Companies Get Warning, Not Penalties, for False “Made in USA” Claims

The Federal Trade Commission recently issued warning letters to seven companies that it said appear to have misrepresented certain products as “Made in USA” despite indications that the products were imported in whole or in significant part.

FTC rules prohibit marketers from labeling products as “Made in USA” unless (1) the final assembly or processing, and all significant processing that goes into the products, occur in the U.S. and (2) all or virtually all ingredients or components of the products are made and sourced in the U.S. The rule also requires all “Made in USA” labels appearing in mail order catalogs to be truthful and non-misleading.

In March 2026 President Trump issued an executive order directing the FTC to prioritize enforcement of this rule, and a month later the FTC announced three related penalty actions. The FTC did not indicate why it issued warning letters instead of penalties in the most recent case.

The EO also directed other actions regarding “Made in USA” claims that do not appear to have been taken yet, including (1) the FTC proposing regulations providing that the failure of an online marketplace to establish procedures for verifying country-of-origin claims may constitute an unfair or deceptive act or practice under the FTC Act, (2) all other agencies with country-of-origin labeling oversight considering new regulations and consistent guidance promoting voluntary country-of-origin labeling for products made or manufactured in the U.S., and (3) federal agencies overseeing government-wide acquisition contracts and schedules periodically reviewing and verifying U.S.-origin claims for products sold to the federal government and referring violators to the Department of Justice for False Claims Act actions.