For years, “Product of USA” has been a familiar origin claim on meat, poultry, and egg products, governed by USDA policy that focused primarily on where processing occurred. That framework has changed. Under USDA’s updated rule governing voluntary U.S.-origin claims, “Product of USA” is subject to a more rigorous, life-cycle-based definition and heightened verification expectations. And while the formal compliance date is January 1, 2026, the practical implication is immediate: if a Food Safety and Inspection Service (FSIS)-regulated food product bears a U.S. origin claim today, the substantiation must already exist and be readily available upon request.

Why USDA Changed the Standard

USDA’s rulemaking was driven in large part by consumer research on how shoppers interpret U.S.-origin claims on meat, poultry, and eggs. USDA found that consumers overwhelmingly understand claims like “Product of USA” to mean that the animal was born, raised, and processed in the United States — not merely that the processing facility was local.

Under the prior policy, that consumer understanding often did not align with reality. Products derived from animals born and raised abroad — but processed in the United States — could still bear a “Product of USA” claim. USDA concluded that this disconnect warranted a clearer, more consistent standard.

The New Standard: A Life-Cycle Origin Test

FSIS, acting under USDA authority, published the final “Voluntary Labeling of FSIS-Regulated Products with U.S.-Origin Claims” rule in March 2024, with a uniform compliance date of January 1, 2026. The rule significantly revised when companies can legally use claims such as “Product of USA” or “Made in the USA” on meat, poultry, and egg products.

Under the revised standard, these claims are permitted only if the product is derived from an animal that was born, raised, slaughtered, and processed entirely in the United States. For multi-ingredient products, all FSIS-regulated animal components must meet that same standard, and all other significant ingredients (excluding spices and flavorings) must also be of U.S. origin, with processing occurring domestically.

The claims remain voluntary. But once used, they are subject to this defined test and verification by FSIS.

How This Differs From Prior USDA Policy

The change is substantive.

Under prior USDA policy, meat or poultry products could bear a “Product of USA” claim so long as the product was processed in the United States, even if the animal itself was born and raised outside the country. Imported livestock that was slaughtered or further processed domestically often qualified.

That approach is no longer permitted.

Under the new rule, U.S. processing alone is insufficient. If the animal was born or raised outside the United States, the product may not be labeled “Product of USA,” regardless of where slaughter or further processing occurs.

Alignment With FTC Origin Principles

Although the USDA rule applies only to FSIS-regulated products, the revised standard more closely aligns with the Federal Trade Commission’s long-standing approach to U.S.-origin labels and claims. Under FTC rulemaking and guidance, an unqualified “Made in USA” statement generally requires that a product be “all or virtually all” made in the United States, including the origin of components and final assembly or processing.

USDA’s life-cycle origin test reflects the same principle identified in its consumer research: when consumers see an unqualified U.S.-origin claim, they reasonably expect that the substantive inputs — not just the final step — are domestic.

Substantiation and Timing: The Compliance Pressure Point

FSIS does not require pre-approval for “Product of USA” claims. However, companies must maintain substantiating documentation and produce it promptly upon request during inspection or label verification.

FSIS reinforced this expectation through updated inspection guidance, including the FSIS Directive 7221.1 issued on December 10, 2025. This Directive instructs inspectors to verify voluntary U.S.-origin claims as part of routine labeling review. In practice, inspectors may request substantiation during an inspection and expect it to be available within a short timeframe.

There is no opportunity to assemble records after the fact. If substantiation is not readily available when requested, the claim may be deemed unsupported.

What FSIS Will Expect to See

FSIS has made clear that substantiation must be meaningful and product-specific. Depending on the product and supply chain, that may include:

• Records demonstrating that animals were born, raised, slaughtered, and processed in the United States;
• Documentation establishing the U.S. origin of FSIS-regulated components in multi-ingredient products;
• Written descriptions of internal controls used to ensure compliance with the origin standard; and
• Records that are organized, accessible, and capable of being produced promptly.

General assurances, informal supplier statements, or assumptions based solely on where final processing occurs are not sufficient.

The Bottom Line

As the year winds down and tables fill with roasted leg of lamb, glazed ham, and egg-rich holiday sides, “Product of USA” will mean something more specific than before. Under USDA’s revised rule, it’s no longer enough that the meat, poultry and eggs incorporated into those dishes were processed domestically — the story of where the ingredients came from matters too.

For companies using U.S.-origin claims, the takeaway is simple: if the label tells an all-American story, the records should be able to tell the same one.