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FTC Announces ‘Made in the USA’ Enforcement Sweep 1 Month after Trump Administration Issues Related Executive Order

By Timothy A. Butler, Cody B. Davis, Matthew White & Tessa Cierny on May 14, 2026
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American flag waving in front of the White House

On April 14, 2026, the Federal Trade Commission announced a coordinated “Made in the USA” enforcement sweep, including three settlements and two investigation closing letters concerning “Made in America,” “Made in the USA,” and similar U.S.-origin claims. The announcement follows an Executive Order the Trump administration issued on March 13, 2026 (See April 2026 GT Alert) that directed the FTC and other federal agencies to protect both consumers and legitimate U.S. manufacturers, including by prioritizing enforcement actions for improper “Made in America” claims.

Link to The Enforcement Actions The Enforcement Actions

The FTC announced three settlements with companies that allegedly violated Section 5(a) of the FTC Act[1] and the Made in the USA Labeling Rule[2] by making unqualified statements that their products were “Made in the USA,” despite relying on foreign manufacturers for component parts. One of the settlements also resolved alleged violations of the Textile Fiber Products Identification Act and related rules.[3] In total, the companies agreed to pay a collective $867,743 toward consumer redress.

  • FTC reaches settlement with manufacturer and seller of electronic dartboards advertised as “Made in the USA.” The FTC sued the company in federal court, alleging violations of Section 5(a) of the FTC Act and the Made in the USA Labeling Rule. According to the FTC, the company made unqualified claims to consumers that its electronic dartboards were “Made in the USA” and “Proudly Made in the USA.” While final assembly of the dartboards occurred in the U.S., many component parts – including “components essential to the function and operation” of the product, such computer chips, cameras, and flatscreen monitors – were allegedly made outside the U.S. The settlement resolving these allegations prohibits the company from making misrepresentations about U.S. origin claims, requires notification to consumers of the settlement, and provides $625,000 toward consumer redress. This is the largest consumer redress award under the Made in the USA Labeling Rule to date.
  • FTC reaches settlement with a footwear company that advertised its products as “Made in the USA.” The FTC sued a footwear seller in federal court, alleging violations of Section 5(a) of the FTC Act and the Made in the USA Labeling Rule. According to the FTC, the company represented that its footwear products were wholly handcrafted in the U.S., through advertisements and labeling which stated that the products were “Made in the USA,” “More than Made in USA™,” and “all components are crafted by hand, not pre-assembled overseas[.]” The FTC asserted that, to the contrary, the company utilized factories in the Dominican Republic and Brazil to create components parts and, at times, to complete final product assembly. The settlement resolving these allegations provides $75,000 toward consumer redress and prohibits the company from making misleading or unsubstantiated country-of-origin claims.
  • FTC reaches settlement with two sellers of flag display products advertised as “Made in the USA.” The FTC sued two companies and their principals in federal court, alleging violations of Section 5(a) of the FTC Act and the Made in the USA Labeling Rule. According to the FTC, the companies made unqualified claims to consumers about their flagpole display products, which included flagpole kits, flags, and related accessories. The FTC alleged that the companies advertised the products as “Made in the USA,” “100% American Made Tough,” and “Built by Americans for Americans,” even though the products were imported, or comprised of “significant or essential foreign components” from China. The FTC alleged that the defendants also violated the Textile Fiber Products Identification Act and related rules by failing to include mandatory disclosures on the labeling and advertising for their textile fiber products, and by falsely claiming that those products were “Made in the USA,” even though the sellers knew the products were made in China. The settlement resolving these allegations requires the companies to avoid making misleading or unsubstantiated country-of-origin claims, notify consumers of the settlement, and make certain disclosures to consumers about the textile fiber products. The settlement provides $167,743 toward consumer redress.

Link to Takeaways for Businesses Takeaways for Businesses

The timing of the FTC’s announcement and the details of the enforcement actions underscore that Made in the USA labeling claims are a priority for the agency. Notably, the enforcement sweep targeted unqualified claims that products were “Made in the USA,” and such claims may face a higher risk of enforcement in the future. In addition to regulatory actions, there is also a risk of class action lawsuits.

Companies making U.S.-origin claims – explicit or implied – may see increased scrutiny from the FTC and other federal agencies, as well as potentially significant monetary consequences for noncompliance. Sellers on digital marketplaces in particular may face an uptick in scrutiny due to the Executive Order’s emphasis on online misrepresentation.

Companies who make “Made in America” claims should consider reviewing:

  • All marketing materials referencing “Made in America,” “Manufactured in the USA,” or similar U.S.-origin claims;
  • Labeling and packaging practices; and
  • Supplier certifications and origin documentation.

Moreover, given the anticipated cross‑agency coordination, businesses may want to evaluate whether their internal systems can document manufacturing location, assembly steps, and material sourcing.


[1] 15 U.S.C. § 45(a).

[2] 16 C.F.R. part 323.

[3] 15 U.S.C. § 70 et seq.; 16 C.F.R. Part 303.

Photo of Timothy A. Butler Timothy A. Butler

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia…

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia Attorney General’s Office, Tim has led the defense of dozens of government investigations and enforcement actions brought by the FTC, the Consumer Financial Protection Bureau (CFPB), and the various state attorneys general. Tim also regularly defends clients in bet-the-company lawsuits, including complex business disputes and consumer class actions alleging privacy, false advertising, and unfair or deceptive business practice claims.

Tim is an experienced guide for companies struggling with regulatory complexity. He offers clear advice that helps his clients meet the demands of the ever-growing set of laws and regulations governing data privacy and cybersecurity, advertising and marketing practices, and consumer financial products and services. Clients rely on Tim’s business-minded and practical strategies to address their most difficult regulatory compliance challenges.

A graduate of the University of Chicago and Stanford Law School, Tim is a prolific author and regularly speaks to industry and trade groups about the evolving privacy landscape, about cutting-edge issues affecting payments and fintech companies, and about developments at the FTC, the CFPB, and within the state attorneys general community.

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Photo of Cody B. Davis Cody B. Davis

Cody Davis advises clients on regulatory compliance, data privacy, and consumer protection matters within the financial technology sector, with a focus on payments, emerging platforms, and evolving regulatory frameworks. He works with companies navigating complex federal and state requirements, including regulatory compliance, government…

Cody Davis advises clients on regulatory compliance, data privacy, and consumer protection matters within the financial technology sector, with a focus on payments, emerging platforms, and evolving regulatory frameworks. He works with companies navigating complex federal and state requirements, including regulatory compliance, government investigations, and risk management across the fintech ecosystem.

Cody also has prior experience working with clients in the health care space on mergers and acquisitions as well as regulatory compliance with HIPAA, state telehealth rules, and facility licensure requirements.

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Photo of Matthew White Matthew White

Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.

Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the…

Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.

Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Truth in Lending Act, and their respective implementing regulations (Regulations E, V, P, and Z). Adept with the Consumer Financial Protection Bureau’s (CFPB) Prepaid Rule, Matt has provided guidance regarding prepaid cards and related compliance.

Matt has also aided clients in developing regulatory compliant products and functionalities, including an earned wage access program, reimbursement prepaid card programs, new merchant cash advance products, and tokenized payment capabilities. In connection with products on which Matt advises, he has also negotiated high-stakes technology sales agreements involving complex regulatory issues, including compliance with data privacy laws, financial regulations, and card network rules.

Beyond helping clients strategize for regulatory complexity, Matt also helps clients navigate government investigations and enforcement actions brought by the Federal Trade Commission (FTC), CFPB, and state attorneys general.

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Photo of Tessa Cierny Tessa Cierny

Tessa Cierny advises companies on financial technology and data privacy issues. She has experience counseling companies on state and federal regulatory compliance, including existing and emerging privacy laws, such as the E.U.’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act

…

Tessa Cierny advises companies on financial technology and data privacy issues. She has experience counseling companies on state and federal regulatory compliance, including existing and emerging privacy laws, such as the E.U.’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), as well as financial and banking regulations, such as the CFPB’s Section 1071 Small Business Lending Rule (Regulation B). In addition, she assists clients in defending business disputes and data breach litigation.

Prior to joining Greenberg Traurig, she served as global records manager for WestRock, where she developed and implemented email and data retention policies for global data privacy regulation compliance. In this role, she also advised on data privacy concerns related to data retention, data loss prevention, and data governance.

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  • Posted in:
    Business and Commercial
  • Blog:
    Consumer Protection Insights
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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