"Made in" Disclosure (US)
"Made in" Disclosure (US)
FTC country-of-origin rules for jewellery sold in the United States
The "Made in" disclosure required for jewellery sold in the United States is governed by the Federal Trade Commission under Section 5 of the FTC Act and elaborated through the Commission's Enforcement Policy Statement on US Origin Claims and the Guides for the Jewelry, Precious Metals, and Pewter Industries (16 CFR Part 23). The disclosure is a country-of-manufacture statement, distinct from the disclosures required for treatments, gem species, metal fineness and synthetic origin.
The "Made in USA" standard
An unqualified "Made in USA" claim, on jewellery as on any consumer product, requires that all or virtually all of the article be of US origin. Under the FTC's Made in USA Labeling Rule (effective 2021) the threshold is that final assembly takes place in the United States, all significant processing is US, and all or virtually all the components are US-sourced. For jewellery, components include findings, settings and stones; the standard is genuinely strict, and a piece set with imported diamonds or gemstones will rarely qualify for an unqualified Made in USA claim.
Qualified claims and origin disclosures
Where an unqualified claim is unavailable, qualified statements such as "Designed in USA", "Assembled in USA with imported stones" or "Made in USA with imported and domestic components" are acceptable provided they are accurate and not misleading. For imported jewellery, the country of origin must be marked under US Customs (19 CFR Part 134) so that the ultimate purchaser can readily identify the country of manufacture; markings such as "Made in Italy" or "Made in Thailand" must be permanent, conspicuous and legible.
Practical effect
The combination of FTC and Customs rules means that any jewellery item sold in the US must carry an accurate country-of-manufacture disclosure, and any "Made in USA" claim must clear the all-or-virtually-all test. Misleading country claims are actionable as deceptive advertising and have been pursued by the FTC against jewellery brands in recent years.