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November Bicycles, what's the story?

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November Bicycles, what's the story?

Old 12-08-15, 12:02 PM
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Originally Posted by November Dave
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.
How important are those carbon fibers to your product?
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Old 12-08-15, 12:02 PM
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Originally Posted by November Dave
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.
If Little Old Ladies in Italy made tomato sauce with Japanese tomatoes...it would be Italian, and they'd chase you out of town wielding wooden spoons if you said otherwise.
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Old 12-08-15, 12:08 PM
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Originally Posted by joejack951
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.
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.
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Old 12-08-15, 12:14 PM
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Originally Posted by UnfilteredDregs
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.
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. 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).
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Old 12-08-15, 12:18 PM
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Some pointless ****e being argued here, I must say.
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Old 12-08-15, 12:19 PM
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Originally Posted by dr_lha
Some pointless ****e being argued here, I must say.
Oh, sorry. I thought this was the pointless **** arguing forum. I got confused by reading other threads on the front page
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Old 12-08-15, 12:19 PM
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Originally Posted by joejack951
How important are those carbon fibers to your product?
Originally Posted by November Dave
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.
Does a steel bicycle have to have tubes that were from materials mined, smelted, and formed in the USA to be "made in the USA?"
I highly suspect that that isn't the case.


But, I think November Dave is being pretty clear.
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Old 12-08-15, 12:20 PM
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Originally Posted by joejack951
Oh, sorry. I thought this was the pointless **** arguing forum. I got confused by reading other threads on the front page
Don't get me wrong, this is classic 41 stuff!
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Old 12-08-15, 12:22 PM
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Originally Posted by RJM
Does a steel bicycle have to have tubes that were from materials mined, smelted, and formed in the USA to be "made in the USA?"
I highly suspect that that isn't the case.
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.
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Old 12-08-15, 12:24 PM
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Originally Posted by joejack951
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).
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.
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Old 12-08-15, 12:28 PM
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Originally Posted by joejack951
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.
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.
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Old 12-08-15, 12:32 PM
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Originally Posted by UnfilteredDregs
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.
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.
The carbon fiber used in a November bicycle falls somewhere in between these two examples. I'd argue that the carbon fiber in a carbon fiber bicycle frame is way more significant than the steel used in a floppy drive. It's likely pretty close to how important the steel used for a wrench is, keeping in mind that steel for a wrench gets extruded, forged, machined, polished, and plated before it is a wrench.
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Old 12-08-15, 12:34 PM
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Originally Posted by RJM
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.
Ok, so add a diamond, or twenty to that ring. How does that affect the interpretation? I honestly can't say 100% but given some of the minutiae argued on the FTC website, I'd be hard pressed to believe that the gold would now be ignored.

Which 'Made in USA' steel bikes used foreign sourced steel tubes?
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Old 12-08-15, 12:38 PM
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Mine.
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Old 12-08-15, 12:39 PM
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Originally Posted by joejack951
Which 'Made in USA' steel bikes used foreign sourced steel tubes?
Are any steel tubes used in bicycle frames made in the US?
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Old 12-08-15, 12:43 PM
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Originally Posted by njkayaker
Are any steel tubes used in bicycle frames made in the US?
Gunnars are made of True Temper tubing, which is "Made in the USA".
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Old 12-08-15, 12:48 PM
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Originally Posted by joejack951
The carbon fiber used in a November bicycle falls somewhere in between these two examples.
Examples that only apply to a "Made in USA" product.

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Old 12-08-15, 12:49 PM
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Originally Posted by RJM
Mine.
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.
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Old 12-08-15, 12:50 PM
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Originally Posted by UnfilteredDregs
Examples that only apply to a "Made in USA" product.

'Between' was a poor word choice.
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Old 12-08-15, 12:51 PM
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Originally Posted by joejack951
'Between' was a poor word choice.
Well, FTC rules for "Made in USA" simply don't apply to "Made in Italy." Agreed?
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Old 12-08-15, 12:56 PM
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Originally Posted by UnfilteredDregs
Well, FTC rules for "Made in USA" simply don't apply to "Made in Italy." Agreed?
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.
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Old 12-08-15, 12:56 PM
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Isn't Columbus tubing "made in Italy?"
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Old 12-08-15, 12:58 PM
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Originally Posted by joejack951
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.
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."
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Old 12-08-15, 01:00 PM
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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.
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Old 12-08-15, 01:01 PM
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Originally Posted by UnfilteredDregs
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."
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).
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