UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
WASHINGTON, D.C. 20580

October 1, 1998

Mr. Al Dixon
President
H&L Products, Inc.
500 W. 16 Street
National City, CA 91950

Re: H&L Products, Inc. - File Number 982 3593

Dear Mr. Dixon:

The Division of Enforcement staff has conducted an investigation of H&L Products, Inc. ("H&L") to determine whether H&L has violated the Federal Trade Commission's "all or virtually all" standard for domestic country of origin claims and Section 5 of the Federal Trade Commission Act.

Staff received a complaint that the package for a Royal Traveller (by Samsonite) Universal Cellular & PCS Phone Case included a prominent "Made in America" logo on the front panel of the package and a "Made in U.S.A." claim on the rear panel. According to the complaint, the product itself, however, carried a label stating it was "Made in China." Your company informed us that, as of April 1, 1998, H&L stopped manufacturing goods in its San Diego plant and began production in a China mainland factory. H&L changed all packaging to indicate the products were "Made in China" and destroyed remaining previous packaging. In changing over 75 items to "Made in China" labels, H&L apparently incorrectly identified this item and shipped 200-300 units with the wrong packaging. H&L has assured us that it labels all its products with the correct country of origin, and that it will take additional steps to ensure the proper labeling of all its products in the future.

Staff, therefore, has concluded that no further action is indicated at this time. This action is not to be construed as a determination that a violation may not have occurred, just as the pendency of an investigation should not be construed as a determination that a violation has occurred. The Commission reserves the right to take such further action as the public interest may require.

Sincerely,

Elaine D. Kolish
Associate Director