Insights on Made in USA
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The Federal Trade Commission (FTC) has continued its crackdown on false and misleading “Made in USA” claims. Since finalizing the Made in the USA Labeling Rule in 2021, which authorizes the agency to levy civil penalties against noncompliant companies, the FTC has brought 11 enforcement actions, resulting in over $15 million in judgments against parties found to have falsely labeled their products as being “Made in the USA.”
With 2024 underway, ArentFox Schiff highlights 10 of the most pressing legal issues facing the consumer products industry this year.
The Federal Trade Commission (FTC) continues to evidence a strong commitment to bringing enforcement actions against false or deceptive US-origin marketing claims.
The Federal Trade Commission (FTC) continues to crack down on companies for falsely advertising that their products are “Made in USA,” as most recently announced in a press release issued on March 30, 2023.
Mattress manufacturer, Resident Home LLC and its owner, Ran Reske, will pay $750,000 to settle Federal Trade Commission (FTC) charges over alleged misrepresentations that its mattresses were made from 100% USA-made materials in violation of an earlier FTC administrative order prohibiting the company
On July 30, 2021, a notice of proposed rulemaking was published in the Federal Register with changes to two regulations that have the potential to materially affect the supply chains of products where manufacturing in the United States does not rise to the level of “substantial transformation.”

Arent Fox is monitoring policy changes by the Biden Administration to provide timely analysis on how they could impact your business.
On July 16, 2020, the Federal Trade Commission (FTC) published a proposed rule for “Made in the USA” (MUSA) claims for labels in the United States.
Though not a national holiday, it is significant that the designation of the first Friday in October as “Manufacturing Day” resulted from bi-partisan resolutions in both houses of Congress as recognition of the contribution that US manufacturing makes to the economy.
March and April were very busy months for the Federal Trade Commission’s Office of Consumer Protection staff who focus on “Made in USA” enforcement.
The Federal Trade Commission has announced a proposed settlement and consent order in its investigation of a US-based water filtration company.
On Monday, November 30, 2015, Nordstrom and denim manufacturer AG Adriano Goldschmied filed a motion to approve a settlement in California federal court, agreeing to pay more than $4 million to settle a consumer class action suit that accused them of falsely labeling jeans as “Made in USA.”
On Tuesday September 1, 2015, California Governor Jerry Brown signed a bill that will enable products to be labeled and marketed with an unqualified “Made in USA” statement even if not entirely made in the United States – a major departure from California’s current more stringent standard.
Your company has been asked by a customer to certify that its products manufactured in US plants are in compliance with “Buy American” requirements. How does your company respond?
Your company has been asked by a customer to certify that its products manufactured in US plants are in compliance with “Buy American” requirements. How does your company respond?