President Trump Issues Made in USA Executive Order

On March 13, President Trump issued an Executive Order regarding “Made in America,” “Made in the USA,” and similar U.S.-origin claims (“MUSA claims”). Although this Order does not change the existing legal requirements for MUSA claims, it signals the Trump administration’s interest in policing MUSA claims, both with existing regulations as well as potentially new rules. Specifically, the Order sets out four directives:

1. Prioritize MUSA Enforcement. The Order first directs the FTC to prioritize enforcement actions against manufacturers and sellers who make unlawful U.S.-origin claims. The FTC’s Made in USA Rule mandates that unqualified MUSA claims are only acceptable when all significant processing to create a product occurs in the U.S., final assembly takes place in the U.S., and “all or virtually all” ingredients or components of the product are of U.S.-origin. The FTC has actively enforced this rule under both the Biden and Trump administrations. Most recently, FTC Chair Andrew Ferguson declared July 2025 “Made in the USA” month, signaling a continued commitment to enforcement.
2. Online Marketplace Rule. The Order also directs the FTC to consider promulgating a rule that would deem an online marketplace’s failure to establish procedures to verify country-of-origin claims as unfair or deceptive under the FTC Act.
3. Voluntary U.S. Origin Labeling Rules. The Order also directs all agencies that oversee country-of-origin labeling to consider promulgating regulations to promote voluntary U.S. country-of-origin labeling for products that are manufactured in the U.S. The Order is silent on what agencies specifically may be implicated by this directive, though such agencies may include Customs and Border Protection (which oversees country-of-origin determinations in accordance with the Tariff Act) and the National Highway Traffic Safety Administration (which is involved in country-of-origin labeling for cars under the American Automobile Labeling Act).
4. Government Contractors. Finally, the Order directs agencies overseeing certain government contracts to verify MUSA claims (including Buy American Act claims) for products acquired through these contracts, even though the Buy American Act standard is distinct from the FTC Made in USA Rule. Per the Order, any contractors or vendors who have misrepresented American-origin status sold to the government shall have their products removed from procurement availability and be referred to the DOJ, which may pursue violations under the False Claims Act. Though not specifically stated in the Order, such a referral presumably would supplement existing regulations authorizing debarment of contractors found to have “[i]ntentionally affix[ed] a label bearing a ‘Made in America’ inscription (or any inscription having the same meaning) to a product . . . when the product was not made in the United States.”