The Rabbit Hole of Labeling Laws

You would think that disclosing where something was made would be pretty straightforward. You’d be wrong.


Let’s start with the imports. US law requires that the “country of origin” should be prominently displayed. 19 CFR 102. But there are exceptions. For example, if the product originates from a “preferential” country (i.e., one with which the United States has an existing trade agreement), then rules from the trade agreement can apply. In 2015, the U.S. had to repeal beef labeling laws because Canada and Mexico successfully argued that, under trade rules established by the World Trade Organization, the U.S. requirements that meat sold in grocery stores must indicate the country or countries, where the animal was born, raised and slaughtered imposed a disproportionate burden in record-keeping and verification requirements on meat producers and processors.  That’s why you probably don’t know where your steaks come from.


So how about Made in USA? Believe it or not, the only US laws that mandate disclosing if something is made here are laws related to automobiles, textiles, wool and fur products. That’s it. Everything else is pretty much up to the manufacturer. The problem is that companies do not need to get prior approval to claim their products are “Made in USA.” The Federal Trade Commission (FTC) enforces these laws, but they only investigates if a complaint is lodged (and, by the way, their budget is almost always on the chopping block).

So if you find the “Made in America” label, what does it mean?

When a product states that it is “Made in America” or “Made in U.S.A,” the company is making an “unqualified claim” that all or virtually all of the product was made in the United States. “Assembled in the USA” means a product is put together domestically, but not all of the products are necessarily from the United States.


However, keep this in mind: “Made in America” means only that it was made here. It’s not an endorsement that the company respected workers’ rights, was a good partner in the community or manufactured the product in an environmentally responsible way. To find out more about company track records, go to: Occupational Health and Safety Administration, National Labor Relations Board and Environmental Protection Agency.