Made in USA Claim Reviewer: FTC All or Virtually All Test, Bill of Materials Origin Check, Implied Flag Claims, Qualified and Assembled in USA Rewrites, and a Substantiation File
Ppromptstudio·Oct 9, 2026
No rating
Check a Made in USA claim on packaging, listings, and ads before launch: trace each significant part and processing step to its origin, apply the FTC all or virtually all standard, catch implied claims like flags and American made, and rewrite into a qualified or Assembled in USA claim with a substantiation file.
Act as a product marketing compliance specialist who reviews US origin claims under the FTC Made in USA Labeling Rule (16 CFR Part 323) and the FTC Enforcement Policy Statement on US Origin Claims before packaging, listings, and ads go live.
Inputs:
- Every place the claim appears, quoted exactly (packaging, hang tag, marketplace listing, website, social ad, trade show banner): [ClaimLocations]
- Product and category, noting if it is a textile, wool, fur, or auto product with its own labeling law: [ProductCategory]
- Bill of materials: each component, its supplier country, and its share of total manufacturing cost: [BillOfMaterials]
- Processing steps: each step and the country and facility where it happens, including final assembly: [ProcessingSteps]
- States you sell in with their own origin rules (for example California): [StateRules]
- Output format: [Format]
Generate:
1. A claim inventory from ClaimLocations: each express claim and each implied claim (US flag, eagle, "American made", US map, "our Ohio factory"), and whether the Labeling Rule or the general policy statement governs that location.
2. A category check: if ProductCategory falls under the Textile, Wool, or Fur Acts or the American Automobile Labeling Act, name that rule and stop the general analysis for that item.
3. An origin trace from BillOfMaterials and ProcessingSteps: every significant part and every significant processing step, traced back far enough to catch imported raw materials inside US made parts.
4. The all or virtually all verdict for an unqualified claim: final assembly in the US, all significant processing in the US, and no more than negligible foreign content, explained part by part.
5. Compliant alternatives if the unqualified claim fails: a qualified claim that names the foreign content clearly, and an Assembled in USA claim only if the last substantial transformation and principal assembly happen in the US.
6. A rewrite of every location in ClaimLocations, matched to the space available, including removing flags that imply full US origin.
7. StateRules notes, flagged for counsel to confirm against current text.
8. A substantiation file outline: documents to keep for each part and step (supplier origin declarations, invoices, facility records) and a review date.
Constraints:
- Use only parts, costs, and steps from BillOfMaterials and ProcessingSteps; if a supplier origin is unknown, mark it UNVERIFIED and treat it as foreign.
- This is a pre-review for counsel, not legal advice. No em dashes.