U.S. Origin Claims: Made in USA Labels and Substantiation

The assessment considers the claim consumers receive, including words, imagery and context. An unqualified U.S.-origin message can arise without the exact phrase Made in USA. A flag, domestic location or patriotic brand presentation should be reviewed with the surrounding statements, especially when imported content or processing would make the overall impression misleading. FTC business guide.

Part 323 requires final assembly or processing in the United States, all significant processing in the United States, and all or virtually all ingredients or components made and sourced domestically. These are connected conditions. Domestic final assembly alone does not support an unqualified claim when significant foreign components or processing remain. Made in USA regulation.

Origin evidence should connect the finished product with manufacturing locations, significant processing and component sourcing. Supplier assertions need an appropriate factual basis and attention to changes. A U.S. mailing address, domestic warehouse or American-owned company does not show where a product or its components were made. Maintain support for the particular claim being communicated. FTC substantiation guidance.

A qualified statement can describe a limited domestic contribution when the qualification is clear, accurate and supported. Its overall impression must not imply more than the evidence demonstrates. A specific assembly claim also requires support for the relevant U.S. assembly activity. Adding small-print qualification does not necessarily correct a prominent contradictory unqualified message. FTC origin-claim guidance.

The rule extends to specified mail-order promotional material, including electronic material within its definition. Other deceptive-origin advertising remains subject to the FTC Act. Customs marking and procurement-origin rules have their own tests. A determination under one of those frameworks should not be presented as automatic satisfaction of the FTC consumer-claim standard. Part 323 scope.

Identify every origin statement and implied message, map the manufacturing and sourcing evidence, and select an appropriately supported claim. Reassess when components or production locations change. FTC does not provide a general Made in USA certification for businesses to display. Rule compliance concerns the actual claim and product, not membership in a domestic-manufacturing promotion program. FTC rule resource.