FTC requires “Made in USA” claims to meet “all or virtually all” standard – products must be made entirely or virtually entirely in the U.S. Qualified claims (“Made in USA from imported components”) permitted with proper qualification. False unqualified claims subject to FTC enforcement and class actions.
This guide covers Made in USA Marking. Specific tariff actions span statutes, programs, and enforcement mechanisms.
Practical implementation depends on company size, sector, and operational structure.
FTC standard
“All or virtually all” – final assembly in U.S. plus negligible foreign content.
Qualified claims
“Made in USA from imported components” or similar qualifications permitted with accurate disclosure.
Common compliance issues
Unqualified MIUSA on products with significant foreign content. FTC enforcement focused on this.
Difference from CBP marking
CBP requires country-of-origin marking based on substantial transformation; FTC requires “all or virtually all” for MIUSA. Different standards.
Frequently asked questions
When does this apply?
Most relevant for SMB importers facing the named situation or considering the named strategy.
What documentation is needed?
Standard CBP forms plus topic-specific records.
What is the timeline?
Initial assessment 2-4 weeks; complex implementation 8-16 weeks.
What does this cost?
Project work typically $5,000-$25,000. Ongoing retainer for active operations.
How do I begin?
Book a 15-minute scoping call. We confirm fit before any engagement.
Get started
Engage on specific tariff action work. Project pricing varies by scope.