The FTC has announced a “Made in the USA” enforcement sweep, bringing three federal actions and issuing two closing letters, following its July 2025 warning letters to companies about “Made in USA” compliance and President Donald Trump’s March 13, 2026, executive order “Ensuring Truthful Advertising of Products Claiming to be Made in America,” directing the agency to prioritize U.S.-origin claim enforcement.

Under the FTC’s long‑standing “all or virtually all” standard from 1997 and the 2021 Made in USA Labeling Rule (see FTC’s guidance on complying with the Made in USA standard), unqualified “Made in USA” claims are allowed only when final assembly and virtually all components and processing are U.S.-based. 

The FTC announced settlements with TouchTunes for electronic dartboards, Americana Liberty/Three Nations and principals for American and military flags, patriotic flag products, and Oak Street Manufacturing/Bootmakers for footwear.

Across these cases, the FTC alleged the companies made unqualified “Made in USA” claims  while relying on foreign components and/or foreign manufacturing (including electronics, footwear uppers and outsoles, textile products from China, and assembly in the Dominican Republic and Brazil).

The FTC alleged violations of Section 5 of the FTC Act and the Made in USA Labeling Rule, and for the flag products, the Textile Fiber Products Identification Act and Rules. In total, the companies agreed to pay $867,743 (TouchTunes: $625,000, Americana Liberty/Three Nations : $167,743, and Oak Street: $75,000) toward consumer redress.

The orders require accurate use of “Made in the USA” claims that comply with federal standards; the type or origin of materials; or any other material fact about a product. The companies may make unqualified U.S.-origin claims only when final assembly or processing occurs in the U.S.; all significant processing occurs in the U.S.; and all or virtually all components are U.S.-made and sourced.

They must also use clear, conspicuous qualified claims that accurately describe foreign content or processing and, for textiles, clearly label country of origin and whether products are U.S.-made, made with imported materials, or partly foreign/partly U.S.

Separately, the FTC closed investigations into Marketing Holders LLC and Lamar Trailers, Inc. after both companies corrected allegedly unqualified “Made in USA” claims and committed to compliance.

Why It Matters

The executive order and these matters confirm that “Made in USA” is an enforcement priority under the current administration, with real monetary and injunctive-relief consequences for lack of alleged compliance. Final U.S. assembly alone is not enough — significant foreign components or processing can render unqualified claims deceptive. The strict standard applies across labels, packaging, websites, social media, and catalogs, and reaches sectors including electronics, patriotic products, textiles, and footwear.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Clayton Friedman Clayton Friedman

Clayton is a partner in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group and co-leader of the State Attorneys General practice, multidisciplinary teams with decades of experience crafting effective strategies to help deter or mitigate the risk of enforcement actions and…

Clayton is a partner in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group and co-leader of the State Attorneys General practice, multidisciplinary teams with decades of experience crafting effective strategies to help deter or mitigate the risk of enforcement actions and litigation.

Photo of Michael Yaghi Michael Yaghi

Michael is a partner in the firm’s State Attorneys General and Regulatory Investigations, Strategy + Enforcement (RISE) Practice Groups, nationwide teams that advise clients on consumer protection enforcement matters and other regulatory issues. Based in the firm’s Orange County office, Michael represents high-profile…

Michael is a partner in the firm’s State Attorneys General and Regulatory Investigations, Strategy + Enforcement (RISE) Practice Groups, nationwide teams that advise clients on consumer protection enforcement matters and other regulatory issues. Based in the firm’s Orange County office, Michael represents high-profile clients in regulatory enforcement investigations involving all facets of their business, including but not limited to, advertising and sales practices, monthly membership programs, auto renewal programs, telemarketing and telephone solicitations, door-to-door sales practices, and endorsements. Having begun his career as a commercial litigator, he also supports clients throughout litigation, should an investigation move in that direction.

Photo of Namrata Kang Namrata Kang

Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer…

Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer protection laws relating to consumer financial services and marketing and advertising. Nam’s experience transcends multiple industries, including financial services, telecommunications, media, and sports betting.