November Bicycles, what's the story?
#26
Senior Member
Italian statement of origin laws are somewhat famously more liberal. "In the U.S., there are some laws covering this. The “last substantial transformation” of a product must happen in the country of origin. Guillermo Jimenez of the Fashion Institute of Technology in New York says that phrase can be stretched pretty far."
The carbon used is Japanese, the resin system is formulated in Italy, and we have absolutely no idea where the paint is made.
The letter of the relevant law is satisfied with the statement that the frames are made in Italy. If your personal interpretation is that "the last substantial transformation" in these frames is the making of the carbon fiber rather than people who are either Italian or able to work in an Italian company, in Italy, mating Japanese carbon with an Italian resin system, and forming and curing that into tubes, which are then cut and assembled into frames and painted is that they aren't made in Italy, so be it. We won't argue.
The carbon used is Japanese, the resin system is formulated in Italy, and we have absolutely no idea where the paint is made.
The letter of the relevant law is satisfied with the statement that the frames are made in Italy. If your personal interpretation is that "the last substantial transformation" in these frames is the making of the carbon fiber rather than people who are either Italian or able to work in an Italian company, in Italy, mating Japanese carbon with an Italian resin system, and forming and curing that into tubes, which are then cut and assembled into frames and painted is that they aren't made in Italy, so be it. We won't argue.
#27
Senior Member
Join Date: Jun 2013
Location: NYC, duh Bronx.
Posts: 3,578
Bikes: Salsa Ti Warbird- 2014/ November RAIL52s
Mentioned: 9 Post(s)
Tagged: 0 Thread(s)
Quoted: 67 Post(s)
Likes: 0
Liked 1 Time
in
1 Post
Italian statement of origin laws are somewhat famously more liberal. "In the U.S., there are some laws covering this. The “last substantial transformation” of a product must happen in the country of origin. Guillermo Jimenez of the Fashion Institute of Technology in New York says that phrase can be stretched pretty far."
The carbon used is Japanese, the resin system is formulated in Italy, and we have absolutely no idea where the paint is made.
The letter of the relevant law is satisfied with the statement that the frames are made in Italy. If your personal interpretation is that "the last substantial transformation" in these frames is the making of the carbon fiber rather than people who are either Italian or able to work in an Italian company, in Italy, mating Japanese carbon with an Italian resin system, and forming and curing that into tubes, which are then cut and assembled into frames and painted is that they aren't made in Italy, so be it. We won't argue.
The carbon used is Japanese, the resin system is formulated in Italy, and we have absolutely no idea where the paint is made.
The letter of the relevant law is satisfied with the statement that the frames are made in Italy. If your personal interpretation is that "the last substantial transformation" in these frames is the making of the carbon fiber rather than people who are either Italian or able to work in an Italian company, in Italy, mating Japanese carbon with an Italian resin system, and forming and curing that into tubes, which are then cut and assembled into frames and painted is that they aren't made in Italy, so be it. We won't argue.
#28
Senior Member
Join Date: Jun 2013
Location: NYC, duh Bronx.
Posts: 3,578
Bikes: Salsa Ti Warbird- 2014/ November RAIL52s
Mentioned: 9 Post(s)
Tagged: 0 Thread(s)
Quoted: 67 Post(s)
Likes: 0
Liked 1 Time
in
1 Post
Likewise, if the base (PAN) for producing the carbon fiber was sourced from a foreign country, a 'Made in XXX' is appropriate. If that plastic radio case was molded using foreign-sourced resin, the unqualified 'Made in XXX' is deceptive. At least that's my interpretation using the gold ring example.
The plastic case was molded in the USA using imported petrol, the components fabricated in the USA, therefore "Made in USA"
The carbon fiber, akin to the petrol, is fabricated, akin to "molding," by Italians, into components, tubes, further fabricated into frames, in Italy, therefore "Made in Italy."
Awfully straightforward, unless only witches float.
#29
Senior Member
Huh?
The plastic case was molded in the USA using imported petrol, the components fabricated in the USA, therefore "Made in USA"
The carbon fiber, akin to the petrol, is fabricated, akin to "molding," by Italians, into components, tubes, further fabricated into frames, in Italy, therefore "Made in Italy."
Awfully straightforward, unless only witches float.
The plastic case was molded in the USA using imported petrol, the components fabricated in the USA, therefore "Made in USA"
The carbon fiber, akin to the petrol, is fabricated, akin to "molding," by Italians, into components, tubes, further fabricated into frames, in Italy, therefore "Made in Italy."
Awfully straightforward, unless only witches float.
Transforming petroleum to plastic is quite significant. The link didn't discuss foreign plastic itself so I can't say how that situation would be dealt with, assuming the plastic was insignificant. Transforming PAN to carbon fiber is likewise significant, though. Melting plastic and injecting it into a mold, much less so, and likewise, molding carbon fiber tubes (not say that any of those are easy, just more so than the first step).
#30
Senior Member
Some pointless ****e being argued here, I must say.
#31
Senior Member
#32
I'm doing it wrong.
Join Date: Jun 2009
Posts: 4,875
Bikes: Rivendell Appaloosa, Rivendell Frank Jones Sr., Trek Fuel EX9, Kona Jake the Snake CR, Niner Sir9
Mentioned: 85 Post(s)
Tagged: 0 Thread(s)
Quoted: 9660 Post(s)
Liked 2,784 Times
in
1,643 Posts
The letter of the relevant law is satisfied with the statement that the frames are made in Italy. If your personal interpretation is that "the last substantial transformation" in these frames is the making of the carbon fiber rather than people who are either Italian or able to work in an Italian company, in Italy, mating Japanese carbon with an Italian resin system, and forming and curing that into tubes, which are then cut and assembled into frames and painted is that they aren't made in Italy, so be it. We won't argue.
I highly suspect that that isn't the case.
But, I think November Dave is being pretty clear.
#33
Senior Member
#34
Senior Member
Mined, perhaps not. Smelted and formed, I'd say yes per the FTC website. A gold ring made of gold mined in a foreign country isn't considered 'Made in XXX' (without qualification) after all.
#35
Senior Member
Join Date: Jun 2013
Location: NYC, duh Bronx.
Posts: 3,578
Bikes: Salsa Ti Warbird- 2014/ November RAIL52s
Mentioned: 9 Post(s)
Tagged: 0 Thread(s)
Quoted: 67 Post(s)
Likes: 0
Liked 1 Time
in
1 Post
I apologize for the late edit to my post but I added a qualifier of the plastic being referenced in the radio's marketing material. In most cases, a plastic radio's marketing material would make zero mention of the plastic resin and as such the plastic, regardless of its source, can be considered insignificant. Now, if the plastic was referenced, that would make it significant and then the interpretation of the rules becomes more tricky. This is the situation that I believe November is in with its Japanese sourced carbon fiber.
Transforming petroleum to plastic is quite significant. Transforming PAN to carbon fiber likewise. Melting plastic and injecting it into a mold, much less so, and likewise, molding carbon fiber tubes (not say that any of those are easy, just more so than the first step).
Transforming petroleum to plastic is quite significant. Transforming PAN to carbon fiber likewise. Melting plastic and injecting it into a mold, much less so, and likewise, molding carbon fiber tubes (not say that any of those are easy, just more so than the first step).
"That’s because of the significant value the gold is likely to represent relative to the finished product, and because the gold — an integral component — is only one step back from the finished article."
I doubt that the raw carbon from Japan is significant in material cost relative to the labor cost, the valuation of the "many steps" removed from the raw material, required to fabricate the frames in question.
Besides, this has been hashed out by far smarter people than me... and trade agreements made accordingly.
#36
I'm doing it wrong.
Join Date: Jun 2009
Posts: 4,875
Bikes: Rivendell Appaloosa, Rivendell Frank Jones Sr., Trek Fuel EX9, Kona Jake the Snake CR, Niner Sir9
Mentioned: 85 Post(s)
Tagged: 0 Thread(s)
Quoted: 9660 Post(s)
Liked 2,784 Times
in
1,643 Posts
I think your strict interpretation of the FTC website is faulty when it comes to bikes. The gold ring is not really a direct comparison to a bike, being that the carbon sheets that will be used to form the bicycle frame are more steps removed from the finished product. A gold ring is all about the gold...where a bike is not all about the specific carbon. Just like with steel bikes, plenty of which are called "made in the USA" from steel tubes manufactured outside of the USA.
#37
Senior Member
Again from the link:
"That’s because of the significant value the gold is likely to represent relative to the finished product, and because the gold — an integral component — is only one step back from the finished article."
I doubt that the raw carbon from Japan is significant in material cost relative to the labor cost, the valuation of the "many steps" removed from the raw material, required to fabricate the frames in question.
Besides, this has been hashed out by far smarter people than me... and trade agreements made accordingly.
"That’s because of the significant value the gold is likely to represent relative to the finished product, and because the gold — an integral component — is only one step back from the finished article."
I doubt that the raw carbon from Japan is significant in material cost relative to the labor cost, the valuation of the "many steps" removed from the raw material, required to fabricate the frames in question.
Besides, this has been hashed out by far smarter people than me... and trade agreements made accordingly.
Originally Posted by FTC
How far back in the manufacturing process should manufacturers and marketers look?
To determine the percentage of U.S. content, manufacturers and marketers should look back far enough in the manufacturing process to be reasonably sure that any significant foreign content has been included in their assessment of foreign costs. Foreign content incorporated early in the manufacturing process often will be less significant to consumers than content that is a direct part of the finished product or the parts or components produced by the immediate supplier.
Example: The steel used to make a single component of a complex product (for example, the steel used in the case of a computer’s floppy drive) is an early input into the computer’s manufacture, and is likely to constitute a very small portion of the final product’s total cost. On the other hand, the steel in a product like a pipe or a wrench is a direct and significant input. Whether the steel in a pipe or wrench is imported would be a significant factor in evaluating whether the finished product is "all or virtually all" made in the U.S.
To determine the percentage of U.S. content, manufacturers and marketers should look back far enough in the manufacturing process to be reasonably sure that any significant foreign content has been included in their assessment of foreign costs. Foreign content incorporated early in the manufacturing process often will be less significant to consumers than content that is a direct part of the finished product or the parts or components produced by the immediate supplier.
Example: The steel used to make a single component of a complex product (for example, the steel used in the case of a computer’s floppy drive) is an early input into the computer’s manufacture, and is likely to constitute a very small portion of the final product’s total cost. On the other hand, the steel in a product like a pipe or a wrench is a direct and significant input. Whether the steel in a pipe or wrench is imported would be a significant factor in evaluating whether the finished product is "all or virtually all" made in the U.S.
#38
Senior Member
I think your strict interpretation of the FTC website is faulty when it comes to bikes. The gold ring is not really a direct comparison to a bike, being that the carbon sheets that will be used to form the bicycle frame are more steps removed from the finished product. A gold ring is all about the gold...where a bike is not all about the specific carbon. Just like with steel bikes, plenty of which are called "made in the USA" from steel tubes manufactured outside of the USA.
Which 'Made in USA' steel bikes used foreign sourced steel tubes?
#39
I'm doing it wrong.
Join Date: Jun 2009
Posts: 4,875
Bikes: Rivendell Appaloosa, Rivendell Frank Jones Sr., Trek Fuel EX9, Kona Jake the Snake CR, Niner Sir9
Mentioned: 85 Post(s)
Tagged: 0 Thread(s)
Quoted: 9660 Post(s)
Liked 2,784 Times
in
1,643 Posts
Mine.
#41
Senior Member
#43
Senior Member
Interesting. I'd like to see how Rivendell presented its case to the FTC (or how they would). It could change my opinion on the subject if the FTC clearly ruled that taking tubes and making them into a bike frame constituted a substantial transformation and that the steel tube origin is insignificant enough to not matter to the final product.
#44
Senior Member
#46
Senior Member
Similar rules likely apply, though their interpretation in the courts may be wildly different as the November rep has alluded to. If I could read Italian perhaps I could make a more informed statement.
#47
I'm doing it wrong.
Join Date: Jun 2009
Posts: 4,875
Bikes: Rivendell Appaloosa, Rivendell Frank Jones Sr., Trek Fuel EX9, Kona Jake the Snake CR, Niner Sir9
Mentioned: 85 Post(s)
Tagged: 0 Thread(s)
Quoted: 9660 Post(s)
Liked 2,784 Times
in
1,643 Posts
Isn't Columbus tubing "made in Italy?"
#48
Senior Member
Join Date: Jun 2013
Location: NYC, duh Bronx.
Posts: 3,578
Bikes: Salsa Ti Warbird- 2014/ November RAIL52s
Mentioned: 9 Post(s)
Tagged: 0 Thread(s)
Quoted: 67 Post(s)
Likes: 0
Liked 1 Time
in
1 Post
Nevertheless, November is in compliance with the law. Japanese Toray fiber is used in Parlee Bicycles as well, and the full custom line is "Made in USA."
#49
Senior Member
Just so we're all clear on this, I'm perfectly satisfied with November's admission that their frames are Made in Italy using Japanese carbon fiber. They look sweet and would get my attention if I was currently in the market.
#50
Senior Member
Again, I'd like to see how Parlee presented its case to the FTC (or how they would). It could change my opinion on the subject if the FTC clearly ruled that taking carbon fiber and making it into a bike frame constituted a substantial transformation and that the carbon fiber origin is insignificant enough to not matter to the final product (paraphrased from my post about Rivendell).