[Home](/)/[Resources](/resources)/FTC Made in USA Labeling USLabeling guide # FTC Made in USA Labeling for Electronics: What You Can and Cannot Claim Making a 'Made in USA' claim on electronics — whether on the product, the packaging, or the website — triggers FTC scrutiny under the 'all or virtually all' standard. For most electronics makers with globally sourced components, an unqualified claim is not supportable, but accurately qualified claims are permissible. Getting the distinction wrong can now result in civil penalties up to $50,120 per violation. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fus-ftc-made-in-usa-labeling) At a glance Standard 'All or virtually all' (FTC) Qualified claims Permitted if accurate Penalty Up to $50,120/violation CBP marking Separate requirement (§ 1304) ## Made in USA rules for electronics ### The FTC Made in USA standard The FTC's Made in USA standard requires that a product making an unqualified 'Made in USA' claim must be 'all or virtually all' made in the United States. 'All or virtually all' means that all significant parts, processing, and labour that go into the product must be of US origin. The product's final assembly must occur in the US. For most consumer electronics — which contain components sourced globally, including semiconductors, displays, batteries, and passives — meeting the unqualified standard is extremely difficult and most legitimate claims are qualified. ### Qualified Made in USA claims A qualified Made in USA claim acknowledges that the product is not entirely of US origin. Examples: 'Made in USA of domestic and imported parts', 'Assembled in USA from globally sourced components', or 'Designed in USA'. These qualified claims are permissible when they accurately describe the product's origin — but the qualification must be clear, conspicuous, and not create a false impression. The FTC scrutinises whether the US connection is genuinely meaningful to consumers or whether the claim is essentially misleading through its context. ### Electronics-specific origin complexity For electronics, the 'all or virtually all' standard is especially difficult because the global electronics supply chain is deeply integrated. A device assembled in the US from imported PCBs, imported displays, imported batteries, and imported chips almost certainly cannot make an unqualified Made in USA claim, even if significant US engineering, software, and assembly labour is involved. The FTC looks at the cost and proportion of foreign inputs as a key factor in evaluating whether the unqualified standard is met. ### CBP country of origin marking — a separate requirement The FTC Made in USA standard governs marketing claims in advertising, labelling, and promotional materials. Separately, US Customs and Border Protection (CBP) requires country of origin marking on imported goods under 19 U.S.C. § 1304 — a product manufactured abroad must be marked with its country of manufacture in a conspicuous location. These are two distinct legal requirements: a product can simultaneously bear a qualified FTC Made in USA claim on its marketing materials and a 'Made in China' country of origin mark on the product body as required by CBP. ## Compliance steps 01 Audit the origin of all significant inputs to your product: components, subassemblies, PCBs, raw materials, and the location of final assembly — this audit forms the factual basis for any Made in USA claim. 02 Apply the 'all or virtually all' test: if any significant foreign input (by cost or by the degree it contributes to the product's character) exists, an unqualified 'Made in USA' claim is likely not supportable — shift to a qualified claim. 03 Draft your qualified Made in USA claim to accurately describe the genuine US connection: 'Assembled in USA', 'Designed and engineered in USA', or 'Made in USA with globally sourced components' — the qualification must be clear and immediately adjacent to or part of the Made in USA claim. 04 Review all marketing materials, product packaging, website copy, and advertising where country of origin claims appear — the FTC standard applies to any representation that could influence a consumer's purchasing decision, not just the product label itself. 05 Confirm CBP country of origin marking compliance separately: imported electronic goods must be marked with the country of manufacture in a conspicuous, permanent location on the product — verify this is on the device body, not just the outer packaging. 06 Document the factual basis for any Made in USA claim and retain that documentation — the FTC can request substantiation for origin claims, and enforcement actions have resulted in civil penalties for unsubstantiated or misleading claims. 07 Monitor for changes in your supply chain that could affect the accuracy of your origin claim — if you switch to a foreign component source for a previously US-sourced input, re-evaluate whether your existing claim remains accurate. ## Frequently asked questions ### Can I say 'Designed in USA' if the product is manufactured abroad? Yes — 'Designed in USA' or 'Designed and engineered in the United States' are not Made in USA claims and do not need to meet the FTC's 'all or virtually all' standard. These are design origin claims and are permissible if accurate. However, they should not be presented in a way that implies the product is manufactured in the US if it is not — context matters. Claims like 'American design and engineering' alongside imagery or other signals that imply domestic manufacturing could be found deceptive. ### What are the penalties for a misleading Made in USA claim? Since 2022, the FTC can bring Made in USA enforcement actions directly (previously, it could only seek injunctive relief). Civil penalties under the Made in USA Labeling Rule can reach up to $50,120 per violation. The FTC has brought enforcement actions against electronics and consumer goods companies and has issued public warning letters. Beyond FTC penalties, state consumer protection laws (particularly California and New York) have their own Made in USA standards that can create additional exposure. ### How does the FTC standard differ from 'Buy American' government procurement rules? The FTC Made in USA standard applies to consumer marketing claims. 'Buy American' requirements under the Buy American Act and the Trade Agreements Act govern federal government procurement — they set domestic content thresholds (typically 60-65% for manufactured products, with higher thresholds increasing under recent Executive Orders) for products purchased by the US government. A product that qualifies for federal procurement under Buy American rules may still not meet the FTC's 'all or virtually all' standard for consumer marketing claims, as they are independent frameworks. ### Does the Made in USA standard apply to online advertising? Yes — the FTC Made in USA standard applies to all representations that could influence purchasing decisions, including website product pages, online advertising, social media, and email marketing. A 'Made in USA' claim on an Amazon listing, a Facebook ad, or a manufacturer's website page is equally subject to FTC scrutiny as a claim on physical packaging. The FTC has brought enforcement actions based on online made-in-USA representations. **Disclaimer:** Educational resource only. FTC Made in USA enforcement and state-level rules vary. Consult a qualified FTC/consumer protection attorney before making or modifying origin claims on your products. 🇺🇸 US roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇺🇸 US compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. 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