Global 

Materials” even though, in numerous instances, those products were wholly imported with de 

minimis finishing in the United States. The FTC’s complaint also alleges that, by distributing 

promotional materials containing misrepresentations regarding the origin of their products, 

Respondents provided trade customers the means and instrumentalities for the commission of 

deceptive act or practices. Based on the foregoing, the complaint alleges Respondents violated 

Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45(a). 

The proposed consent order contains provisions designed to prevent Respondents from 

engaging in similar acts and practices in the future. Consistent with the FTC’s Made in USA 

Labeling Rule, 16 C.F.R. Part 323, and its Enforcement Policy Statement on U.S.-Origin Claims, 

Part I prohibits Respondents from making U.S.-origin claims for their products unless: (1) the 

final assembly or processing of the product occurs in the United States, all significant processing 

that goes into the product occurs in the United States, and all or virtually all ingredients or 

components of the product are made and sourced in the United States; (2) a clear and 

conspicuous qualification appears immediately adjacent to the representation that accurately 

conveys the extent to which the product contains foreign parts, ingredients or components, 

and/or processing; or (3) for a claim that a product is assembled in the United States, the product 

is last substantially transformed in the United States, the product’s principal assembly takes place 

in the United States, and United States assembly operations are substantial. 

Part II prohibits Respondents from making any representation about the country of origin 

of a product or service, unless the representation is not misleading and Respondents have a 

reasonable basis substantiating it. 

Page 1 of 2 
 

 

 

 

 

 

 

 

 

 

 

 

 

Part III prohibits Respondents from providing others with the means and instrumentalities 

to make the claims prohibited in Parts I or II. 

Parts IV through V are monetary provisions. Part IV imposes a judgment of $191,481. 

Part V includes additional monetary provisions relating to collections. Part VI requires 

Respondents to provide sufficient customer information to enable the Commission to administer 

consumer redress, if appropriate. 

Part VII is a notice provision requiring Respondents to identify and notify certain 

consumers of the FTC’s action within 30 days after the issuance of the order, or within 30 days 

of the consumer’s identification, if identified later. Respondents are also required to submit 

reports regarding their notification program. 

Parts VIII through IX are reporting and compliance provisions. Part VIII requires 

Respondents to acknowledge receipt of the order, to provide a copy of the order to certain 

current and future principals, officers, directors, and employees, and to obtain an 

acknowledgement from each such person that they have received a copy of the order. Part IX 

requires Respondents to file a compliance report within one year after the order becomes final 

and to notify the Commission within 14 days of certain changes that would affect compliance 

with the order. Part X requires Respondents to maintain certain records, including records 

necessary to demonstrate compliance with the order. Part XI requires Respondents to submit 

additional compliance reports when requested by the Commission and to permit the Commission 

or its representatives to interview Respondents’ personnel. 

Finally, Part XII is a “sunset” provision, terminating the order after twenty (20) years, 

with certain exceptions. 

The purpose of this analysis is to aid public comment on the proposed order. It is not 

intended to constitute an official interpretation of the complaint or proposed order, or to modify 

in any way the proposed order’s terms. 

Page 2 of 2