False labeling is its own offense
Updated
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What it says
A person may not make or submit any false record, account, or label for, or any false identification of, any paleontological resource excavated or removed from federal land. Four nouns, and a label is one of them.
Four things it reaches
A record, an account, a label, and an identification. So a specimen card, an invoice, a listing description and a species attribution are each capable of being a false one.
It is separate from the sale offense
Subsection (a)(3) covers selling; subsection (b) covers the labeling. A misstated origin is actionable in its own right, which is unusual and worth knowing before anyone decides a vague locality is safer than an honest one.
Vagueness is not the answer
Writing "Western USA" over a precise locality you know might feel cautious. If the real origin is federal land, an obscured label is closer to a false record than to an omission, and the sale offense is unaffected either way.
Identification counts
A false identification of a resource is named, so attributing a specimen to a species or a formation you have no basis for is in scope. In a category where the name drives the price that is a real temptation.
Locality data has its own protection
Under a permit, specific locality data may not be released by the permittee or repository without the Secretary’s written permission. So withholding precise locality is sometimes required rather than evasive, and the two situations should not be confused.
Write what you actually know
Including "locality unknown, acquired from X on Y date" where that is the truth. An honest gap is a usable record. An invented precision is the thing the subsection is about.