FTC staff closed its review of General Pencil Company’s Made in USA marketing in a letter dated August 9, 2024, after the company agreed to fix claims that overstated how much of its line is made in the USA.
The concern
Staff said General Pencil’s marketing made broad references to its history of making pencils in the USA without saying that it now also sells some imported products, and that other products contain significant imported materials.
What General Pencil did
- Updated its websites, invoices, packaging and social media.
- Notified distributors and retailers.
- Withheld ad allowances from marketers that did not update claims on time.
- Contacted third-party sellers still using outdated claims.
The lesson
The letter says a line-wide claim such as “Our products are Made in USA” should not be used when only some products qualify. Companies can still promote their USA history, jobs and processes, or use qualified claims like “Made in USA of Imported Parts” or “Assembled in USA” when they fit.
The FTC said closing the review is not a finding that no violation occurred.
FAQ
Was General Pencil fined?
No. FTC staff closed the review after the company took corrective action.
What was the problem?
Marketing suggested its whole line was made in the USA when some products are imported or use significant imported materials.
Can a company still talk about its USA history?
Yes, as long as it does not imply products are made in the USA when they are not.
Source & credit
Source: FTC closing letter to counsel for General Pencil Company, August 9, 2024: General Pencil closing letter (PDF).