text: Marketers and manufacturers that promote their products as Made in USA must meet the “all or virtually all” standard. This publication offers practical guidance on Made in USA claims. 
   
   Introduction 
   
   The Federal Trade Commission (FTC) is charged with preventing deception and unfairness in the marketplace. The FTC Act gives the Commission the power to bring law enforcement actions against false or misleading claims that a product is of U.S. origin. Traditionally, the Commission has required that a product advertised as Made in USA be "all or virtually all" made in the U.S. After a comprehensive review of Made in USA and other U.S. origin claims in product advertising and labeling, the Commission announced in December 1997 that it would retain the "all or virtually all" standard. The Commission also issued an Enforcement Policy Statement on U.S. Origin Claims to provide guidance to marketers who want to make an unqualified Made in USA claim under the "all or virtually all" standard and those who want to make a qualified Made in USA claim. 
   
   This publication provides additional guidance about how to comply with the "all or virtually all" standard. It also offers some general information about the U.S. Customs Service’s requirement that all products of foreign origin imported into the U.S. be marked with the name of the country of origin. 
   
   This publication is the Federal Trade Commission staff’s view of the law’s requirements. It is not binding on the Commission. The Enforcement Policy Statement issued by the FTC is at the end of the publication. 
   
   Basic Information About Made In USA Claims 
   
   Must U.S. content be disclosed on products sold in the U.S.? 
   
   U.S. content must be disclosed on automobiles and textile, wool, and fur products. There’s no law that requires most other products sold in the U.S. to be marked or labeled Made in USA or have any other disclosure about their amount of U.S. content. However, manufacturers and marketers who choose to make claims about the amount of U.S. content in their products must comply with the FTC’s Made in USA policy. 
   
   What products does the FTC’s Made in USA policy apply to? 
   
   The policy applies to all products advertised or sold in the U.S., except for those specifically subject to country-of-origin labeling by other laws. Other countries may have their own country-of-origin marking requirements. As a result, exporters should determine whether the country to which they are exporting imposes such requirements. 
   
   What kinds of claims does the Enforcement Policy Statement apply to? 
   
   The Enforcement Policy Statement applies to U.S. origin claims that appear on products and labeling, advertising, and other promotional materials. It also applies to all other forms of marketing, including marketing through digital or electronic mechanisms, such as Internet or e-mail. 
   
   A Made in USA claim can be express or implied. 
   
   Examples of express claims: Made in USA. "Our products are American-made." "USA." 
   
   In identifying implied claims, the Commission focuses on the overall impression of the advertising, label, or promotional material. Depending on the context, U.S. symbols or geographic references (for example, U.S. flags, outlines of U.S. maps, or references to U.S. locations of headquarters or factories) may convey a claim of U.S. origin either by themselves, or in conjunction with other phrases or images. 
   
   Example: A company promotes its product in an ad that features a manager describing the "true American quality" of the work produced at the company’s American factory. Although there is no express representation that the company’s product is made in the U.S., the overall — or net — impression the ad is likely to convey to consumers is that the product is of U.S. origin. 
   
   Brand names and trademarks 
   
   Ordinarily, the Commission will not consider a manufacturer or marketer’s use of an American brand name or trademark by itself as a U.S. origin claim. Similarly, the Commission is not likely to interpret the mere listing of a company’s U.S. address on a package label in a non-prominent way as a claim of U.S. origin. 
   
   Example: A product is manufactured abroad by a well-known U.S. company. The fact that the company is headquartered in the U.S. also is widely known. Company pamphlets for its foreign-made product prominently feature its brand name. Assuming that the brand name does not specifically denote U.S. origin (that is, the brand name is not "Made in America, Inc."), using the brand name by itself does not constitute a claim of U.S. origin. 
   
   Representations about entire product lines 
   
   Manufacturers and marketers should not indicate, either expressly or implicitly, that a whole product line is of U.S. origin ("Our products are made in USA") when only some products in the product line are made in the U.S. according to the "all or virtually all" standard. 
   
   Does the FTC pre-approve Made in USA claims? 
   
   The Commission does not pre-approve advertising or labeling claims. A company doesn’t need approval from the Commission before making a Made in USA claim. As with most other advertising claims, a manufacturer or marketer may make any claim as long as it is truthful and substantiated. 
   
   The Standard For Unqualified Made In USA Claims 
   
   What is the standard for a product to be called Made in USA without qualification? 
   
   For a product to be called Made in USA, or claimed to be of domestic origin without qualifications or limits on the claim, the product must be "all or virtually all" made in the U.S. The term "United States," as referred to in the Enforcement Policy Statement, includes the 50 states, the District of Columbia, and the U.S. territories and possessions. 
   
   What does "all or virtually all" mean? 
   
   "All or virtually all" means that all significant parts and processing that go into the product must be of U.S. origin. That is, the product should contain no — or negligible — foreign content. 
   
   What substantiation is required for a Made in USA claim? 
   
   When a manufacturer or marketer makes an unqualified claim that a product is Made in USA, it should have — and rely on — a "reasonable basis" to support the claim at the time it is made. This means a manufacturer or marketer needs competent and reliable evidence to back up the claim that its product is "all or virtually all" made in the U.S. 
   
   What factors does the Commission consider to determine whether a product is "all or virtually all" made in the U.S.? 
   
   The product’s final assembly or processing must take place in the U.S. The Commission then considers other factors, including how much of the product’s total manufacturing costs can be assigned to U.S. parts and processing, and how far removed any foreign content is from the finished product. In some instances, only a small portion of the total manufacturing costs are attributable to foreign processing, but that processing represents a significant amount of the product’s overall processing. The same could be true for some foreign parts. In these cases, the foreign content (processing or parts) is more than negligible, and, as a result, unqualified claims are inappropriate. 
   
   Example: A company produces propane barbecue grills at a plant in Nevada. The product’s major components include the gas valve, burner and aluminum housing, each of which is made in the U.S. The grill’s knobs and tubing are imported from Mexico. An unqualified Made in USA claim is not likely to be deceptive because the knobs and tubing make up a negligible portion of the product’s total manufacturing costs and are insignificant parts of the final product. Example: A table lamp is assembled in the U.S. from American-made brass, an American-made Tiffany-style lampshade, and an imported base. The base accounts for a small percent of the total cost of making the lamp. An unqualified Made in USA claim is deceptive for two reasons: The base is not far enough removed in the manufacturing process from the finished product to be of little consequence and it is a significant part of the final product. 
   
   What items should manufacturers and marketers include in analyzing the percentage of domestic content in a particular product? 
   
   Manufacturers and marketers should use the cost of goods sold or inventory costs of finished goods in their analysis. Such costs generally are limited to the total cost of all manufacturing materials, direct manufacturing labor, and manufacturing overhead. 
   
   Should manufacturers and marketers rely on information from American suppliers about the amount of domestic content in the parts, components, and other elements they buy and use for their final products? 
   
   If given in good faith, manufacturers and marketers can rely on information from suppliers about the domestic content in the parts, components, and other elements they produce. Rather than assume that the input is 100 percent U.S.-made, however, manufacturers and marketers would be wise to ask the supplier for specific information about the percentage of U.S. content before they make a U.S. origin claim. 
   
   Example: A company manufactures food processors in its U.S. plant, making most of the parts, including the housing and blade, from U.S. materials. The motor, which constitutes 50 percent of the food processor’s total manufacturing costs, is bought from a U.S. supplier. The food processor manufacturer knows that the motor is assembled in a U.S. factory. Even though most of the parts of the food processor are of U.S. origin, the final assembly is in the U.S., and the motor is assembled in the U.S., the food processor is not considered "all or virtually all" American-made if the motor itself is made of imported parts that constitute a significant percentage of the appliance’s total manufacturing cost. Before claiming the product is Made in USA, this manufacturer should look to its motor supplier for more specific information about the motor’s origin. Example: On its purchase order, a company states: "Our company requires that suppliers certify the percentage of U.S. content in products supplied to us. If you are unable or unwilling to make such certification, we will not purchase from you." Appearing under this statement is the sentence, "We certify that our ___ have at least ___% U.S. content," with space for the supplier to fill in the name of the product and its percentage of U.S. content. The company generally could rely on a certification like this to determine the appropriate country-of-origin designation for its product. 
   
   How far back in the manufacturing process should manufacturers and marketers look? 
   
   To determine the percentage of U.S. content, manufacturers and marketers should look back far enough in the manufacturing process to be reasonably sure that any significant foreign content has been included in their assessment of foreign costs. Foreign content incorporated early in the manufacturing process often will be less significant to consumers than content that is a direct part of the finished product or the parts or components produced by the immediate supplier. 
   
   Example: The steel used to make a single component of a complex product (for example, the steel used in the case of a computer’s floppy drive) is an early input into the computer’s manufacture, and is likely to constitute a very small portion of the final product’s total cost. On the other hand, the steel in a product like a pipe or a wrench is a direct and significant input. Whether the steel in a pipe or wrench is imported would be a significant factor in evaluating whether the finished product is "all or virtually all" made in the U.S. 
   
   Are raw materials included in the evaluation of whether a product is "all or virtually all" made in the U.S.? 
   
   It depends on how much of the product’s cost the raw materials make up and how far removed from the finished product they are. 
   
   Example: If the gold in a gold ring is imported, an unqualified Made in USA claim for the ring is deceptive. That’s because of the significant value the gold is likely to represent relative to the finished product, and because the gold — an integral component — is only one step back from the finished article. By contrast, consider the plastic in the plastic case of a clock radio otherwise made in the U.S. of U.S.-made components. If the plastic case was made from imported petroleum, a Made in USA claim is likely to be appropriate because the petroleum is far enough removed from the finished product, and is an insignificant part of it as well. 
   
   Qualified Claims 
   
   What is a qualified Made in USA claim? 
   
   A qualified Made in USA claim describes the extent, amount or type of a product’s domestic content or processing; it indicates that the product isn’t entirely of domestic origin. 
   
   Example: "60% U.S. content." "Made in USA of U.S. and imported parts." "Couch assembled in USA from Italian Leather and Mexican Frame." 
   
   When is a qualified Made in USA claim appropriate? 
   
   A qualified Made in USA claim is appropriate for products that include U.S. content or processing but don’t meet the criteria for making an unqualified Made in USA claim. Because even qualified claims may imply more domestic content than exists, manufacturers or marketers must exercise care when making these claims. That is, avoid qualified claims unless the product has a significant amount of U.S. content or U.S. processing. A qualified Made in USA claim, like an unqualified claim, must be truthful and substantiated. 
   
   Example: An exercise treadmill is assembled in the U.S. The assembly represents significant work and constitutes a "substantial transformation" (a term used by the U.S. Customs Service). All of the treadmill’s major parts, including the motor, frame, and electronic display, are imported. A few of its incidental parts, such as the handle bar covers, the plastic on/off power key, and the treadmill mat, are manufactured in the U.S. Together, these parts account for approximately three percent of the total cost of all the parts. Because the value of the U.S.-made parts is negligible compared to the value of all the parts, a claim on the treadmill that it is "Made in USA of U.S. and Imported Parts" is deceptive. A claim like "Made in U.S. from Imported Parts" or "Assembled in U.S.A." would not be deceptive. 
   
   U.S. origin claims for specific processes or parts 
   
   Claims that a particular manufacturing or other process was performed in the U.S. or that a particular part was manufactured in the U.S. must be truthful, substantiated, and clearly refer to the specific process or part, not to the general manufacture of the product, to avoid implying more U.S. content than exists. 
   
   Manufacturers and marketers should be cautious about using general terms, such as "produced," "created" or "manufactured" in the U.S. Words like these are unlikely to convey a message limited to a particular process. Additional qualification probably is necessary to describe a product that is not "all or virtually all" made in the U.S. 
   
   In addition, if a product is of foreign origin (that is, it has been substantially transformed abroad), manufacturers and marketers also should make sure they satisfy Customs’ markings statute and regulations that require such products to be marked with a foreign country of origin. Further, Customs requires the foreign country of origin to be preceded by "Made in," "Product of," or words of similar meaning when any city or location that is not the country of origin appears on the product. 
   
   Example: A company designs a product in New York City and sends the blueprint to a factory in Finland for manufacturing. It labels the product "Designed in USA — Made in Finland." Such a specific processing claim would not lead a reasonable consumer to believe that the whole product was made in the U.S. The Customs Service requires the product to be marked "Made in," or "Product of" Finland since the product is of Finnish origin and the claim refers to the U.S. Examples of other specific processing claims are: "Bound in U.S. — Printed in Turkey." "Hand carved in U.S. — Wood from Philippines." "Software written in U.S. — Disk made in India." "Painted and fired in USA. Blanks made in (foreign country of origin)." Example: A company advertises its product, which was invented in Seattle and manufactured in Bangladesh, as "Created in USA." This claim is deceptive because consumers are likely to interpret the term "Created" as Made in USA — an unqualified U.S. origin claim. Example: A computer imported from Korea is packaged in the U.S. in an American-made corrugated paperboard box containing only domestic materials and domestically produced expanded rigid polystyrene plastic packing. Stating Made in USA on the package would deceive consumers about the origin of the product inside. But the company could legitimately make a qualified claim, such as "Computer Made in Korea — Packaging Made in USA." Example: The Acme Camera Company assembles its cameras in the U.S. The camera lenses are manufactured in the U.S., but most of the remaining parts are imported. A magazine ad for the camera is headlined "Beware of Imported Imitations" and states "Other high-end camera makers use imported parts made with cheap foreign labor. But at Acme Camera, we want only the highest quality parts for our cameras and we believe in employing American workers. That’s why we make all of our lenses right here in the U.S." This ad is likely to convey that more than a specific product part (the lens) is of U.S. origin. The marketer should be prepared to substantiate the broader U.S. origin claim conveyed to consumers viewing the ad. 
   
   Comparative Claims 
   
   Comparative claims should be truthful and substantiated, and presented in a way that makes the basis for comparison clear (for example, whether the comparison is to another leading brand or to a previous version of the same product). They should truthfully describe the U.S. content of the product and be based on a meaningful difference in U.S. content between the compared products. 
   
   Example: An ad for cellular phones states "We use more U.S. content than any other cellular phone manufacturer." The manufacturer assembles the phones in the U.S. from American and imported components and can substantiate that the difference between the U.S. content of its phones and that of the other manufacturers’ phones is significant. This comparative claim is not deceptive. Example: A product is advertised as having "twice as much U.S. content as before." The U.S. content in the product has been increased from 2 percent in the previous version to 4 percent in the current version. This comparative claim is deceptive because the difference between the U.S. content in the current and previous version of the product are insignificant. 
   
   Assembled in USA Claims 
   
   A product that includes foreign components may be called "Assembled in USA" without qualification when its principal assembly takes place in the U.S. and the assembly is substantial. For the "assembly" claim to be valid, the product’s last "substantial transformation" also should have occurred in the U.S. That’s why a "screwdriver" assembly in the U.S. of foreign components into a final product at the end of the manufacturing process doesn’t usually qualify for the "Assembled in USA" claim. 
   
   Example: A lawn mower, composed of all domestic parts except for the cable sheathing, flywheel, wheel rims and air filter (15 to 20 percent foreign content) is assembled in the U.S. An "Assembled in USA" claim is appropriate. Example: All the major components of a computer, including the motherboard and hard drive, are imported. The computer’s components then are put together in a simple "screwdriver" operation in the U.S., are not substantially transformed under the Customs Standard, and must be marked with a foreign country of origin. An "Assembled in U.S." claim without further qualification is deceptive. 
   
   The FTC and The Customs Service 
   
   What is the U.S. Customs Service’s jurisdiction over country-of-origin claims? 
   
   The Tariff Act gives Customs and the Secretary of the Treasury the power to administer the requirement that imported goods be marked with a foreign country of origin (for example, "Made in Japan"). 
   
   When an imported product incorporates materials and/or processing from more than one country, Customs considers the country of origin to be the last country in which a "substantial transformation" took place. Customs defines "substantial transformation" as a manufacturing process that results in a new and different product with a new name, character, and use that is different from that which existed before the change. Customs makes country-of-origin determinations using the "substantial transformation" test on a case-by-case basis. In some instances, Customs uses a "tariff shift" analysis, comparable to "substantial transformation," to determine a product’s country of origin. 
   
   What is the interaction between the FTC and Customs regarding country-of-origin claims? 
   
   Even if Customs determines that an imported product does not need a foreign country-of-origin mark, it is not necessarily permissible to promote that product as Made in USA. The FTC considers additional factors to decide whether a product can be advertised or labeled as Made in USA. 
   
   Manufacturers and marketers should check with Customs to see if they need to mark their products with the foreign country of origin. If they don’t, they should look at the FTC’s standard to check if they can properly make a Made in USA claim. 
   
   The FTC has jurisdiction over foreign origin claims on products and in packaging that are beyond the disclosures required by Customs (for example, claims that supplement a required foreign origin marking to indicate where additional processing or finishing of a product occurred). 
   
   The FTC also has jurisdiction over foreign origin claims in advertising and other promotional materials. Unqualified U.S. origin claims in ads or other promotional materials for products that Customs requires a foreign country-of-origin mark may mislead or confuse consumers about the product’s origin. To avoid misleading consumers, marketers should clearly disclose the foreign manufacture of a product. 
   
   Example: A television set assembled in Korea using an American-made picture tube is shipped to the U.S. The Customs Service requires the television set to be marked "Made in Korea" because that’s where the television set was last "substantially transformed." The company’s World Wide Web page states "Although our televisions are made abroad, they always contain U.S.-made picture tubes." This statement is not deceptive. However, making the statement "All our picture tubes are made in the USA" — without disclosing the foreign origin of the television’s manufacture — might imply a broader claim (for example, that the television set is largely made in the U.S.) than could be substantiated. That is, if the statement and the entire ad imply that any foreign content or processing is negligible, the advertiser must substantiate that claim or net impression. The advertiser in this scenario would not be able to substantiate the implied Made in USA claim because the product was "substantially transformed" in Korea. 
   
   Other Statutes 
   
   What are the requirements of other federal statutes relating to country-of-origin determinations? 
   
   Textile Fiber Products Identification Act and Wool Products Labeling Act — Require a Made in USA label on most clothing and other textile or wool household products if the final product is manufactured in the U.S. of fabric that is manufactured in the U.S., regardless of where materials earlier in the manufacturing process (for example, the yarn and fiber) came from. Textile products that are imported must be labeled as required by the Customs Service. A textile or wool product partially manufactured in the U.S. and partially manufactured in another country must be labeled to show both foreign and domestic processing. 
   
   On a garment with a neck, the country of origin must be disclosed on the front of a label attached to the inside center of the neck — either midway between the shoulder seams or very near another label attached to the inside center of the neck. On a garment without a neck, and on other kinds of textile products, the country of origin must appear on a conspicuous and readily accessible label on the inside or outside of the product. 
   
   Catalogs and other mail order promotional materials for textile and wool products, including those disseminated on the Internet, must disclose whether a product is made in the U.S., imported or both. 
   
   The Fur Products Labeling Act requires the country of origin of imported furs to be disclosed on all labels and in all advertising. For copies of the Textile, Wool or Fur Rules and Regulations, or the new business education guide on labeling requirements, call the FTC’s Consumer Response Center 
   
   (202-382-4357). Or visit the FTC online at www.ftc.gov. Click on Consumer Protection. 
   
   American Automobile Labeling Act — Requires that each automobile manufactured on or after October 1, 1994, for sale in the U.S. bear a label disclosing where the car was assembled, the percentage of equipment that originated in the U.S. and Canada, and the country of origin of the engine and transmission. Any representation that a car marketer makes that is required by the AALA is exempt from the Commission’s policy. When a company makes claims in advertising or promotional materials that go beyond the AALA requirements, it will be held to the Commission’s standard. For more information, call the Consumer Programs Division of the National Highway Traffic Safety Administration (202-366-0846). 
   
   Buy American Act — Requires that a product be manufactured in the U.S. of more than 50 percent U.S. parts to be considered Made in USA for government procurement purposes. For more information, review the Buy American Act at 41 U.S.C. §§ 10a-10c, the Federal Acquisition Regulations at 48 C.F.R. Part 25, and the Trade Agreements Act at 19 U.S.C. §§ 2501-2582. 
   
   What To Do About Violations 
   
   What if I suspect noncompliance with the FTC’s Made in USA standard or other country-of-origin mislabeling? 
   
   Information about possible illegal activity helps law enforcement officials target companies whose practices warrant scrutiny. If you suspect noncompliance, contact the Division of Enforcement, Bureau of Consumer Protection, Federal Trade Commission, Washington, DC 20580; (202) 326-2996 or send an e-mail to MUSA@ftc.gov. If you know about import or export fraud, call Customs’ toll-free Commercial Fraud Hotline, 1-800-ITS-FAKE. Examples of fraudulent practices involving imports include removing a required foreign origin label before the product is delivered to the ultimate purchaser (with or without the improper substitution of a Made in USA label) and failing to label a product with a required country of origin. 
   
   You also can contact your state Attorney General and your local Better Business Bureau to report a company. Or you can refer your complaint to the National Advertising Division (NAD) of the Council of Better Business Bureaus by calling (212) 754-1320. NAD handles complaints about the truth and accuracy of national advertising. You can reach the Council of Better Business Bureaus on the web at adweb.com/adassoc17.html. 
   
   Finally, the Lanham Act gives any person (such as a competitor) who is damaged by a false designation of origin the right to sue the party making the false claim. Consult a lawyer to see if this private right of action is an appropriate course of action for you. 
   
   For More Information 
   
   The FTC works for the consumer to prevent fraudulent, deceptive, and unfair business practices in the marketplace and to provide information to help consumers spot, stop, and avoid them. To file a complaint or to get free information on consumer issues, visit ftc.gov or call toll-free, 1-877-FTC-HELP (1-877-382-4357); TTY: 1-866-653-4261. The FTC enters consumer complaints into the Consumer Sentinel Network, a secure online database and investigative tool used by hundreds of civil and criminal law enforcement agencies in the U.S. and abroad. ||||| Perhaps Walmart’s products aren’t as patriotic as they claim 
   
   According to a report recently released by the advertising watchdog group, Truth in Advertising, over 100 products labeled on Walmart’s website as “Made in the USA” are, in fact, imported from other countries. 
   
   The report found that both Walmart’s store brand products, such as Equate makeup sponges and tooth whitening strips, as well as other brands, such as Almay eyeliner, were falsely labeled as made in the United States. 
   
   
   
   Some products clearly displayed contrary information, such as a red, white, and blue “made in the USA” logo on the front, with the words “Made in China” displayed on the back. Other products were stamped with the patriotic logo while the product specifications listed the item as imported. 
   
   Walmart had an excuse, but the labels are magically gone 
   
   While there is no official certification process for labeling a product “made in the USA,” a company can still be sued for false advertising if they misuse the label. However, rather than taking legal action, Truth in Advertising simply sent a letter to Walmart CEO, Doug McMillon, causing the retail chain some embarrassment, but sparing them the court room drama. 
   
   Walmart responded by saying that some manufacturing of its store brands had recently moved to the United States, but the website hadn’t been update yet. However, many Made in USA labels were removed from the website after Truth in Advertising’s letter went public. As for other brands, Walmart claims that the country of origin information comes from the supplier. 
   
   Great reminder to stay honest 
   
   Unimpressed by these excuses, executive direction of Truth in Advertising, Bonnie Patten, says that the “largest retailer in the world should have made sure its American-made claims were accurate before affixing made in USA labels on the products. Until Walmart cleans up this mess, consumers cannot rely on Walmart with regard to where a product is really made when shopping on the site.” 
   
   The report also argues that the website’s labels for “Made in USA” and “Assembled in USA,” with their tiny fonts and identical color schemes, are too similar to distinguish on the website, even though the Federal Trade Commission makes a clear differentiation between these two labels. 
   
   All of this is an important reminder for businesses to stay honest in advertising. All it takes is a watchdog with an internet connection and keen eye to uncover false claims. ||||| While there is no official review process required for labeling a product as “Made in the U.S.A.,” a company can get into legal trouble for misusing that label, as doing so may constitute false advertising. A new report from an advertising watchdog group claims that Walmart’s website has more than 100 examples of products incorrectly marketed as made in America. 
   
   According to a letter [PDF] recently sent by the group Truth In Advertising to Walmart CEO Doug McMillon, “Walmart’s website is mired in USA labeling errors.” 
   
   Among the items singled out in the letter are Walmart’s Equate store-brand makeup sponges in the image at the top of this story. TINA says these were given the Made in the U.S.A. label on Walmart.com even though the product’s own packaging clearly states that they were “Made in China.” 
   
   Another Equate-brand product called out by TINA are these teeth-whitening strips that the company simultaneously lists as made in America while declaring in the product details that they are imported form outside the country: 
   
   
   
   In response to the TINA letter, Walmart told the group that manufacturing for both of these products was recently moved to the U.S. but that some stores may still contain versions made overseas and not all the information on the website is correct. Regardless, both items no longer carry the patriotic marketing message. 
   
   It wasn’t just store-brand items that got the false “Made in U.S.A.” labels, according to the report. TINA’s letter gives the example of an Almay eyeliner that states the product is made and assembled here in the U.S., even though the packaging declares that it is “Made in Germany.” Walmart says that the country of origin information comes from the supplier. 
   
   “False made in USA labeling on Walmart’s website has misled consumers looking to purchase American-made products,’’ said TINA.org Executive Director Bonnie Patten. “The largest retailer in the world should have made sure its American-made claims were accurate before affixing made in USA labels on the products. Until Walmart cleans up this mess, consumers cannot rely on Walmart with regard to where a product is really made when shopping on the site.” 
   
   ============ 
   
   UPDATE: When reached for comment, a rep for Walmart provided the following statement to Consumerist — 
   
   “We are continually working to improve our website listings and information. We are undertaking a more extensive quality assurance review to help eliminate these coding errors. Based on our initial internal review, we believe these errors are limited to a small percentage of items and we are confident in the overall integrity of the information on our website.” 
   
   ============ 
   
   A more detailed report [PDF] commissioned by TINA looked at the actual “Made in the U.S.A.” labeling on Walmart.com and found a number of issues. 
   
   This report noted that Walmart does little to differentiate its “Made in the U.S.A.” label from its “Assembled in the U.S.A.” label, even though the two labels have very different standards in the eyes of the Federal Trade Commission. 
   
   “The legibility of the text at the top of the label, which can be either ‘Made in the’ or ‘Assembled in the’, is marginal even for people with excellent or corrected vision, due both to the text’s small size and the low contrast of light blue text on a white background,” writes the report’s author, Dr. Jeff Johnson, who notes that the problem is exacerbated for farsighted people or those looking at the site on a small-format screen. “If such people have not seen it earlier in larger format (e.g., on a product page), they would be unable to determine what it says. Even consumers who have seen that text already in larger format would, in search results, have trouble distinguishing ‘Made in the USA’ from ‘Assembled in the USA’.”
target: – An advertising watchdog group warns you to beware of patriotic "Made in the USA" labels on some Walmart products, saying the company uses them far too liberally. The group Truth In Advertising sent Walmart CEO Doug McMillon a letter last week saying that "Walmart's website is mired in USA labeling errors," and ran down a few examples, per the Consumerist: The company's store brand Equate Beauty Wedge Applicator Sponges, formerly labeled "Made in the USA" on the website, "are made in China according to the product packaging," the letter says. Some "USA" labels conflict with the product information on the same Web page, according to the letter—including Equate 7 Day Dental Whitening System Advanced Whitening Wraps (imported) and Almay Intense I-color Liquid Eye Liner (made in Germany). Some USA labels ignore the fact that the product is only partly made, or is assembled rather than made, in the US, the letter adds. "False made in USA labeling on Walmart’s website has misled consumers looking to purchase American-made products," says TINA.org Executive Director Bonnie Patten. In response, Walmart says the two Equate products only recently located in the US—yet the "Made in the USA" label on them is now gone, the Consumerist notes. Walmart adds that it's undertaking "a more extensive quality assurance review" of its website. While there's no official standard for "Made in the USA" labeling, companies can get sued over it for false advertising, AGBeat reports. Click to see a more extensive TINA review of Walmart's "USA" labeling.