The Federal Trade Commission recently closed two investigations into marketers' “Made in USA” claims.  Here's a quick recap. 

The FTC looked into whether LifeVac overstated the extent to which its medical device products were made in the United States.  According to the FTC, the company marketed the products as “Made in the USA” even though those products “contained significant imported content.”  The FTC ultimately closed the investigation, though, indicating that the company had removed all of its “Made in USA” claims from its marketing materials, including television and social media. 

The FTC also investigated whether Buckingham Manufacturing Co. overstated the extent to which its safety harnesses are made in the United States.  The FTC noted that the products were marketed on the company's own website, in Amazon listing, and in other online advertising.  Again, the FTC closed the investigation, indicating that the company had removed its “Made in USA” claims from all product packaging and marketing materials, communicated the changes to distributors and third party websites, and instituted a compliance monitoring plan. 

These letters – which were issued the day after Andrew N. Ferguson was officially designated as Chairman of the FTC – were pretty routine, and they certainly don't give any hints that the FTC plans to change its approach to “Made in USA” enforcement.  The letters restate well-established principles, warn consumers about substantiating both express and implied claims, and reaffirm that it is proper for companies to promote their commitment to American jobs and highlight U.S. processes in a non-misleading manner.  And, as these letters have done for many years, they indicate that FTC staff is available to work with companies to help them craft claims “serving the dual purposes of conveying non-deceptive information and highlighting work done in the United States.”