Made in USA Claim Checklist (FTC Standard)

0%

0 of 28 items complete

9 critical items still open - these are the highest-risk gaps.

Download checklist:

Is the claim unqualified?

Listed every place the claim appears: product, packaging, website, catalogs, listings, trade show, social media, sales emailsCRITICALConfirmed whether the wording is unqualified (for example Made in USA) or qualified (for example Assembled in USA with global parts)CRITICALChecked that images, flags and phrases such as American made or Built in America are treated as origin claims tooIdentified the product by name and SKU so each product is assessed separately

All or virtually all test

Final assembly or processing takes place in the United StatesCRITICALAll significant processing that goes into the product takes place in the United StatesCRITICALAll or virtually all ingredients and components are made and sourced in the United StatesCRITICALReviewed how much of the product cost is foreign content and where it enters the supply chainCRITICALConsidered how much a foreign component matters to the product's function and its significance to buyersChecked sub-tier suppliers, not just first-tier suppliers, for foreign inputsReviewed whether a foreign input is a significant, expensive or defining part of the product

Qualified claim options

If the test is not met, replaced the claim with a clear qualified one that describes what happens in the USQualified claim is placed close to the origin statement and is not hidden in small printQualified claim uses plain wording such as Made in USA with imported parts, or Assembled in USA from US and global componentsQualified claim does not imply more domestic content than the product hasSpecial rules reviewed for products with their own labeling regimes (textile, wool, fur, automotive parts)

Substantiation records

Bill of materials with country of origin for every component and subassemblyCRITICALSigned supplier origin affidavits for each domestic component claimedCRITICALCost breakdown showing the share of domestic and foreign contentProcess flow showing where each manufacturing step is done and by whomRecords of any change in supplier or location that could affect the claimClaim approval log naming the person who approved the wording and the date

Ongoing control

Change control step requires origin review when a supplier, component or plant changesCRITICALMarketing and the web team require compliance sign-off before publishing new origin wordingDistributor and retailer partners informed of the correct wording and told not to alter itAnnual review of every product carrying an origin claimProcedure for correcting claims quickly if a source changes or a complaint arrivesState rules checked where products are sold, since some states set stricter origin wording

An unqualified Made in USA claim is a strong statement. If any critical item cannot be supported, change the claim or the product before continuing. This checklist is a planning aid and not legal advice.

Origin data on your item master

Optional: see how country-of-origin fields and change alerts can be added to an ERP so claims stay supportable.

Optional. The tool and every export work without this. No spam.

How to use the checklist

Gather the bill of materials, supplier list and every piece of marketing that mentions origin. Work through the groups for one product at a time. Mark an item complete only if you have a document that supports it, such as an affidavit or cost breakdown. If a critical item fails, move to the qualified claim group and choose wording that matches the facts, then record the decision in the claim log.

The standard behind an unqualified claim

The FTC's Made in USA Labeling Rule and its enforcement policy statement say that a product claimed as Made in USA should be last substantially transformed in the United States, with all significant processing done here, and with all or virtually all of its ingredients or components made and sourced here. The more foreign content, or the more important that content is to the product, the less likely the claim holds. A product with minor foreign content may still qualify, which is why cost share and significance both matter.

Final assembly or processing in the United States
All significant processing done in the United States
All or virtually all inputs made and sourced here
Foreign content judged on cost share and importance

Qualified claims and marketing

When the unqualified standard is not met, a qualified claim can be accurate, such as Assembled in USA with global parts. The wording must be clear and placed with the origin claim, not hidden. Marketing is where problems usually start: a flag graphic on a web page, a distributor listing or a sales sheet can make an origin claim that the label does not. Treat every channel as part of the same claim.

Common mistakes and ERP notes

Common mistakes include assuming a US supplier address means a US-made part, ignoring foreign content in sub-tier components, and failing to re-test after a supplier change. Store country of origin on the item and supplier in the ERP and add an origin review to engineering change and supplier approval workflows, so a change in sourcing triggers a check before the label or website says something that is no longer true.

Frequently Asked Questions

What does Made in USA legally mean?

Under FTC guidance, an unqualified claim means the product is all or virtually all made in the United States: final assembly here, all significant processing here, and all or virtually all components made and sourced here. Qualified claims can be used when the product does not meet that standard.

Can a product with some imported parts say Made in USA?

Only if the foreign content is negligible. If imported parts are significant in cost or function, the product does not meet the standard, and a qualified claim such as Made in USA with imported parts is the safer route. Document the cost share and significance for each foreign input.

Does Assembled in USA have its own rule?

Yes. An Assembled in USA claim can be accurate when the principal assembly happens here and the assembly is substantial, even with imported parts. It still needs to avoid suggesting greater domestic content, and the product must be last substantially transformed in the United States.

Who is responsible for a retailer's listing?

Both. If you supply the product and wording, or let a false claim stand, you can share responsibility with the retailer. Give partners approved wording in writing and monitor listings and marketing for claims that exceed what your records support.

Netray can help add origin fields to your ERP item master and flag sourcing changes that could affect a Made in USA claim, for your compliance team to review.

Talk to an Expert Explore More Free Tools

Related Tools

Compliance & Contracts

More Compliance & Contracts tools

See all

Made in USA Claim Compliance Checklist