FTC Closes 3D Solutech Probe: USA Raw Materials Alone Don’t Make a Filament USA-Made

The Federal Trade Commission closed its investigation of 3D printer filament maker 3D Solutech in a letter dated February 22, 2019. Staff had been concerned that the company’s marketing overstated how much of its filament is made in the USA.

The issue

According to the FTC, some of 3D Solutech’s filaments are made from USA-sourced raw materials. In many instances, though, those materials went through significant processing overseas before they became finished filament.

The letter made a key point about the FTC’s origin standard: no matter how much USA content a product has, it must have been last “substantially transformed” in the USA before it can be considered “all or virtually all” made in the United States.

The FTC also said a company may still promote true USA facts, such as employing USA workers, sourcing USA raw materials or designing products in the USA, as long as its marketing does not overstate how much of the product is made here.

How the company fixed it

• It revised its product packaging, website and social media accounts.
• Because most of its sales come through Amazon, it made batch and listing-specific changes there, including product narratives, specifications, photos and listing titles.

The FTC closed the matter without further action, the usual outcome for closing letters at the time. That approach drew growing criticism through 2019 and led to the agency’s September 2019 Made in USA workshop.

FAQ

What did the FTC say about raw materials?

USA-sourced raw materials are not enough. A product must be last substantially transformed in the USA to be called all or virtually all made in the United States.

Did 3D Solutech face a penalty?

No. The FTC closed the investigation after the company took remedial steps.

Where did the company make changes?

On its packaging, website and social media, and mostly on its Amazon listings.