Made in USA on a listing: the 'all or virtually all' standard and how marketplaces check it

An unqualified "Made in USA" claim on a US listing requires the product to be "all or virtually all" made in the United States under the Federal Trade Commission's standard: final assembly and all significant processing in the US, all or virtually all components made and sourced in the US, and no more than negligible foreign content. Since the FTC's Made in USA Labeling Rule of August 2021, an unqualified Made in USA label, seal or stamp, including one in online marketing, can bring civil penalties when the product does not meet that standard. A product with real US work but significant imported parts can carry a qualified claim such as "Made in USA of U.S. and imported parts", and Walmart bars a Made in USA claim when the listing's images, packaging and attributes conflict.

What are the Made in USA requirements?

The FTC sets four conditions for an unqualified Made in USA claim:

• Final assembly or processing of the product happens in the United States.
• All significant processing happens in the United States.
• All or virtually all ingredients or components are made and sourced in the United States.
• The product contains no, or negligible, foreign content.

The seller must also have a reasonable basis for the claim, meaning competent and reliable evidence, and must update the claim if sourcing changes.

What does "all or virtually all" mean for imported parts?

"Negligible" foreign content is judged by how important the part is to what the product does, not only by its cost. The FTC's examples make the point:

• A watch with a Swiss movement: the movement is a small share of the cost but essential to how the watch works, so an unqualified Made in USA claim for the watch is likely deceptive.
• A table lamp with an imported base that is a significant part of the product: an unqualified Made in USA claim for the lamp is deceptive.

What is a qualified Made in USA claim?

A qualified Made in USA claim describes the US content of a product that does not meet the "all or virtually all" standard but has real US content or work. The FTC gives examples such as "60% U.S. content", "Made in USA of U.S. and imported parts", and "Couch assembled in USA from Italian Leather and Mexican Frame".

The FTC's guidance adds two cautions about qualified claims:

• A qualified claim needs significant US content or processing. In the FTC's treadmill example, "Made in USA of U.S. and Imported Parts" is deceptive when US parts are about three percent of part costs, while "Made in U.S. from Imported Parts" or "Assembled in U.S.A." would not be.
• "Assembled in USA" needs real assembly. The FTC's lawn mower example, with 15 to 20 percent foreign content, suits "Assembled in USA"; screwing together a few imported parts does not.

The last row follows the FTC's computer example: a computer imported from Korea in American packaging could be labelled "Computer Made in Korea. Packaging Made in USA."

Does the Made in USA Labeling Rule apply to online listings?

Yes, for seals, marks, tags and stamps. The FTC's Made in USA Labeling Rule, 16 CFR 323, finalised in August 2021, codified the "all or virtually all" standard for labels on products. The rule covers labels making unqualified claims, and it "applies to any online or other mail order marketing materials that include a seal, mark, tag, or stamp" labelling a product Made in USA.

Can a flag or badge in a listing image make a Made in USA claim?

Yes. A US flag, a "proudly made in America" badge or a map of the US in a product image can make a Made in USA claim as clearly as words, and a seal, mark, tag or stamp in online marketing falls under the Labeling Rule. Treat every listing image the way you treat the title: if the product does not meet the standard, the image should not suggest it does.

A flag used as a Made in USA seal or badge on a product image is covered by the Labeling Rule. A flag that is clearly part of a scene, such as on a porch in a lifestyle image, is less clear-cut; keep a flag out of any place where it reads as a claim about the product.

How does Walmart check a Made in USA claim?

Walmart bars a "Made in USA" claim when the listing's images, packaging and attributes conflict (Walmart's product claims policy, updated 5 June 2026). A Walmart listing that says "Made in USA" in the title while the package in the main image says "Made in China", or while the country of origin attribute names another country, is the conflict Walmart looks for.

Before adding a Made in USA claim on Walmart, check three things:

• The country of origin attribute says United States.
• The package in every listing image says the same, or says nothing that contradicts it.
• Every marketplace and the Shopify store show the same origin for the same product.

What are the country of origin rules for textiles?

Textile products have a separate US rule that applies to every listing, not only to listings making a claim. US rules for mail order and internet advertising of textile products, at 16 CFR 303.34, ask for a clear statement of whether the product was made in the USA, imported, or both, matching the label. The FTC's guidance adds that the textile and wool laws generally require a Made in USA label on most clothing and household textiles made in the US from US-made fabric.

Walmart also asks textile listings to disclose the country of origin at the point of sale (Walmart's textiles and apparel policy, updated 11 December 2025). The clothing and textile labelling rules cover fibre content and care labels too.

Can a handmade product with some imported parts say Made in USA?

A made-up example shows the decision for a leather wallet. A seller makes leather wallets in a workshop in Ohio; the leather comes from a US tannery, the thread is made in Germany, and the snap is made in China.

• Final assembly happens in Ohio: yes.
• Significant processing, the cutting, stitching and finishing, happens in Ohio: yes.
• Components: the leather, the main material, is US-made. The thread and the snap are imported and small in cost, and the question is whether they are negligible to the wallet as a whole.

The wallet seller has three honest choices: confirm the imported parts are negligible and keep the evidence; source US-made thread and snaps and make the unqualified claim; or use a qualified claim such as "Made in USA of U.S. leather and imported hardware". The FTC's examples show that what matters is whether a foreign part is significant to the product, not only its cost, as with a watch's movement.

What happens to a Made in USA claim when sourcing changes?

The FTC asks marketers to update a Made in USA claim when sourcing changes. A cheaper imported component, a new supplier for a part, or a move of one production step abroad can each take a product from Made in USA to a qualified claim. A seller who makes Made in USA claims should agree that whoever changes a supplier or a part tells whoever maintains the listings, and check the claim the same week on every marketplace.

Can "Made in USA" be used as a keyword?

"Made in USA" is a phrase shoppers search for, and on a listing it is a claim wherever it appears: in the title, the bullets, the backend search terms or the tags. Use "Made in USA" only for products that meet the FTC standard, or as part of an honest qualified phrase that matches the label. "Designed in USA" is a different claim, about design rather than manufacture, and a listing that uses it must not also suggest the product is made in the US.

What evidence supports a Made in USA claim?

The FTC asks for a reasonable basis for a Made in USA claim. For each product claimed as Made in USA, keep:

• a list of the product's parts and materials, with where each was made and sourced
• where final assembly or processing happens
• supplier statements for components
• the date of the last check, since the claim must be updated if sourcing changes

A Made in USA checklist

1. Final assembly or processing in the US.
2. All significant processing in the US.
3. All or virtually all parts and materials made and sourced in the US, the essential ones included.
4. If not, a qualified claim that says exactly what is true.
5. No US flag badges or seals in listing images unless the product meets the standard.
6. The country of origin attribute, the package and the listing all agree.
7. For textiles, "Made in USA", "Imported" or both, matching the label.
8. Evidence on file, reviewed when sourcing changes.

How Commicorn helps

• Claims marked. A "Made in USA" keyword comes with a line saying what the marketplace asks for before it goes into your listing.
• Your package, as printed. On the Untouched product route the pixels of your photo are never redrawn, so the origin on your package is the one shoppers see.

Commicorn marks a Made in USA claim with what each marketplace asks for. Start free.

Questions sellers ask

What percentage of a product must be made in the USA to say Made in USA?

The FTC sets no fixed percentage: an unqualified claim needs the product to be "all or virtually all" made in the US, with no more than negligible foreign content, judged by how important each foreign part is to the product as well as its cost.

Can I say Made in USA if the product is assembled in the US from imported parts?

Not without qualification. "Assembled in USA" suits a product with real US assembly, and the FTC's treadmill example shows "Made in USA of U.S. and Imported Parts" is deceptive when US parts are only about three percent of part costs.

Does the Made in USA Labeling Rule cover Amazon and Etsy listings?

The FTC's Labeling Rule applies to online and mail order marketing that includes a seal, mark, tag or stamp labelling a product Made in USA, which covers a badge in a listing image on any marketplace.

Do textile listings have to state where the product was made?

Yes. US rules for internet advertising of textile products ask each listing to say whether the product was made in the USA, imported, or both, matching the label.

What is the penalty for a false Made in USA label?

Since the FTC's Labeling Rule of August 2021, an unqualified Made in USA label on a product that is not all or virtually all made in the US can bring civil penalties, including in catalogues and online.