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Getting started

Three tests, and all three have to hold

On this page11
Final assembly, all significant processing, all or virtually all components. Satisfy two and the claim is still prohibited.

The prohibition is one sentence with three conditions in it

It is an unfair or deceptive act to label any product as Made in the United States unless the final assembly or processing occurs here, all significant processing occurs here, and all or virtually all ingredients or components are made and sourced here.

And the three reach progressively further back

The first asks about one step, the last one. The second asks about every material step. The third asks about the whole bill of materials and where each item on it came from.

Which means the easiest test to satisfy is the one people quote

Final assembly in the United States is a fact about a factory floor. All or virtually all components made and sourced here is a fact about a supply chain, and the two are very different things to establish.

So a claim can be literally true and still prohibited

A product genuinely assembled in the United States from imported parts is accurately described as made here in one sense, and labeling it Made in the USA is an unfair or deceptive act under this rule.

That is a sharper position than a prohibition on falsity

The Lacey Act false labeling offense prohibits any false record, account or label, assessed against the world. This rule prohibits an unqualified claim unless three specific conditions hold, which can catch a statement nobody would call false.

All or virtually all is the qualifier and it is doing necessary work

Not all. A rule requiring literally every component to be domestic would be unmeetable for almost any manufactured product, and virtually all moves the test from an absolute to a practical one.

This library has collected several such qualifiers and they behave the same way

Essentially the same optical, physical and chemical properties, in the jewelry guides. No severe rusting, in the used oil storage rule. Very small quantities, in the hazard communication article test. Each one makes a test applicable.

Made and sourced is also two words rather than one

Made in the United States and sourced in the United States. A component manufactured here from imported raw material is a different case from one imported finished, and the phrase covers both questions.

And significant is the only undefined word in the second test

All significant processing. Which leaves the question of what counts as significant to be judged, and that is the one place in the sentence where the rule declines to specify.

None of which reaches anything on this shelf

This catalog records no country of origin for any product. Nothing on these pages states where anything was made, and no page says whether any product may carry a domestic origin claim.

References

16 CFR 323.2, Prohibited acts: "In connection with promoting or offering for sale any good or service, in or affecting commerce as “commerce” is defined in section 4 of the Federal Trade Commission Act, 15 U.S.C. 44, it is an unfair or deceptive act or practice within the meaning of section 5(a)(1) of the Federal Trade Commission Act, 15 U.S.C. 45(a)(1), to label any product as Made in the United States unless the final assembly or processing of the product occurs in the United States, all significant processing that goes into the product occurs in the United States, and all or virtually all ingredients or components of the product are made and sourced in the United States." law.cornell.edu
Written from 16 CFR part 323 and from the catalog as it stood on 19 October 2026. Part 323 is the Made in USA Labeling Rule and it governs an unqualified claim of United States origin; it imposes no labeling requirement on anybody who makes no such claim, and it does not reach any container on this shelf. The catalog records no country of origin for any product, so nothing here states the origin of anything or whether any product may be labeled Made in the USA. Nothing here is advice about origin claims or advertising. This shelf is a subset of the store-small-dry shelf and the sewing notions property enumerates that shelf in full.