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FAQ's

The FTC’s “Made in the USA Labeling Rule” (the “MUSA Rule” or “the Rule”) defines what it means to be “Made in the USA”:

“The term Made in the United States means any unqualified representation, express or implied, that a product or service, or a specified component thereof, is of U.S. origin, including, but not limited to, a representation that such product or service is “made,” “manufactured,” “built,” “produced,” “created,” or “crafted” in the United States or in America, or any other unqualified U.S.-origin claim.”

Additional clarification can be found in the PDF downloaded guideline.

The FTC’s MUSA Rule establishes a three-pronged test to determine whether a product fits that definition:

“it is an unfair or deceptive act or practice within the meaning of section 5(a)(1) of the Federal Trade Commission Act, 15 U.S.C. 45(a)(1), to label any product as Made in the United States unless:

  1. the final assembly or processing of the product occurs in the United States,
  2. all significant processing that goes into the product occurs in the United States, and
  3. all or virtually all ingredients or components of the product are made and sourced in the United States.”

The FTC can pursue monetary punishments for violations of the MUSA Rule. As of January 2022, the FTC may seek civil penalties of up to $46,517 per violation. Those numbers can add up quickly.

Understanding the FTC Guidelines

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  • Other important laws and regulations in plain language
  • How to develop your manufacturing and marketing practice
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