The FTC “all or virtually all” standard, explained
If you advertise “Made in USA,” one FTC phrase decides whether you're compliant: “all or virtually all.” Here's what it actually means for an online store — in plain English.
Unqualified claims: the high bar
An unqualified claim — “Made in USA,” “American made,” a US flag with no caveat — tells customers the product is all or virtually all made in the United States. In practice that means:
- Final assembly or processing happens in the US;
- All significant processing happens in the US; and
- All or virtually all components and inputs are US-origin.
And the burden is on you: the FTC expects you to have competent and reliable evidence on file before the claim runs — supplier certifications of domestic content, a bill of materials, and so on.
The penalty
Violations of the Made in USA Labeling Rule carry civil penalties of up to $53,088 per violation. In 2026, following a March executive order, the FTC ran an enforcement sweep with multiple actions — and signaled that online marketplaces and their sellers are in scope.
Qualified claims: the safe path
If some of your content is imported, don't drop the American story — qualify it accurately and conspicuously:
- “Assembled in USA” — assembly happens here.
- “Made in USA from imported parts” — built here, some inputs imported.
- “Made in USA from imported and domestic components”.
Qualified claims are perfectly fine when truthful. The qualification just has to be clear and close to the claim — not buried in a footnote.
Implied claims count too
It isn't only the words. US flags, “American craftsmanship,” eagles, red-white-and-blue framing — implied origin claims are held to the same standard. If the overall impression is “this is American-made,” you need to be able to back it up.
General information, not legal advice. An FTC determination is fact-specific; consult counsel for your situation.