The Federal Trade Commission (FTC) is taking a more aggressive approach to enforcing U.S.-origin advertising claims. Unqualified statements such as “Made in USA” or “Manufactured in USA” generally require that all or virtually all of a product’s components and manufacturing be domestic. There is no specific percentage that automatically satisfies this standard; the FTC considers factors such as the proportion of U.S. manufacturing costs and the significance of foreign components. Importantly, final assembly in the United States does not necessarily support an unqualified U.S.-origin claim when a product contains significant or functionally important imported components.

Companies with mixed domestic and foreign sourcing should therefore consider limiting U.S.-origin claims to specific products or product lines that meet the applicable requirements. Depending on the circumstances, qualified language such as “Manufactured in the USA with globally sourced components” or “Assembled in USA” may be more appropriate. Recent FTC enforcement actions involving products assembled in the United States but containing significant foreign components demonstrate the potential consequences of unsupported claims, reinforcing the importance of reviewing and substantiating U.S.-origin statements before using them in marketing.