As we’ve noted in other posts, an FTC rule prohibits companies from stating or implying that a product is made in the USA unless: (1) the final assembly or processing of the product occurs in the USA; (2) all significant processing that goes into the product occurs in the USA; and (3) all or virtually all components are made or sourced in the USA. It can be a challenge to figure out whether a product you make meets that standard, especially when you get components from suppliers. A new FTC closing letter sheds some light on how companies should go about this.
https://www.adlawaccess.com/2022/09/articles/ftc-addresses-supplier-due-diligence-for-made-in-usa-claims/
Gonzalo E. Mon
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Email: gmon@kelleydrye.com
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