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A U.S. shop is not the whole manufacturing history
The FTC rule requires all three conditions: final assembly or processing in the United States, all significant processing there, and all or virtually all components or ingredients made and sourced there. Its defined unqualified representations include more than the exact words Made in USA.
The FTC’s staff guidance considers the overall impression and the importance, cost and closeness of foreign content to the finished product. A small cost percentage alone does not make an essential foreign component negligible. An American brand name or a modestly displayed U.S. address alone is not automatically an origin claim.
A narrower statement still needs support
Fictional example: a service brand assembles a floor machine in a U.S. shop using an imported motor, battery and housing. Showing only the assembly address does not establish the three-part unqualified standard. This example decides no real product’s origin or permitted wording.
A qualified claim must truthfully describe the actual domestic work and foreign content without implying more U.S. content than exists. Even Assembled in USA is not an automatic replacement: the staff guidance requires substantial principal assembly in America and the product’s last substantial transformation there. Simple screwdriver assembly may not meet that standard.
A real historical example: broad claims across a product line
The FTC’s 2020 Williams-Sonoma complaint alleged that broad U.S.-origin claims covered product categories that included wholly imported goods or significant imported content. The July 2020 final consent order separately addressed unqualified claims, accurate adjacent qualifications and assembly claims. The company neither admitted nor denied the allegations apart from jurisdictional facts.
That historical order is not a trial finding or an approval of a replacement label. Its practical relevance is the mismatch between a broad marketing statement and the sourcing evidence for the actual products. No later enforcement or collection outcome is established here.
Customs marking and advertising are different questions
The labelling rule covers product labels and specified seals, marks, tags or stamps in mail-order materials, including electronic materials. The wider FTC advertising guidance is a distinct source, not an extension of every label provision to every advertisement.
A Customs marking result or a government-procurement domestic-content test does not by itself establish the consumer-facing FTC claim. Check the actual message and evidence when suppliers or production steps change.
Scope
- No label, origin, assembly, procurement or percentage finding is made. Special product-label laws, Customs requirements and state protections remain separate. The case discussion is limited to the fully read 2020 complaint and final consent order.
Next step
Compare the exact product claim with the real components and processing before printing the label or repeating it online.
Sources & review notes
Federal Trade Commission
Passage, dates and research notes
primary · Complete §§323.1–323.6
all or virtually all ingredients or components
Read complete unqualified claim definition, three-part label standard, mail-order seal/mark scope, enforcement and other-law/exemption provisions. No automatic substantial-transformation-to-advertising equivalence or percentage safe harbour.
Federal Trade Commission staff
Passage, dates and research notes
official-guidance · Basic claims, unqualified/qualified/process claims, assembly and FTC/CBP distinctions
principal assembly takes place
Read complete named guidance sections, including express/implied overall impression, supplier evidence, negligible foreign-content factors, qualified/process/assembly conditions and separate Customs marking. Staff view is nonbinding; July 2024 printed date is not new rulemaking.
Federal Trade Commission
Passage, dates and research notes
primary · Complete eight-page Decision and Order; Decision, Parts I–II, X
neither admits nor denies
Read complete eight-page order issued July 13, 2020. It is effective upon website final publication; official timeline announces final orderJuly 16. No-admission except jurisdiction; unqualified/qualified/assembly branches read. Historical terms only, not later 2024 litigation or money collected.
Federal Trade Commission
Passage, dates and research notes
primary · Complete six-page complaint, especially paragraphs 9–14
wholly imported, or contain significant imported
Read all written paragraphs 1–14 of the six-page complaint issued July 13, 2020. Alleged broad product-category U.S.-origin claims and significant imports remain allegations, not contested trial findings or admissions. The article relies on these written paragraphs rather than separate claims about embedded advertisement images.
Federal Trade Commission
Passage, dates and research notes
official-guidance · Complete 2020 administrative timeline and final-order entry
July 16, 2020
Read official 2020 case summary and timeline, including final-decision entry; used for final publication status. This is not the separate 2024 enforcement docket and supplies no collection result.
Detailed rule records (1)
An unqualified Made-in-USA product label requires final assembly/processing in the United States, all significant processing there, and all or virtually all ingredients/components made and sourced there. Advertising claims need a truthful supported overall impression. A narrower assembly claim has its own principal/substantial-assembly and last-substantial-transformation conditions in staff guidance.
16 CFR Part 323: Made in USA Labelling Rule Complying with the Made in USA StandardKeep this reading in your learning library.
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