Using Domestically Sourced Recycled Content? Look Beyond the Recycling Process

We periodically stumble across older FTC investigations that have new relevance, and post about them as reminders. That happened recently as we get more questions about the use of recycled content and the desire to tout U.S.-based manufacturing. Although the FTC’s Enforcement Policy Statement and regulation regarding Made in USA claims do not mention how to evaluate recycled content, in a 2014 FTC Staff Advisory Opinion the Staff declined to consider the recycling process as a ​“new life cycle” and disregard the origin of the jewelry returned for recycling.