Made in America: When Should My Supplement Label Say "Made in the USA"
For most Americans, there’s a certain sense of pride that comes with being able to say, “My product is made in the USA.” But in an increasingly connected global market, where ingredients and materials can easily be sourced from halfway around the world, the lines between the supplements that really are “Made in the USA” and those that aren’t can blur.
Defining “Made in America”
For those looking to find a definition of “Made in America” that’s both accurate and thorough, the Federal Trade Commission (FTC) has you covered. Primarily responsible for protecting consumers and regulating goods, the FTC has published thousands of pages concerning the nature of a “Made in the USA” product claim.
The FTC’s “Made in USA” policy applies to any and all products sold or advertised in the U.S., except for those products that are subject to specific “Country of Origin” labeling laws. For those working internationally, other countries may also have their own unique set of rules concerning “Made in the USA”/”Country of Origin labeling.”
According to the FTC, this baseline for making a “Made in the USA” product claim:
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.
That “all or virtually all” bit translates, roughly, to almost all (if not all) of the components, ingredients, and materials used to make your product should be sourced and manufactured within the United States or its territories/possessions.
At this point you might be thinking to yourself, “All of this is fine and well, but what does it mean for my dietary supplement product?”
Labeling Supplements With American-Made Ingredients
Ultimately, the way that you label your supplement product will depend on how much or your product’s ingredients and materials have been sourced and manufactured in the USA. Put together by the Made in America Movement, this chart does a great job of highlighting the differences between “Made in America,” “Assembled/Manufactured in the America,” “Made with American Materials” and “American Brand.”
Establishing the Right Label Claim for Your Supplement Product
Along with having a conversation with your contract manufacturer concerning the country of origin for the materials used in your product, seeking additional legal counsel is always a viable option when trying to determine the best label statements and claims for a product.
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