Disclose to WHO? There is a difference between disclosure to the government and disclosure to consumers. If it isn’t required, and it isn’t illegal, why would someone argue it is?
A fun little exercise: Try asking a major corporation who their suppliers are for raw material and see how far you get. If someone outside the company called me and asked “hey where do you get your resin and copper?” I’d slam the phone down.
There is no entitlement to disclose COO to consumers. Absolutely nada. If you want to make “made in America” an issue legally, you’d better be able to prove:
Hoback said, in writing, that a knife made outside of the US was “made in the USA”.