FTC Announces “Made in the USA” Sweep, Including Three Law Enforcement Actions to Protect American Consumers and Businesses

Today, the Federal Trade Commission announced law enforcement actions involving three companies that deceived American consumers by falsely claiming, in advertising and labeling, that their products were made in the United States. These actions follow President Trump's March Executive Order, "Ensuring Truthful Advertising of Products Claiming to be made in America."

As part of these actions, the FTC reached settlements with sellers of American flags and flagpole display kits, entertainment systems for home and commercial use, and footwear products, resolving allegations in separate federal court complaints that these sellers violated the law by making unqualified and unsubstantiated "Made in USA" claims.

"The FTC is committed to ensuring that 'Made in the USA' claims are truthful and trustworthy," said Christopher Mufarrige, Director of the FTC's Bureau of Consumer Protection. "We will robustly enforce the 'Made in the USA' standard so that the American people have confidence that their purchases of American-made products support American workers and manufacturing."

The three enforcement actions continue the Commission's work to protect American consumers from deceptive "Made in USA" advertising and labeling claims, while providing consumers with confidence that their purchases of American-made products actually support American workers, manufacturing, and communities. These enforcement actions also ensure that American businesses, who have made the necessary investments in domestic manufacturing, are not disadvantaged and that there is fair competition for those sellers who truthfully advertise their products as "Made in the USA."

TouchTunes

The FTC sued TouchTunes Music Company, LLC (TouchTunes), alleging in a complaint that the company falsely claimed its electronic dartboards sold for both residential and commercial use were "Made in the USA."

According to the FTC's complaint, TouchTunes made numerous unqualified "Made in the USA" claims across its website and other marketing materials even though the electronic dartboards contained imported components. The complaint further alleges that, though TouchTunes completed the final assembly of its electronic dartboards in the United States, many components-including ones essential to the function and operation of the products, such as computer chips, cameras, and flatscreen monitors-were made outside the United States. Accordingly, the FTC alleged that TouchTunes made false, unqualified "Made in the USA" claims on its online sales page and in other advertisements, in violation of Section 5 of the FTC Act, Section 45a, and the Made in USA (MUSA) Labeling Rule.

To resolve these allegations, TouchTunes stipulated to a proposed order that:

• Provides $625,000 towards consumer redress under Section 19 of the FTC Act, the largest for a Made in USA Labeling Rule case to date;
• Prohibits misrepresentations regarding U.S.-origin claims;
• Prohibits misleading or unsubstantiated country-of-origin claims; and
• Requires TouchTunes to provide notice to consumers of the settlement with the FTC.

The Commission vote to issue the complaint and proposed order was 2-0. The complaint and proposed stipulated order will be filed in the U.S. District Court for the Southern District of New York.

Americana Liberty and Related Parties

As a follow-on to a July 8, 2025, warning letter issued by FTC staff, the FTC brought an enforcement action against Americana Liberty LLC and Three Nations LLC, as well as the companies' principals-Maximiliano Ojeda, Virginia Hilfiger, and Julian Groves-alleging that they falsely advertised and labeled patriotic flag display and related products as "Made in the USA."

Americana Liberty, Three Nations, and their principals repeatedly and prominently represented in advertising and labeling that American flags, U.S. military flags, and patriotic flag display products and other accessories were "Made in the USA," "All-American Made," "100% Made in the USA," "100% American Made Tough," and "Built by Americans for Americans," the FTC's complaint alleges. The defendants allegedly made these unqualified "Made in the USA" claims through their corporate websites, digital marketing, and other marketing materials. According to the complaint, despite these claims, several products were wholly imported from China and others were comprised of significant or essential foreign components from China, according to the FTC's complaint.

In addition, the companies and their principals are alleged to have violated the Textile Act and Rules-depriving consumers of information about the true nature and origin of these products by failing to include mandatory disclosures on the labeling and advertising for their flags and falsely claiming flags were "Made in the USA" when sellers knew they were made in China.

The FTC alleges that Americana Liberty, Three Nations, and their principals violated Section 5 of the FTC Act, Section 45a, the MUSA Labeling Rule, the Textile Act, and the Textiles Rules.

To resolve these allegations, defendants stipulated to a proposed order that:

• Provides $167,743 towards consumer redress;
• Prohibits misrepresentations regarding U.S.-origin claims;
• Prohibits misleading or unsubstantiated country-of-origin claims;
• Requires certain disclosures concerning textile fiber products; and
• Requires defendants to provide notice to consumers of the settlement with the FTC.

The Commission vote to issue the complaint and proposed stipulated order was 2-0. The complaint and proposed order will be filed in the U.S. District Court for the Southern District of Florida.

Oak Street

The FTC took action against Oak Street Manufacturing Company, LLC, which also does business as Oak Street Bootmakers, alleging that the company falsely claimed that certain boots, loafers, moccasins, and other footwear products were "handcrafted 100%" in the United States; the "entire product" was made in the U.S. "from heel-to-toe, using no pre-assembled components from overseas"; and that their footwear products were "More than Made in USA^TM." This law enforcement action also follows a warning letter issued by the FTC to Oak Street last July expressing concerns about the company's "Made in USA" claims.

The FTC's complaint alleges that, since May 2023, Oak Street used a factory in the Dominican Republic to produce the top portion of certain footwear products, while also sourcing outsoles from a factory in Brazil. Oak Street shipped these components to a facility in the United States, according to the complaint, which then assembled the uppers and outsoles into completed footwear products. In some instances, Oak Street did not complete the final assembly stage with U.S.-based contract manufacturers and instead engaged a factory in the Dominican Republic to complete the "bottoming" services for various footwear products, the FTC alleges.

Due to these imported components and the assembly process taking place outside the United States, the FTC alleged that Oak Street sold footwear products that were not "all or virtually all" made in the United States, in violation of Section 5 of the FTC Act, Section 45a, and the MUSA Labeling Rule

To resolve these allegations, Oak Street stipulated to a proposed order that:

• Provides $75,000 towards consumer redress;
• Prohibits misrepresentations about its products or services, including representations regarding U.S.-origin claims; and
• Prohibits misleading or unsubstantiated country-of-origin claims.

The Commission vote to issue the complaint and proposed stipulated order was 1-0-1, with Commissioner Meador recused. The complaint and proposed order will be filed in the U.S. District Court for the Northern District of Illinois Eastern Division.

Closing Letters

In addition to the three enforcement actions and settlement agreements, the FTC issued closing letters to two companies that had been under investigation for making unqualified "Made in the USA" claims without proper substantiation or support.

After being contacted by FTC staff, acrylic product and custom display manufacturer Marketing Holders LLC and trailer manufacturer Lamar Trailers, Inc. each agreed to take action to remediate certain "Made in USA" representations and bring their companies into compliance with the FTC's "Made in USA" standard. Based on each company's remedial actions and commitment to future compliance, FTC staff issued letters closing these investigations.

However, both companies were warned that the Commission reserves the right to monitor and take further action, including potentially filing a federal lawsuit.

NOTE: The Commission authorizes the filing of a complaint when it has "reason to believe" that the named defendants are violating or are about to violate the law and it appears to the Commission that a proceeding is in the public interest. Stipulated orders have the force of law when approved and signed by the District Court judge.

The Federal Trade Commission offers guidance on how to comply with the Made in USA standard.