Here’s some examples to help avoid confusion. A US company manufacturers and resells custom umbrella’s. The world headquarters is in the US. The materials are purchased and assembled in China, then imported to the US. A custom imprinted company logo is added in the US manufacturing plant. Because the raw materials and assembly are almost entirely in China, the umbrella’s are shipped to the US with the Made in China label.
A Chinese company has China and US manufacturing plants. The materials are manufactured in the US, and the umbrella’s are assembled and completed in the US. The umbrella’s are shipped with the Made in USA label.
A US golf bag manufacture purchases all raw materials from China and substantially modifies them to produce a product. Because significant elements are made abroad, the company cannot use Made in USA. “A product that includes foreign components may be called ‘Assembled in USA’ without qualification when its principal assembly takes place in the U.S. and the assembly is substantial. For the ‘assembly’ claim to be valid, the product’s last ‘substantial transformation’ also should have occurred in the U.S.”
- Imported products must identify the country where they were processed or manufactured.
- Products made entirely in the U.S. of materials also made in the U.S. must be labeled “Made in USA” or with an equivalent phrase.
- Products made in the U.S. of imported materials must be labeled to show the processing or manufacturing that takes place in the U.S., as well as the imported component.
- Products manufactured in part in the U.S. and in part abroad must identify both aspects. “Designed by Apple in California, Assembled in China” might fall under this category.
What is the standard for a product to be called Made in USA without qualification?
For a product to be called Made in USA, or claimed to be of domestic origin without qualifications or limits on the claim, the product must be “all or virtually all” made in the U.S. The term “United States,” as referred to in the Enforcement Policy Statement, includes the 50 states, the District of Columbia, and the U.S. territories and possessions.
What does “all or virtually all” mean?
“All or virtually all” means that all significant parts and processing that go into the product must be of U.S. origin. That is, the product should contain no — or negligible — foreign content.
Who approves Made in USA designation?
Companies self-regulate. A company doesn’t need approval from the Commission before making a Made in USA claim. As with most other advertising claims, a manufacturer or marketer may make any claim as long as it is truthful and substantiated. The Commission investigates false advertising claims.
Is there Made in USA official logo?
No. Companies often use a USA flag with Made in USA text. An enterprising for-profit company attempted to capitalize on this by making their own seal and charging companies to use it. Made in the USA Brand, LLC recently settled charges with the FTC that it deceived consumers by allowing companies to use it’s seal without either independently verifying that those companies’ products were made in the United States, or disclosing that the companies had certified themselves.
CEOgolfshop custom manufactures and is an authorized distributor for dozens of brands of promotional umbrella’s. If you need a custom umbrella, we can produce it.
Made in America Resources
The FTC is the best resource for regulatory information. Complying with the Made in USA Standard http://www.business.ftc.gov/documents/bus03-complying-made-usa-standard
Union Made in America- Check out their list of seasonal products you may be looking for. Because not every company has a union, not all products will be listed.
Looking for promotional products made in USA? Contact us at 800-CEO-1899 for all quality product needs.