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Made in USA Clothing Labels: FTC Rules for Fashion Brands

Updated 20 Oct 20264 min readNot legal advice

Last updated: October 20, 2026

A clothing brand can use an unqualified "Made in USA" claim only if the product is made in the United States from components that are all or virtually all U.S.-made. Final assembly in the U.S. is not enough by itself. Enforcement has intensified in 2026, which makes this one of the riskiest phrases on a product page.

The FTC standard: "all or virtually all"

The FTC's Made in USA Labeling Rule (16 CFR Part 323), finalized in 2021, codifies the "all or virtually all" standard for labels. In practice, final assembly or processing must take place in the U.S., all significant processing must happen in the U.S., and all or virtually all of the product's components must be made and sourced in the U.S. Violations of the rule can bring civil penalties of up to roughly $53,000 per violation.

Why assembly in the U.S. is not enough

A T-shirt sewn in Los Angeles from fabric woven in Asia does not meet the standard for an unqualified claim. Fabric, yarn and other significant inputs matter, as does where significant processing takes place. Such a shirt can often be described accurately with a qualified claim instead.

Qualified claims that can be accurate

  • "Made in USA with imported fabric"
  • "Assembled in USA from imported components"
  • "Designed in USA" (a design claim, not an origin claim, and best kept clearly separate from origin wording)

Qualified claims must be clear, prominent and truthful. The Textile Act also has its own origin wording for U.S.-made goods that use imported fabric.

What changed in 2026

  • March 13, 2026: an executive order directed the FTC to prioritize enforcement against false "Made in USA" claims. It does not change the standard itself.
  • April 14, 2026: the FTC announced three enforcement actions, including a footwear company, and reported the largest monetary recovery to date under the Labeling Rule.
  • Earlier cases included an apparel company that replaced "Made in China" tags with "Made in USA" labels.
  • Class action lawyers also bring claims based on origin labeling, and California has its own, more flexible threshold that allows limited foreign content, so meeting California's test does not satisfy the FTC.

The executive order also called for exploring rules that would require online marketplaces to verify sellers' origin claims, so expect more scrutiny of listings.

How to substantiate a Made in USA claim

  1. Map the supply chain for each style, from fiber to final assembly.
  2. Obtain written statements from fabric, trim and sewing suppliers about where each input was made.
  3. Identify where significant processing happens.
  4. Keep records so that you can answer an FTC inquiry quickly.
  5. If any significant input is imported, use a qualified claim or no origin claim.

Where to audit your claims

The rule covers the product label, but the FTC also treats misleading marketing as deception. Check:

  • [ ] Garment labels and hangtags
  • [ ] Product titles, descriptions and badges on Shopify
  • [ ] Collection pages and navigation menus (for example, a "Made in USA" collection)
  • [ ] Meta titles and descriptions
  • [ ] Marketplace listings, ads and social posts
  • [ ] Packaging and email templates

Frequently asked questions

Can I say Made in USA if the last step happens here? Not unless the all-or-virtually-all standard is met. Consider a qualified claim.

Is "Assembled in USA" safe? It can be accurate if the assembly claim is true and the wording makes clear the parts may be imported.

Does California's rule help? No. The FTC standard still applies to sales across the U.S.

Do I need paperwork? The FTC says the rule creates no new recordkeeping duty, but you need proof to defend a claim.

Related guides

This article is general information, not legal advice.

Sources

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