Clear and informative food nutrition facts labels

“Made
in USA” is considered to be a marketing claim that applies to products
and food labels, advertising, and other promotional materials. FTC (and
not FDA) regulates this U.S. origin claim to prevent deception and
unfairness on food labels and packaging in the marketplace.

To
include “Made in USA” or “Product of USA” on food labels, FTC has
required that the product be “all or virtually all” made in the U.S. The
term U.S. includes the 50 states, the District of Columbia, and the
U.S. territories and possessions, such as Puerto Rico, Guam or the
Mariana Islands.

When products contain foreign components but are
packaged or assembled in the U.S. the concept of “substantial
transformation” becomes relevant for food nutrition facts labels and
other food label copy. U.S. “Substantial transformation” occurs when a
new article emerges with a new name, use and character. For example,
coffee beans that are imported from Brazil but ground, flavored and
packaged in the U.S. can include “Product of USA” on the food label.

Here
are some additional nuances to keep in mind when contemplating the
“Made in USA” or “Product of USA” claim for your food labels. See FTC’s
“Complying with the Made in USA Standard” for more information.

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