For products imported into or offered for sale in the United States, there are a couple of federal agencies' rules that have a say in how you mark your goods; some are a "may" and some are a "must." Do you understand the differences?

Manufacturers and marketers should not indicate, either expressly or implicitly, that a whole product line is of U.S. origin (“Our products are made in USA”) when only some products in the product line are made in the U.S. according to the “all or virtually all” standard.

On July 16, 2020, the Commission published a Notice of Proposed Rulemaking (“NPRM”) (85 FR 43162) seeking comments on a new rule regarding unqualified U.S.-origin claims (“MUSA claims”) on product labels. The NPRM was preceded by a review of the Commission's longstanding program to prevent deceptive MUSA claims. [1] .

Manufacturers and marketers should not indicate, either expressly or implicitly, that a whole product line is of U.S. origin (“Our products are made in USA”) when only some products in the product line are made in the U.S. according to the “all or virtually all” standard.