Compiled by Juli Case
I make bags out of a cotton fabric that isn’t made in the U.S. anymore. I sew the bags in the U.S., though, and am wondering if I can label them as “Made in the U.S.A.”?
The Federal Trade Commission (FTC) is the entity in the U.S. that enforces country of origin labeling. According to the FTC, for a product to be labeled as “Made in the U.S.A.” without any qualification, it must be “all or virtually all” made in the United States. What does “all or virtually all” mean? To quote their website, “‘all or virtually all’ means that all significant parts and processing that go into the product must be of U.S. origin.” Since the fabric is a key component in the construction of a bag, it would be incorrect to label a bag sewn in the U.S.A., but made of imported fabric, as “Made in the U.S.A.”
That said, you still have an option of identifying the bag as assembled in the U.S. This would be what the FTC calls a ‘qualified Made in the U.S.A. claim.’ To use this claim, your product must include U.S. content or processing, and that U.S. content/processing must not be overstated. In your case, something like “Made in the U.S.A. of Imported Fabric” should suffice.