EU Label Compliance

United States

US labelling: country of origin, the FTC identity and net quantity

American labelling is federal, fragmented and outdated. Three requirements handle most of the compliance, and errors in these can cause a container to be stopped at the port rather than reaching the shelf.

Example of the label this guide describes
Facsimile of the file we deliver. Sample data, fictitious company.

Country of origin

Every imported article of foreign origin into the United States must be conspicuously, legibly and permanently marked with the English name of the country of origin. 'Made in Türkiye' is a marking; a flag or a three-letter code is not.

The marking applies to the article itself, not the carton. If the final purchaser sees the retail box, the box must also display it.

Identity of the responsible party

The Fair Packaging and Labeling Act requires the name and address of the manufacturer, packer or distributor on the principal display panel. A distributor must specify this — 'Distributed by' — rather than implying manufacturing.

This is the detail foreign sellers often omit, assuming that the responsible person in the EU covers the same requirement. It does not.

Net quantity and dual units

Net contents must be declared in both US customary and metric units, in a specified position and type size on the principal display panel. Rounding one of the two figures to a more convenient number is a violation, not a design choice.

Textiles and care

Textile products must list fibre content by weight in descending order, the country where processed or manufactured, and the responsible company — often as an RN number. Care instructions must follow the Care Labeling Rule and be permanent.

California on top

Proposition 65 is a state law with national implications, as most sellers cannot separate Californian stock. When a listed chemical exceeds the safe harbour level, a specific warning with a defined symbol and wording is required. We include it upon your instruction; we do not test the product to determine its presence.

How customs interprets the mark

The marking must be legible, indelible and sufficiently permanent to reach the final purchaser. Customs examines the article first, then the container, and applies the J-list and substantial transformation rules to determine the actual country of origin.

Assembly abroad from US components does not automatically make the product American, nor does a final screw in one country erase the origin of the entire product. The test is whether a new article with a different name, character or use has emerged.

Special marking rules apply to certain articles — pipe fittings, manhole covers, knives, watches — where the mark must be die-stamped, cast or engraved rather than printed.

Made in USA claims

A product advertised as Made in USA must be predominantly or entirely manufactured in the United States. The FTC actively enforces this, with civil penalties since 2021, and qualified claims such as 'Assembled in USA from imported parts' are available for partial compliance.

If your listing states American but your label states Türkiye, the issue lies with the listing, not the label.

Labels for online sales

Federal marking requirements apply to the product; platform rules govern the listing. Amazon requests fields for country of origin and responsible party, and discrepancies between these fields and the printed label are the most common automated flags.

The three federal layers

RequirementSourceWhere it appears
Country of origin19 U.S.C. 1304On the article, conspicuously
Identity of responsible partyFair Packaging and Labeling ActPrincipal display panel
Net quantity, dual unitsFPLA and state weights rulesPrincipal display panel, defined type size
Fibre content and careTextile Act and Care Labeling RulePermanent label in the garment
Prop 65 warningCalifornia Health and Safety CodeLabel or listing, clear and reasonable

How the pieces fit

The same information, in the order an inspector or reviewer encounters it.

The three federal layers1Country of origin2Identity of responsible party3Net quantity, dual units4Fibre content and care5Prop 65 warning

Words that keep coming up

Ultimate purchaser
The last person in the United States who receives the article in the form in which it was imported.
Substantial transformation
Processing that creates a new article with a different name, character or use, changing the origin.
Principal display panel
The part of the label most likely to be seen at the time of purchase.
RN number
A registered identification number issued by the FTC, usable instead of the company name on textile labels.

Questions people ask

Do I need a US entity to sell there?

Not for labelling. You need an identifiable responsible party with a US place of business, which is usually your importer or distributor.

Is an RN number mandatory?

No, but for textiles it is a convenient way to satisfy the identity requirement without printing a long company name.

Does Prop 65 apply to every product?

No. It applies when a listed chemical is present and exposure exceeds the safe harbour level, or where your supplier declares one.

Is a sticker acceptable for origin?

Yes if permanent enough to reach the purchaser, but several articles on the special list require die-stamping or casting.

Do I need both metric and customary units?

Yes on the principal display panel for packaged consumer commodities.

Who is the responsible party if I sell direct?

You are, and your place of business appears on the panel with 'Distributed by' or 'Manufactured for'.

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