Background

Just a month after President Trump issued an executive order directing the Federal Trade Commission to prioritize enforcement of its “Made in USA” rule, the FTC announced the enforcement actions noted below.

The FTC rule prohibits 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.

- One company will pay $625,000, the largest amount in a “Made in USA” labeling rule case to date, to resolve allegations that it made numerous unqualified “Made in the USA” claims across its website and other marketing materials even though the products at issue contained imported components.

- Two other companies will pay $167,743 to resolve allegations that they and their principals repeatedly and prominently represented in advertising and labeling that U.S. flags, U.S. military flags, and patriotic flag display products and other accessories were “Made in the USA,” “All-American Made,” “100% Made in the USA,” “100% American Made Tough,” and “Built by Americans for Americans” even though several products were wholly imported from China and others were comprised of significant or essential foreign components from China.

- Another company will pay $75,000 to resolve allegations that it falsely claimed that certain footwear products were “handcrafted 100%” in the U.S., that the “entire product” was made in the U.S. “from heel-to-toe, using no pre-assembled components from overseas,” and that their footwear products were “More than Made in USATM” when in fact various components were sourced from the Dominican Republic and Brazil.

- The FTC also closed without penalty investigations of two companies that each agreed to take action to remediate certain “Made in USA” representations and bring their companies into compliance with the FTC rule. The FTC noted, however, that it reserves the right to monitor and take further action, including potentially filing a federal lawsuit. 

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