EU Label Compliance

United States

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

American labelling is federal, fragmented and old. Three requirements do most of the work, and getting them wrong is what stops a container at the port rather than at the shelf.

Example of the label this guide describes
Fac-simile of the file we deliver. Specimen data, invented company.

Country of origin

Every article of foreign origin imported into the United States must be marked conspicuously, legibly and permanently 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 follows the article, not the carton. If the ultimate purchaser sees the retail box, the box carries it too.

Identity of the responsible party

The Fair Packaging and Labeling Act asks for the name and place of business of the manufacturer, packer or distributor on the principal display panel. A distributor must say so — 'Distributed by' — rather than implying manufacture.

This is the block foreign sellers most often leave out, because in the EU the equivalent is the responsible person and they assume one covers the other. It does not.

Net quantity and dual units

Net contents are declared in both US customary and metric units, in a defined position and type size on the principal display panel. Rounding one of the two figures to something friendlier is a violation, not a design choice.

Textiles and care

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

California on top

Proposition 65 is a state law with national reach, because most sellers cannot separate Californian stock. Where a listed substance is present above the safe harbour level, a specific warning with a defined symbol and wording is required. We place it when you tell us it applies; we do not test the product to find out.

How customs reads the mark

Marking must be legible, indelible and permanent enough to reach the ultimate purchaser. Customs looks at the article first and the container second, and applies the J-list and the substantial transformation rules to decide what the country of origin actually is.

Assembly abroad from American components does not automatically make the product American, and a final screw turned in one country does not erase the origin of the whole. The test is whether a new article with a different name, character or use emerged.

Special marking rules apply to a list of 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 all or virtually all made in the United States. The FTC enforces this actively, with civil penalties since 2021, and qualified claims such as 'Assembled in USA from imported parts' exist precisely for the middle ground.

If your listing says American and your label says Türkiye, the listing is the problem, not the label.

Labels for online sales

Federal marking rules apply to the goods; the platform rules apply to the listing. Amazon asks for country of origin and responsible party fields, and a mismatch between the field and the printed label is the most common automated flag.

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 a reviewer meets 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'.

Related guides

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