FTC Sends Warning Letters Regarding “Made in USA” Advertising Compliance, Indicates a High Enforcement Priority

The Federal Trade Commission (FTC) continues enforcement of its “Made in the USA” (MUSA) advertising standards, which has been a priority for the agency under both the current and previous Presidential Administrations. On July 6, 2026, the agency issued warning letters to seven companies marketing products as MUSA, asserting that it had reason to believe the products were imported.

The warning letters mark the latest step in a series of FTC activities focusing on U.S. origin claims in advertising during the past year. In July 2025 – which FTC Chairman Andrew Ferguson had designated as “Made in the USA Month” – the agency issued warning letters to several manufacturers and retailers. And in March 2026, President Trump issued an Executive Order directing the FTC to prioritize enforcement against unlawful Made in USA claims and to consider a rulemaking addressing online retail platforms’ listing of items sold by third parties in violation of FTC MUSA standards. One month later, the FTC announced three settlements with sellers of American flag products, footwear, and electronic dartboards who allegedly violated Section 5 of the FTC Act and the Made in USA Labeling Rule. Together with the most recent warning letters, these actions signify the high priority current FTC leadership places on MUSA compliance and enforcement.

FTC Standards for Making MUSA Claims in Advertising

Under the Made in USA Labeling Rule and its Policy Statement on U.S. Domestic Origin Claims, marketers generally may make “unqualified” MUSA claims – such as claims that a product is “Made in the USA” or “Made in America” – only when a product is “all or virtually all” made in the United States. According to the FTC, this means that final assembly or processing occurs domestically, all significant manufacturing takes place in the United States, “all or virtually all” inputs and parts are sourced domestically, and any foreign content is minimal. The FTC’s guidance also recognizes that advertisers may make “qualified” U.S. origin claims without satisfying the stringent requirements for an “unqualified” MUSA claim. Claims such as “Assembled in USA using imported parts” or “Made in USA with imported materials” may be appropriate if they are accurate and can be substantiated.

The FTC’s July 6 Warning Letters

The FTC’s latest warning letters targeted a diverse group of manufacturers and retailers making a variety of MUSA claims. The companies include sellers of e-cigarettes, musical instruments, industrial laser machinery, and coordinate measuring machines. Taken together, these warning letters identified a number of claims, beyond “Made in the USA” and “Made in America” claims, that the agency argued convey an implied meaning that the product is MUSA. These claims include: “Made in Texas,” “Built in the USA,” “Built in America,” “AMERICAN MADE,” “Precision Built in the USA,” “designed and manufactured in the USA,” and other representations suggesting domestic manufacturing – including references to U.S.-based facilities, American workers, American suppliers, local sourcing, and products being handmade in Austin, Texas. The agency warned that these allegedly deceptive origin claims may violate both Section 5 of the FTC Act and the Made in USA Labeling Rule.

Key Takeaways and Compliance Tips

Made in USA enforcement remains an FTC priority. The latest warning letters, coupled with recent enforcement actions and Executive Orders from President Trump, suggest this will remain a high priority issue for the FTC.

Review express claims as well as potential implied claims. Businesses should remember that the FTC doesn’t limit enforcement to express claims that explicitly say a product is “Made in USA.” The agency also looks at implied claims, which it says can be conveyed through other patriotic messaging such as the use of flags and phrases like “True American Quality.”

Look beyond product labels and traditional ads. Companies should evaluate websites, social media content, online marketplace listings, and other marketing materials to ensure that origin representations are accurate and consistent across all channels. Some of the warning letters indicated that the use of deceptive hashtags accompanying social media posts could violate the FTC’s MUSA labeling rule, which can trigger civil penalties up to $53,080 per violation.

State-specific origin claims count, too. The FTC’s warning letters highlighted long-standing guidance that claims about specific U.S. locations, like “Made in Texas,” can also constitute MUSA claims. Moreover, states may have their own laws to address these claims.

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