FTC Made in USA Labeling: Compliance Steps for Durable Goods

Mislabeling a product as Made in USA can lead to enforcement actions and lost trust. For durable goods makers and distributors, including sellers of plumbing and HVAC parts, the Federal Trade Commission’s Made in USA Labeling Rule sets clear conditions for unqualified and qualified origin claims. Here’s how to align operations, packaging, and online listings with the rule.

Accurately presenting U.S.-origin claims is more than a packaging choice—it is a compliance discipline that spans sourcing, assembly, and every channel where a claim appears. The FTC’s Made in USA Labeling Rule allows unqualified claims only when a product is “all or virtually all” made in the United States, including final assembly or processing on U.S. soil. For durable goods and parts, the safest path is to build a repeatable process that determines whether to use an unqualified claim, a qualified claim such as “Made in USA of U.S. and imported parts,” “Assembled in USA,” or to make no claim at all.

Online plumbing supplies: what claim fits?

Sellers of online plumbing supplies must treat product pages, images, badges, comparison charts, and ad copy as labeling. If a SKU is eligible for an unqualified claim, ensure the claim appears consistently across the hero image, bullets, and technical specs. If not, use a precise qualified claim that reflects actual content and processing. Avoid implying U.S.-origin with flags or color schemes when the text makes no claim. Align distributor catalogs, marketplace feeds, and local services listings “in your area” with the same, verified statement to prevent mixed messages.

Water heater parts: can you say U.S.-made?

Water heater parts often include imported subassemblies such as thermostats, igniters, or valves. An unqualified Made in USA claim is inappropriate if even a non-negligible portion of total content is foreign. Confirm that final assembly occurs in the United States and that virtually all significant components are U.S.-origin before using an unqualified claim. When parts are a blend, a qualified claim like “Made in USA of U.S. and imported parts” may be accurate. For service kits with mixed-origin components, consider stating origin at the kit level or avoid a claim to prevent confusion.

HVAC components: assembly and origin rules

For HVAC components, “Assembled in USA” can be suitable when principal assembly happens domestically and is more than a minor or simple process. Assembly should be substantial and result in the finished article’s essential character, not merely attaching imported parts. Map the bill of materials and assign origin to each significant component; document where each manufacturing and assembly step occurs. Keep records that show final assembly in the U.S. and the proportion of foreign content to support your chosen claim across packaging, spec sheets, and online listings.

Residential plumbing supplies: labeling online

Residential plumbing supplies frequently move through multiple channels—direct e-commerce, distributor sites, and marketplaces. Harmonize claims in product titles, feature bullets, comparison modules, and image overlays. Use consistent phrasing across PDPs, downloadable PDFs, and data feeds. Avoid broad statements like “American quality” if the product does not meet the rule for an unqualified claim. If you must change suppliers, update packaging artwork, website copy, and marketplace feeds at the same time, and remove cached images that still display the old claim to reduce the risk of lingering inaccuracies.

Heating system parts: records and updates

Durable parts programs depend on disciplined recordkeeping. Maintain supplier affidavits, certificates of origin, and dated engineering change orders tied to specific SKUs and revision levels. Keep artwork proofs and screenshots of webpages showing the exact claim in use by date. Build a change-control trigger: when a component source moves offshore, re-evaluate the claim before the next production run or content refresh. Inspect third-party listings and reseller pages periodically, since unauthorized or outdated claims on a partner site can still pose compliance risk.

Practical compliance steps for durable goods

  • Define claim policy: unqualified, qualified, assembled, or none; adopt standardized language for each claim type.
  • Conduct origin substantiation: map content by cost and criticality; identify where significant processing and final assembly occur.
  • Review packaging and digital assets: cartons, labels, manuals, and all e-commerce placements including alt text and image overlays.
  • Train teams: sourcing, engineering, marketing, and channel partners on when and how to present claims.
  • Monitor and audit: schedule periodic reviews; maintain a central repository of substantiation and dated claim usage.
  • Correct promptly: if facts change, pull or revise claims across packaging, websites, ads, and marketplace feeds.

Common pitfalls and how to avoid them

  • Overreliance on supplier assurances without documentation tied to the specific part number and revision.
  • Using patriotic visuals that imply a claim where none is substantiated.
  • Treating “assembled” as a shortcut; simple placement or minor processing is not enough.
  • Failing to synchronize claims across packaging, PDPs, and third-party catalogs.
  • Leaving legacy artwork or cached images online after sourcing changes.

Examples using sector-specific parts

  • Online plumbing supplies: a U.S.-assembled brass valve with imported seals may support “Assembled in USA” if the assembly is principal and substantial; avoid an unqualified claim if foreign content is more than negligible.
  • Water heater parts: a burner assembly with a foreign gas valve likely needs a qualified claim that acknowledges imported components.
  • HVAC components: a control board designed and programmed domestically but built abroad should not carry an unqualified U.S. claim; consider no claim.
  • Residential plumbing supplies: a mixed-origin faucet kit sold as a single SKU should use a single, accurate qualified claim on both box and PDP.
  • Heating system parts: if a domestic casting changes to an imported casting, revalidate claims before shipping the next lot.

A sound Made in USA compliance program turns complex rules into routine practice. By documenting origin, choosing precise claim language, and aligning packaging with online content, durable goods makers and distributors can give shoppers clear, truthful information while managing regulatory risk across every channel where their products appear.