Buying Guides Guide
“Made in USA” on electronics and kitchenware: what the FTC requires, and what “Assembled in USA” means
Our take
Final assembly here is not enough: the FTC says a product labeled Made in USA must be all or virtually all made in the US. What the other claims mean.
By Review Boon Team · · 5 min read
Key points
- Under the FTC's Made in USA Labeling Rule, in effect since August 13, 2021, an unqualified label needs final assembly, all significant processing and all or virtually all components in or from the US.
- The FTC says no law requires most products to disclose their US content. Automobiles and textile, wool and fur products are the exceptions.
- In the FTC staff's guidance, “Assembled in USA” needs a substantial principal assembly in the US, and a simple “screwdriver” assembly of foreign parts usually does not qualify.
- In April 2026, TouchTunes stipulated to a proposed order providing $625,000 toward consumer redress, to resolve FTC allegations that it falsely called its electronic dartboards Made in the USA.
- In 2023, Pyrex maker Instant Brands agreed to an FTC order with a $129,416 judgment, and in 2024 Williams-Sonoma agreed to pay a $3.175 million civil penalty over charges it violated a 2020 FTC order.
When a product page says “Made in USA”, the Federal Trade Commission sets the standard that claim has to meet, and it is strict: a product sold with an unqualified Made in USA claim must be “all or virtually all” made in the United States. Since August 13, 2021, the FTC's Made in USA Labeling Rule has written that standard into federal regulation for labels, so a company that breaks it can face civil penalties.
What an unqualified claim promises
The rule sets three conditions for a product labeled Made in the United States: its final assembly or processing happens in the US, all significant processing happens in the US, and all or virtually all of its ingredients or components are made and sourced in the US. The FTC staff's plain-language guide, dated July 2024, sums it up as no foreign content, or only a negligible amount.
Cost is only part of the test. Once final assembly is in the US, the FTC also looks at how far back in the manufacturing chain any foreign content sits and how much it matters to what the product is or does. Two of its examples fit this site's lane. A food processor assembled in the US from mostly American parts cannot carry the claim if its motor, half of the manufacturing cost, is made of imported parts that make up a significant percentage of the appliance's total manufacturing cost. The silicon inside a computer's microchip, by contrast, is an early input that the FTC says is likely to be a very small part of the final cost.
Where the rule applies
The Labeling Rule covers labels on products that make an unqualified Made in USA claim. It also reaches online or other mail order marketing that shows a seal, mark, tag or stamp labeling a product Made in USA. Other origin claims in advertising, including digital marketing, fall under the FTC Act and the agency's 1997 policy statement, which applies the same “all or virtually all” standard. The standard applies to products advertised or sold in the US, except those covered by other country-of-origin labeling laws.
A label is optional. The FTC says no law requires most products sold in the US to state their American content, though separate laws require it for automobiles and for textile, wool and fur products. Imports are a separate matter: under the Tariff Act, U.S. Customs and Border Protection (CBP) requires imported goods to be marked with their foreign country of origin. The FTC adds that an import CBP decides needs no foreign-origin mark is not automatically entitled to a Made in USA claim.
Qualified claims and “Assembled in USA”
A qualified claim states how much of a product, or which part of it, is American, and so tells you that the product is not entirely domestic. The FTC's examples include “60% U.S. content” and “Made in USA of U.S. and imported parts”. Even so, FTC staff advise against qualified claims unless the product has a significant amount of US content or US processing. In one FTC example, a treadmill is assembled in the US, in work the FTC calls significant, from an imported motor, frame and display, with only incidental US parts worth about 3% of the parts cost. The FTC says calling it “Made in USA of U.S. and Imported Parts” is deceptive, while “Made in U.S. from Imported Parts” or “Assembled in U.S.A.” would not be.
| Claim | What it needs, according to the FTC | FTC example |
|---|---|---|
| Made in USA, with no qualification | Final assembly and all significant processing in the US, and all or virtually all components made and sourced in the US | Watches assembled in Nevada with inexpensive Swiss movements: likely deceptive, because the movements are essential |
| Qualified claim, such as “Made in USA of U.S. and imported parts” | A significant amount of US content or processing, stated truthfully and backed by evidence | The treadmill above: deceptive with that wording, not deceptive as “Made in U.S. from Imported Parts” |
| Assembled in USA | Principal assembly in the US that is substantial, with the last substantial transformation in the US | A computer put together from imported major parts in a simple screwdriver operation: deceptive without more qualification |
| A claim about one process or part | Must be true, backed by evidence and clearly limited to that process or part | A product invented in Seattle and made in Bangladesh, called “Created in USA”: deceptive |
Recent cases involving home products
On April 14, 2026, the FTC announced a Made in USA sweep with law enforcement actions involving three companies, each resolved by a settlement. One was with TouchTunes Music Company, which the FTC alleged had made false, unqualified “Made in the USA” claims for electronic dartboards sold for home and commercial use. According to the complaint, TouchTunes did the final assembly in the US, but many components, including ones essential to how the boards work such as computer chips, cameras and flat-screen monitors, were made outside the US. To resolve the allegations, TouchTunes stipulated to a proposed order providing $625,000 toward consumer redress, which the FTC called the largest for a Made in USA Labeling Rule case to date, and requiring it to notify consumers of the settlement. The FTC's case page lists the stipulated order as entered by the court, under May 5, 2026.
In kitchenware, the FTC's January 2023 complaint said that Instant Brands, the maker of Pyrex products, made some glass measuring cups in China from March 2021 to May 2022 while still selling them on Amazon as “Made in USA”, even though the cups themselves were marked “Made in China”. The FTC put the total at more than 110,000 units. The order, which the company agreed to and the FTC finalized in March 2023, requires Instant Brands to pay a $129,416 judgment, and in October 2024 the FTC said it was sending more than $88,000 in refunds to buyers.
In April 2024, Williams-Sonoma agreed to a settlement requiring it to pay a $3.175 million civil penalty, which the FTC called the largest ever in a Made in USA case. The Justice Department's complaint, filed on the FTC's referral, charges that the retailer violated a 2020 FTC order by listing products as Made in USA that were made in China and other countries.
Marketplace listings
On July 8, 2025, the FTC sent letters to Amazon and Walmart that explained how its Made in USA requirements apply to online marketplaces and named third-party sellers that may be making deceptive US-origin claims. The FTC said such claims may break the FTC Act and the platforms' own terms of service. The same day it sent warning letters to four companies, and two of them, Americana Liberty and Oak Street Manufacturing, were among the April 2026 settlements.
In the Pyrex case, the FTC's complaint said listings claimed Made in USA for cups marked Made in China. The FTC warns that an ad whose origin claim does not match the foreign-origin mark CBP requires on the product can leave buyers confused about where it was made. Its guide says suspected violations can be reported at ReportFraud.ftc.gov or to a state attorney general. For another label worth checking, see our guide to counterfeit safety certification marks.
Based on the FTC's Made in USA Labeling Rule (16 CFR Part 323), its staff guide to the standard, and FTC press releases and case pages. It describes the rules and published cases, not any product's origin, and is not legal advice.
Sources
- Complying with the Made in USA Standard (FTC staff guide, July 2024) Federal Trade Commission, November 10, 2026
- 16 CFR Part 323, Made in USA Labeling (eCFR, current text) Office of the Federal Register, eCFR, November 10, 2026
- FTC Announces “Made in the USA” Sweep, Including Three Law Enforcement Actions to Protect American Consumers and Businesses Federal Trade Commission, April 14, 2026
- Touchtunes Music Company, FTC v. (case page) Federal Trade Commission, May 5, 2026
- FTC Order Requires Pyrex Glass Manufacturer to Pay for Falsely Claiming Chinese Products Were Made in USA Federal Trade Commission, January 18, 2023
- Instant Brands LLC, In the Matter of (case page) Federal Trade Commission, October 1, 2024
- Williams Sonoma (case page: United States v. Williams-Sonoma, Inc.) Federal Trade Commission, April 26, 2024
- Federal Trade Commission Warns Companies to Comply with “Made in USA” Requirements Federal Trade Commission, July 8, 2025
Researched and drafted with AI assistance, then checked against the 8 sources above in a separate fact-check on November 10, 2026. Spotted an error? Tell us.