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What Are the "Made in the USA" Requirements for Fragrances?

September 25, 2012
Question 

We are interested in a "Made in USA" program and looking for guidance in the fragrance industry as to what percent (raw materials, packing, labor, etc.) must come from the U.S. to make the "Made in USA" statement on the packaging.

Answer 

The Federal Trade Commission's (FTC) "Made in USA" policy requires that that a product be made "all or virtually all" in the U.S. for it to be called Made in USA, or claim to be of domestic origin without qualifications or limits on the claim. FTC has clarified that "all or virtually all" means that all significant parts and processing that go into the product are of U.S. origin, and that it contains negligible foreign content. Additionally, the product's final assembly or processing must take place in the U.S. However, FTC will consider other factors, including how much of the product's total manufacturing costs can be assigned to U.S. parts and processing, and how far removed any foreign content is from the finished product. The FTC Made in America policy applied to all products advertised or sold in the U.S., except for those specifically subject to country-of-origin labeling by other laws. For more information, see FTC's website. We suggest you consult with legal counsel to determine requirements for your specific product.