Federal Trade Commission staff closed three Made in USA investigations on consecutive days in April 2018, making clear that “Built in USA” and similar phrases are judged by the same standard as “Made in USA.”
EBSCO Sign Group (April 17)
Staff was concerned that marketing overstated how much of EBSCO Sign Group’s LED signs were made in the USA. Its closing letter said unqualified “Made in USA,” “Made in America,” “Built in USA” or “Built in America” claims likely suggest a product is “all or virtually all” made in the USA. The company dropped unqualified claims, updated its materials, sent the changes to dealers and trained staff.
Mobern Lighting (April 18)
Saylite, LLC, doing business as Mobern Lighting, used “Made in USA,” “Made in America” and “Manufacturing … in the USA” claims for its lighting fixtures. Per its closing letter, Mobern revised its website, social media, catalog, product cut sheets and staff training.
Hallmark Cards (April 19)
Staff flagged “Made in USA” claims on hallmark.com for holiday puzzles that were apparently imported. In its closing letter, the FTC said Hallmark corrected the puzzle listings and reviewed every website SKU with a USA-origin claim. Hallmark also:
- Set procedures to remove a USA-origin claim from hallmark.com whenever a product’s country of origin changes.
- Added validation requirements for USA-origin claims on the site.
- Required escalation of consumer complaints about country-of-origin claims.
In each case, staff decided not to pursue the investigation further, noting that this is not a finding that no violation occurred. The FTC approved its final order against Bollman Hat Company over Made in USA and certification claims the same week; see our coverage.
FAQ
Does “Built in USA” mean something different from “Made in USA”?
No. The FTC letters said both likely suggest a product is all or virtually all made in the USA.
What did Hallmark change?
It corrected puzzle listings and added procedures to keep USA-origin claims on its website accurate.
Were there penalties?
No. Staff closed all three investigations without action.
Source & credit
Source: FTC: Closing letter to Hallmark Cards, Incorporated, April 19, 2018.
Also: FTC: Closing letter to EBSCO Sign Group, LLC, April 17, 2018; Closing letter to Saylite, LLC (Mobern Lighting), April 18, 2018; Lexology: “Made, Built, or Manufactured in the USA?”.