Made in the USA by Parallax

The Federal Trade Commission (FTC) publishes guidelines for marketers who wish to label products with "Made in the USA". As an active manufacturer in California, we researched the FTC's policy with a goal of applying it to Parallax's products. In order to apply this to Parallax, it's important to understand the role of our manufacturing process for products we will label "Made in the USA" and to understand our interpretation of the FTC's policy. Below I've explained what we're doing and how their policy applies.
 
Parallax's Goals Pertaining to Manufacturing
 
First, we would like to explain Parallax's objectives related to manufacturing (and engineering, to some extent). Our goals are that we keep our core products and knowledge in Rocklin, that we are able to quickly turn a prototype into production, and that we consider the most appropriate manufacturing process concurrent with the product's design. With such goals we must be able to build what we design.  
 
Our internal abilities include SMT pick and place, reflow, prototype PCB routing, CNC machining, semiconductor diagnosis (focused ion beam and e-beam probe equipment), hand-assembly of prototypes, chip-shooting/programming, and kitting of our finished goods. We currently have the most active manufacturing staff and abilities in our company's 20+ year history. We've recently replaced most of our manufacturing equipment in 2008 and our manufacturing staff actively cross-trains. See the photos below as an example.

(a) Sue, Pick and Place Operator is loading the machine to build some products.	(b) Natalia, Manufacturing Technician, saws apart assembled BASIC Stamp boards.	(c) Rich, Manufacturing Manager, prepares the focused ion beam machine for the arrival of the next test chip.
(d) Mark, Kitting Lead, and Matt, Kitting, building Boe-Bot kits in their new shop.	(e) Matt, Machinist, and Kevin, Electronic  Engineer, in front of the Haas Super Mini Mill while it runs motor mounts.	(f) Russ, Manufacturing Technician, places legs on our BASIC Stamp boards.

Though you can see that we're building our core products in Rocklin, our customers also need to know that it's nearly impossible to source everything in the USA and that we must rely on external sources to run our business. For example, manufacturing processes we don't offer internally include through-hole electronic assembly with wave soldering, metal stamping, plastic molding, and semiconductor die packaging. Further, many raw materials and components are simply not available from domestically-manufactured sources. Ever try to locate a bearing or passive electronic component made in the USA?
 
In order to use overseas sources efficiently, we also operate a company in China. This allows us to access the component markets and to build specific products at a much lower cost. We are able to control our QA/QC this way and be certain that our test procedures are properly applied. We view our manufacturing operations in China as a very important component of our company, and we aim to continue to improve our capabilities overseas.
 
Finally, and perhaps not directly related to claiming "Made in the USA", it's our opinion that this country's ability to perform in a global marketplace must be determined by American companies. Politicians shouldn't tell us how things will work trade-wise. Markets (both in terms of supply and sourcing) are now globally accessible and neglecting this premise is sure cause for failure when a business grows to a certain level. Government shouldn't be relied upon to support our business or bail us out. To this end, we need to be responsible for our own future and make decisions that ensure a basic level of self-reliance.
 
The Federal Trade Commission Guidelines
 
The Federal Trade Commission (FTC) has offered guidelines for complying with the Made in the USA Standard. Making an unqualified claim of Made in the USA means that all of the product (labor, raw materials, components) is made in the USA. For Parallax this claim is nearly impossible to make since electronic components come from Asia; however, the FTC's alternative - a "qualified Made in the USA claim" - may be applied to specific Parallax products which have undergone a substantial transformation from their raw material to the finished good.
 
A qualified claim is accompanied with an explanation. For example, a product may be "Assembled in the USA from domestic and foreign-supplied components" or it may involve a significant amount of labor to transform it from the component level to a finished good. There's no clear threshold to help a company determine when to make a qualified claim about being "Made in the USA". The most clear interpretations seem to relate to products made of fur, textiles, and automobiles. And we're not in that kind of business.
 
Read the FTC Guidelines if you are interested.
 
Parallax's "Made in the USA" Sticker 

Parallax will now label specific products with our "Made in the USA" sticker when the following conditions are met:

• the core of the product has undergone a substantial transformation from raw materials to the finished good and;
• the cost of our labor (manufacturing and overhead) in relation to the total product's cost exceeds 75%; and
• we have qualified [documented] the claim the product's "store" page.

Since the variety of qualifications would require an assortment of stickers exhibiting different conditions, we've opted to use a single sticker and to direct our customers to the product's web page for detailed explanation. The product's web page will explain why we've applied this sticker to a particular product.
 
Please feel to contact me directly if any of this is of further interest to you or your company.
 
Ken Gracey
Parallax, Inc.