Made In USA Tracker
January 1997 To Present
| DATE | COMPANY | AUTHOR | ADDRESSEE/ COPYEE |
NATURE OF INQUIRY | CLOSING REASON |
| 2/8/2021 | West Coast Corporation, also d/b/a Key-Bak (Made in USA) |
Julia Solomon Ensor Staff Attorney Lashanda Freeman Federal Trade Investigator |
Wendy Y. Wang, Esq. Best Best & Krieger LLP |
Concerns that marketing materials may have
overstated the extent to which products advertised, including
certain retractable badge and key holders, are made in the United States. Specifically, although WCC operates a plant, designs products, and performs certain manufacturing functions in the USA, many products it offers are wholly imported or contain significant imported components. |
To avoid deceiving consumers, WCC implemented a remedial action plan to update and qualify its representations. This plan included: (1) revising websites and social media accounts; (2) updating listings on third-party platforms, such as Amazon.com; (3) updating print materials and packaging, including by stickering over unqualified claims until new materials could be printed; (4) updating tradeshow materials; (5) updating product molds; (6) contacting and training trade customers on appropriate claims; (7) designating employees to supervise and ensure compliance; and (8) adding country-of-origin training to the Company's semi-annual sales training for sales, marketing, and customer service staff. |
| 1/11/2020 | GDMC USA LLC d/b/a VOmax (Made in USA) |
Julia Solomon Ensor Staff Attorney Lashanda Freeman Federal Trade Investigator |
Mr. Bruce Tretter Chief Operations Officer |
Two sets of concerns. First, certain marketing
materials may have overstated the extent to which VOmax products
are made in the United States. For example, VOmax made
"#madeinUSA" and other unqualified U.S.-origin claims in social media posts and other online materials, even though some VOmax cycling apparel is imported or made from imported fabrics. Second, certain VOmax marketing materials may have failed to comply with provisions of the Textile Products Identification Act, 15 U.S.C. § 70 et seq. ("Textile Act"), and implementing rules, 16 C.F.R. Part 303 ("Textile Rules"). Specifically, for some apparel products, materials omitted required country-of-origin information, or failed to disclose that products were made from imported fabrics. |
To come into compliance with Section 5 of the FTC
Act, 15 U.S.C. § 45(a) ("Section 5"), and the Textile Act and Textile Rules, VOmax implemented a remedial action plan to update its labels and marketing materials. This plan included: (1) removing broad, unqualified U.S.-origin claims from advertisements, including social media posts; (2) updating product labels, where appropriate; and (3) ensuring all "mail order advertising" contains required origin information. As discussed, it is appropriate for VOmax to promote the fact that it employs workers in the United States and offers a line of U.S.-origin apparel. However, marketing materials that cover imported products or products made from imported fabrics must (1) not overstate the extent to which company products are made in the United States, and (2) make clear origin disclosures in compliance with the Textile Act and Textile Rules. FTC staff is available to work with companies to craft appropriate claims that comply with the Textile Act and Textile Rules, convey non-deceptive information to consumers, and highlight work done in the United States. |
| 1/11/2020 | GDMC USA LLC d/b/a VOmax (Made in USA) |
Julia Solomon Ensor Staff Attorney Lashanda Freeman Federal Trade Investigator |
Mr. Bruce Tretter Chief Operations Officer |
Two sets of concerns. First, certain marketing
materials may have overstated the extent to which VOmax products
are made in the United States. For example, VOmax made
"#madeinUSA" and other unqualified U.S.-origin claims in social media posts and other online materials, even though some VOmax cycling apparel is imported or made from imported fabrics. Second, certain VOmax marketing materials may have failed to comply with provisions of the Textile Products Identification Act, 15 U.S.C. § 70 et seq. ("Textile Act"), and implementing rules, 16 C.F.R. Part 303 ("Textile Rules"). Specifically, for some apparel products, materials omitted required country-of-origin information, or failed to disclose that products were made from imported fabrics. |
To come into compliance with Section 5 of the FTC
Act, 15 U.S.C. § 45(a) ("Section 5"), and the Textile Act and Textile Rules, VOmax implemented a remedial action plan to update its labels and marketing materials. This plan included: (1) removing broad, unqualified U.S.-origin claims from advertisements, including social media posts; (2) updating product labels, where appropriate; and (3) ensuring all "mail order advertising" contains required origin information. As discussed, it is appropriate for VOmax to promote the fact that it employs workers in the United States and offers a line of U.S.-origin apparel. However, marketing materials that cover imported products or products made from imported fabrics must (1) not overstate the extent to which company products are made in the United States, and (2) make clear origin disclosures in compliance with the Textile Act and Textile Rules. FTC staff is available to work with companies to craft appropriate claims that comply with the Textile Act and Textile Rules, convey non-deceptive information to consumers, and highlight work done in the United States. |
| 11/12/2020 | Dal-Tile Corporation, a subsidiary of Mohawk
Industries, Inc. (Made in USA) |
Julia Solomon Ensor Staff Attorney Lashanda Freeman Federal Trade Investigator |
Kathleen Benway, Esq. Alston & Bird LLP |
Concerns that marketing materials may have overstated the extent to which Dal-Tile's quartz slab products are made in the United States. Specifically, although the Company substantially transforms American Reserve products into finished goods in the United States, because quartz material has limited availability in the U.S., the Company imports essential raw materials it incorporates into these products. | Dal-Tile implemented a remedial action plan to
update its representations. This plan included: (1) correcting
webpages and social media posts; (2) redistributing labels, as well as instructions and guidelines, to stone centers, third-party fabricators, and distributors that purchased sample tower displays; and (3) undertaking a comprehensive review of and substantiation check for U.S.-origin claims by other Mohawk Industries, Inc. subsidiaries. |
| 11/12/2020 | Dude Products, Inc. (Made in USA) |
Julia Solomon Ensor Staff Attorney Lashanda Freeman Federal Trade Investigator |
Christine Skoczylas, Esq. Barnes & Thornburg LLP |
Concerns that marketing materials may have overstated the extent to which certain hygienic products including, but not limited to, Dude Wipes, are made in the United States. Specifically, although the Company's wipes undergo significant manufacturing or processing in the United States, in some instances they incorporate significant imported components. | Dude Products implemented a remedial action plan to update and qualify its representations where needed. This plan included: (1) updating affected packaging and marketing materials to qualify claims; (2) updating potentially confusing or conflicting marketing copy on Company websites; and (3) submitting updated photographs and marketing copy to third-party platforms, including Amazon and Walmart. As part of this inquiry, Dude Products also reviewed its country-of-origin claims for textile products to ensure compliance with the Textile Fiber Products Identification Act, 15 U.S.C. §§ 70-70k, and implementing rules, particularly 16 C.F.R. §§ 303.15(b); 303.16; 303.33; and 303.34. |
| 10/21/2020 | Keen Pump Company, Inc. (Made in USA) |
Julia Solomon Ensor Staff Attorney Lashanda Freeman Federal Trade Investigator |
Jonathan G. Polak, Esq. Taft Stettinius & Hollister LLP |
Marketing materials may have overstated the extent
to which certain specialty pumps are made or "built" in
the United States. Specifically, although Keen assembles certain
products in the United States, those products incorporate significant imported parts. |
Keen removed all references to U.S. origin from
its online and hardcopy marketing materials. Additionally, Keen provided notice of the changes and updated marketing materials to all known third-party distributors. |
| 10/1/2020 | Zoeller Pump Company, LLC (Made in USA) |
Julia Solomon Ensor Staff Attorney Lashanda Freeman Federal Trade Investigator |
Jeffery P. Langer, Ph.D., J.D. General Counsel |
Marketing materials may have overstated the extent
to which all of ZPC's products are made in the United States.
Specifically, although some ZPC products are "all or virtually
all" made in the United States, many more incorporate more than de minimis imported content, and some are wholly imported. |
ZPC implemented a remedial action plan to update
and qualify its representations where needed. This plan included:
(1) introducing qualified claims to ZPC marketing materials, where appropriate; (2) correcting outdated or incorrect claims, including by stickering over claims on product packaging until new packaging arrives; (3) reviewing and updating all social media accounts; (4) introduced enhanced training for ZPC and related-company staffs; and (5) implementing enhanced processes to ensure the accuracy of dealer/distributor claims, including by providing updated marketing materials and implementing a quarterly audit process. |
| 10/1/2020 | American Crafts, L.C. (Made in USA) |
Julia Solomon Ensor Staff Attorney Lashanda Freeman Federal Trade Investigator |
Mr. Grant Madsen Chief Marketing Officer |
AC may have failed to update packaging for certain SKUs of a cardstock product sourced from overseas mills and cut, printed, and packaged in the United States. | AC implemented a remedial action plan to update and correct these representations. This plan included: (1) updating product packaging, specification sheets, and inventory systems; (2) updating social media; (3) contacting distributors with instructions to update materials; (4) blocking new sales to noncompliant distributors; (5) updating third-party sales platforms, including Amazon.com; (6) training staff; and (7) introducing a regular country-of-origin auditing program administered by the Chief Marketing Officer. |
| 10/1/2020 | Sunex International, Inc. (Made in USA) |
Julia Solomon Ensor Staff Attorney Lashanda Freeman Federal Trade Investigator |
John Kavanagh, J.D. Steptoe & Johnson LLP |
Marketing materials may have overstated the extent to which certain hydraulic presses are made in the United States. Specifically, although the Companies' hydraulic presses are substantially transformed in the United States, they incorporate significant imported components.. | The companies implemented a remedial action plan
to update and qualify their representations where needed. This plan
included: (1) updating press labels to state "Made in USA with Foreign Components;" (2) updating product manuals and catalogues; (3) updating social media accounts; ( 4) updating profiles on third-party sales platforms, including amazon.com; and (5) implementing a plan to communicate changes and distribute materials to third-party distributors and downstream retailers, including sending multiple communications, performing internal checks on customer sites, and suspending noncompliant dealers. |
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