On the Origin of Species: An in-depth look at how American, British and Swiss watches claim origin
Here we have three watches, a Zenith Captain Dual Time (My Own), a Niall Panda GMT and a Bremont Boeing 100 GMT and inside each of these watches is a Swiss movement however they all claim to be from different countries: Switzerland, America and Great Britain.
I've started work on an in-depth look at the state of American watchmaking so today I just wanted to compare and contrast the laws and regulations of these three countries and how they impact the watchmaking and advertising of brands based in them.
If we look at the dials of these watches, we'll see that the Bremont and Zenith both have a designation of origin at six o'clock whereas the Nial has a blank space. Currently there are no laws in any of these countries forcing watch manufacturers to state where their products came from however if a claim is made, there are regulations that govern what they can and can't say without proof.
The term 'Made in USA' or any derivatives like 'Manufactured/Built/Assembled in America' is regulated by the Federal Trade Commission (FTC) whose standard for the term requires that 'All or virtually all' of the product must be made in the USA. Any significant parts of processing should be of American origin and there should be no, or a negligible amount of, foreign content within a production.
In comparison, Switzerland's 'Swiss Made' or any derivatives are controlled by the Swiss Federal Council (SFC) and surprisingly their regulations are far more forgiving despite the prestige associated with the 'Swiss Made' name. The SFC define a Swiss watch as having a Swiss movement (that was assembled and inspected by the manufacturer in SWitzerland), a Swiss case (It must have undergone at least one essential manufacturing option in Switzerland like stamping, turning or polishing) and that the final product inspection of the piece occurs in Switzerland. Only 50% of the value of a product has to be of Swiss origin for it to be qualified as such.
Conversely the use of 'Made in USA' is subject to far tighter control by the FTC who seem to be more concerned with protecting the consumer from misleading adverts whilst the SFC seem to focus on maintaining the highest level of internal manufacture as possible as long as the 50% minimum is met.
There are two types of geographic claims that the FTC recognize, qualified and unqualified. A qualified claim is one that describes the amount of a product's domestic content, '60% US Materials' or 'Designed in California. Made in China' and these qualified claims give the consumer enough knowledge to aquaquality judge the origin of the product. An unqualified claim is one far more generic, 'Made in America' or 'Built in USA' and these claims could, if used incorrectly, mislead the consumer as to the origin of the product. The FTC even takes into account implicit claims like the use of flags, maps, city names or even state outlines as making an unqualified claim.
It is clear that the continued production of watches in Switzerland has affected their regulations as the SFC guidelines only affect timepieces whilst the FTC's 'Made in America' regulations affect all products as there was no need for regulation on an almost non-existent American watch industry.
Great Britain takes a different approach as regulations limiting the use of 'Made in Great Britain' are quite lax.
The British watchmaking industry hasn't existed in any great capacity for over one hundred years so there has been no need for regulation on geographic claims for watches. Any regulations that do exist are limited to food and drink such as Plymouth Gin or Melton Mowbray Pork Pies which have to be produced in those cities to quality for use of that name (I can't recommend pairing those two together but I heartily endorse indulging in them individually).
Whilst any blatantly false claims of origin will fall under the jurisdiction of the British Advertising Standards Agency, there is a substantial amount of wiggle room for brands to make claims with. Bremont currently sign their dials with 'London' even though their facilities in Silverstone and Henley-on-Thames are far beyond the outer limits of that city. There is no engraving on the caseback regarding the origin of the Bremont Boeing 100 though the movement itself has a small engraving at 8 o'clock stating the origin as Swiss.
Bremont's ultimate, and admirable, goal is to design and manufacture a production movement on British shores but when that day comes, will there be some industry oversight with regards to the designation of origin of those watches or a dictated level of transparency? Who would run such a program?
The chances of the British Government being organised enough to oversee claims is laughable however the alternative of having the only company making British watches at scale be the arbiter of defining a British watch is potentially troublesome. Roger Smith's almost puritanical view of English watchmaking would give any watch branded with a Smith decreed 'Made in Great Britain' real creedence but setting an impossibly high standard for a fledgling industry is incredibly impractical for growth
This is exactly what is happening in America right now
America no longer has easy access to skilled labor and watchmaking equipment making it truly difficult to meet the FTC's guidelines as the inclusion of a foreign movement, the most crucial part of a watch, automatically disqualifies brands from using unqualified claims. Niall now use the qualified claims of 'USA Made. Swiss Mvmt' on their case back but that transparency might dissuade consumers looking for a true star spangled watch. Currently the only American watchmakers who make 'real American' movements are similar to Roger W. Smith, they produce movements of immeasurable quality at an immeasurably low frequency.
When a watch is nothing without its movement, how is an American based company supposed to make watches at any kind of scale without using a foreign movement. Qualified claims like Niall's just don't have the same appeal as the straight talkin', true-blue 'Made in USA' claim does. Without access to support of a large market, how can the recovering American watch industry grow from serving a few select and patient clients to the masses whilst still respecting the consumer's right for an honestly advertised product?
Does the future of American mechanical watchmaking have to start with designing and building of an American quartz movement?
The future of lower end Swiss watches might also be changing as well as on January 1st, 2017, the SFC will be increasingly the minimum value of Swiss components in a watch from 50% to 60%. Currently brands are able to maneuver around the 50% limit by buying as more cheap components from Asia which are balanced out by more expensive Swiss components like the balance wheel and mainspring which inflate the percentage of value in favor of Swiss. A 10% increase is hardly restrictive however and companies willing to stretch that profit margin will continue to find ways to do so but it's a start at least.
I'd be interested to know what other watch fans and collectors think about all this? Does the name Swiss Made really mean that much to you? Does it mean less when compared against more stringent regulations? Does where a watch come from ultimately mean that much? Let me know in the comments below.
- FHS: Ordiance Governing the Use of the Appellation 'Switzerland" or "Swiss" for watches
- FHS: THe New Requirements Stipulated by Swissness
- FHS: The Criteria for Strengthening the Swiss Made Label
- Flat Land KC: Watch Words
- FTC: Complying with the Made in USA Standard
- FTC: Niall Letter, 20th November, 2015
- Hamlins: Made in Britain, The Pitfalls of Patriotic Marketing Claims
- Hodinkee: The Federal Trade Commission Takes Action Against Deceptive Marketing Practices in the American Watchmaking Industry
- Hodinkee: Four Fascinating American Watchmaking Films
- Hodinkee: Smoke and Mirrors in the American Watchmaking Industry
- Medium: A Defining Moment in Our Industry
- Wipo: United Kingdom Trade Descriptions Act 1968, Chapter 29
- Wrist Review: Interview with the CEO and Co-Founder of Niall Watches, Michael Wilson