---
title: Made in USA Closing Letter Addresses Retailer Obligations
date: 2022-02-28T00:00:00-05:00
author: "hilary@usesharepoint.com"
canonical_url: "https://www.kelleydrye.com/viewpoints/podcasts/ad-law-access/made-in-usa-closing-letter-addresses-retailer-obligations"
section: Podcast Episodes
---
# Made in USA Closing Letter Addresses Retailer Obligations

 February 28, 2022 | 2 min

 

 

 

 

 

 

 [Kelley Drye Ad Law Access Podcast](https://soundcloud.com/adlawaccess "Kelley Drye Ad Law Access Podcast") · [Made in USA Closing Letter Addresses Retailer Obligations](https://soundcloud.com/adlawaccess/made-in-usa-closing-letter "Made in USA Closing Letter Addresses Retailer Obligations")

 [Apple](https://podcasts.apple.com/us/podcast/made-in-usa-closing-letter-addresses-retailer-obligations/id1457734764?i=1000552456440) [Spotify](https://open.spotify.com/episode/0lBqU4m12SQf3QRLqPOkln?si=5ef128af4a5a48d0) [SoundCloud](https://soundcloud.com/adlawaccess/made-in-usa-closing-letter?utm_source=clipboard&utm_medium=text&utm_campaign=social_sharing) 

 

An FTC rule prohibits companies from stating or implying that a product is made in the USA unless: (1) the final assembly or processing of the product occurs in the USA; (2) all significant processing that goes into the product occurs in the USA; and (3) all or virtually all ingredients or components are made or sourced in the USA. It can be a challenge to figure out whether a product you make meets that standard, but it’s even harder to figure that out for products you didn’t make.

This month, the FTC published a closing letter in an investigation about ​“Made in USA” claims that Crate and Barrel made about various products that were made by other companies. Although the case doesn’t break new ground, the steps that Crate and Barrel promised to take related to ​“Made in USA” claims on its site could provide some helpful guidance about what the FTC expects retailers to do when making claims about other companies’ products.

 

 

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