Review a US origin claim against FTC guidance on assembly, significant processing, foreign parts and supporting evidence.
Product category
Your answers stay in this tab. Print or download the checklist without an account.
Proposed claim
An unqualified Made in USA claim requires US final assembly or processing, all significant US processing and all or virtually all ingredients or components made and sourced in the US. A percentage alone is insufficient.
State the specific US work or content you can document. Review the entire label, imagery and product listing for implied claims.
Illustrative assessments
Significant substantiation concerns
US final assembly with a significant imported component. The proposed claim is Made in USA.
An unqualified Made in USA claim requires US final assembly or processing, all significant US processing and all or virtually all ingredients or components made and sourced in the US. A percentage alone is insufficient.
Evidence and records checklist · Keep supplier origin records, a bill of materials, manufacturing and assembly records, and the proposed label or listing. Recheck when sourcing changes.
CBP · FTC claim substantiation and CBP import marking are separate checks. Confirm applicable country-of-origin marking before using a US claim.
Potentially supportable with adequate evidence
US final assembly, significant processing and US sourcing are documented for the product.
An unqualified Made in USA claim requires US final assembly or processing, all significant US processing and all or virtually all ingredients or components made and sourced in the US. A percentage alone is insufficient.
Evidence and records checklist · Keep supplier origin records, a bill of materials, manufacturing and assembly records, and the proposed label or listing. Recheck when sourcing changes.
CBP · FTC claim substantiation and CBP import marking are separate checks. Confirm applicable country-of-origin marking before using a US claim.
Potentially supportable with adequate evidence
Imported parts undergo documented substantial principal assembly and last substantial transformation in the US. Claim: Assembled in USA.
For Assembled in USA, check substantial principal assembly and the last substantial transformation in the US. US packaging alone cannot substantiate manufacturing or assembly.
Evidence and records checklist · Keep supplier origin records, a bill of materials, manufacturing and assembly records, and the proposed label or listing. Recheck when sourcing changes.
CBP · FTC claim substantiation and CBP import marking are separate checks. Confirm applicable country-of-origin marking before using a US claim.
The review date identifies the approved rules in use. Source changes require review before publication.
This educational screen concerns US federal rules. Verify the current sources and your facts. The result cannot establish compliance or agency approval.
Frequently asked questions
Proposed claim
An unqualified Made in USA claim requires US final assembly or processing, all significant US processing and all or virtually all ingredients or components made and sourced in the US. A percentage alone is insufficient.
Manufacturing and assembly
For Assembled in USA, check substantial principal assembly and the last substantial transformation in the US. US packaging alone cannot substantiate manufacturing or assembly.
Official sources
FTC claim substantiation and CBP import marking are separate checks. Confirm applicable country-of-origin marking before using a US claim.
