The Federal Trade Commission’s standard for an unqualified Made in USA claim is “all or virtually all”. Final assembly in the United States, all significant processing in the United States, and all or virtually all of the parts made and sourced there. The agency gives no number. It weighs how much of the cost is American, how far back the foreign content sits, and how much that content matters to the product.
Other rules do have numbers. For federal purchases, Buy American asks that domestic components be more than 65% of the cost of the components, and 75% for items delivered from 2029. In Canada, “Product of Canada” means at least 98% of the direct costs were incurred in the country. “Made in Canada” means at least 51%, with a qualifying statement such as “with imported parts”. One bag, four tests, two countries.
We think the test without a number is the demanding one. A percentage can be met once, on a spreadsheet. “All or virtually all” has to be true of every box, on the day it is packed. For a garbage bag, that means knowing where the resin comes from, then the color, the core when there is one, the carton and the label. We make bags in Quebec and in Mississippi, and the work is the same on both sides: the claim on the box is worth what the records behind it are worth.
That is why the longer label deserves more respect than it gets. The FTC lists wording such as “Made in USA of U.S. and imported parts” among its examples of qualified claims. A box that says so does not hold a weaker product. It carries a claim that somebody checked.
The rule has a price. In July 2021, the agency adopted the Made in USA Labeling Rule, which lets it seek civil penalties for a false label. In April 2024, a national retailer agreed to pay a record $3.17 million over products sold as Made in USA that, the agency said, were made in China and other countries.
What this changes for you. If you buy bags or film on the strength of an origin claim, ask two questions in writing. Which test does the claim answer, the label standard or the purchasing rule? And what do the records cover: resin, color, core, carton? A supplier who can answer the second one quickly has the paper trail. The label is worth exactly that.
