The Textile, Wool, Fur, and Care Labeling Rules require proper origin and fiber content labeling of textile, wool and fur products, and care label instructions attached to clothing and fabrics.
For a product to bear the label “Made in USA,” the product must be “all or virtually all” made in the United States. The term “United States,” as referred to in the Enforcement Policy Statement, includes the 50 states, the District of Columbia, and the U.S. territories and possessions. “All or virtually all” means that all significant parts and processing that go into the product must be of U.S. origin. That is, the product should contain no, or negligible, foreign content. The product’s final assembly or processing must take place in the United States. The Commission then considers other factors, including how much of the product’s total manufacturing costs can be assigned to U.S. parts and processing and how far removed any foreign content is from the finished product. In some instances, only a small portion of the total manufacturing costs is attributable to foreign processing, but that processing represents a significant amount of the product’s overall processing. Claims that a particular manufacturing or other process was performed in the United States or that a particular part was manufactured in the United States must be truthful, substantiated, and clearly refer to the specific process or part, not to the general manufacture of the product, to avoid implying more U.S. content than exists.
A product that includes foreign components may be called “Assembled in USA” without qualification when its principal assembly takes place in the United States and the assembly is substantial. For the assembly claim to be valid, the product’s last substantial transformation should have occurred in the United States.