On April 14, 2026, the FTC announced three settlements and issued closing letters to two additional companies concerning “Made in America,” “Made in the USA,” and similar U.S.‑origin claims (collectively, “MUSA claims”).  These actions reflect the FTC’s continued focus on MUSA claims and, more broadly, the Trump administration’s focus on American manufacturing and related claims.  We briefly summarize each of these matters below:

FTC Settlements

Americana Liberty LLC and Related Parties (Americana Liberty)

The FTC alleged that Americana Liberty violated the Made in USA Labeling Rule by repeatedly and prominently claiming that its patriotic flag display products (e.g., flagpole kits, flags, and related parts and accessories) were “Made in the USA,” “All-American Made,” “100% Made in the USA,” “100% American Made Tough,” and “Built by Americans for Americans,” when in fact they were wholly imported and/or comprised significant or essential foreign components.  In addition, the FTC alleged that Americana Liberty violated the Textile Act and Rules 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.  To resolve these allegations, Americana Liberty agreed to a settlement that includes $167,743 in consumer redress, prohibits misleading country-of-origin claims, and requires Americana Liberty to inform consumers of the settlement and make certain disclosures about textile fiber products.

Oak Street Manufacturing Company, LLC (Oak Street)

The FTC alleged that Oak Street violated the Made in USA Labeling Rule by representing that its footwear products “meet[] the minimum FTC requirements to claim ‘Made in USA[,]’” and that “all components are crafted by hand, not pre-assembled overseas.”  Moreover, between approximately 2020 through August 2025, Oak Street allegedly claimed that its footwear products were “More than Made in USATM,” and that the “entire product . . . from heel-to-toe us[ed] no pre-assembled components from overseas.”  Despite these unqualified claims, Oak Street allegedly utilized factories in the Dominican Republic and Brazil to create components and, at times, complete final assembly of its products.  To resolve these allegations, Oak Street agreed to a settlement that includes $75,000 in consumer redress and prohibits misleading or unsubstantiated country-of-origin claims.

TouchTunes Music Company, LLC (TouchTunes) The FTC announced a settlement resolving allegations that TouchTunes violated the Made in USA Labeling Rule by making unqualified express claims that its Arachnid 360 dartboards were “Made in the USA.”  The FTC alleged that while final assembly of Arachnid 360 electronic dartboards occurred in the United States, many components—including components essential to the function and operation of the product, such as computer chips, cameras, and flatscreen monitors—were made outside the United States.  The settlement prohibits TouchTunes from making misrepresentations of U.S. origin claims and requires notice to consumers and $625,000 in consumer redress.

FTC Closing Letters

Lamar Trailers, Inc. (Lamar Trailers)

The FTC began investigating Lamar Trailers based on alleged concerns that the company overstated the extent to which its trailers are made in the United States.  Specifically, the FTC alleged that Lamar Trailers advertised and sold trailers with a “Made in U.S.A.” sticker even though it moved some of its trailer manufacturing operations from Texas to Mexico.  The FTC also expressed concerns with broad, unqualified “Made in U.S.A.” and U.S.‑origin claims made by Lamar Trailers’ authorized dealers on their websites and in other promotional materials.  On April 14, the FTC issued a formal closing letter publicly announcing the end of this investigation, noting that Lamar Trailers had brought its claims into compliance with FTC laws and rules, and documenting the remedial steps that Lamar Trailers has agreed to take to address its future conduct.

Marketing Holders LLC (Marketing Holders) The FTC began investigating Marketing Holders—an acrylic product and custom display manufacturer—based on alleged concerns that the company overstated the extent to which its products were made in the United States.  Specifically, the FTC alleged that Marketing Holders advertised numerous products on its website using “Made in U.S.A.” claims, as well as broad, unqualified representations that all of its products were “manufactured” and “fabricated” in the United States, even though many of the products were made in China, assembled in the United States using some parts from China, or could be made in either the United States or China.  On April 14, the FTC issued a formal closing letter publicly announcing the end of this investigation, noting that Marketing Holders had brought its claims into compliance with FTC laws and rules, and documenting the remedial steps that Marketing Holders has agreed to take to address its future conduct.

Key Takeaways

These actions reflect an increase in formal enforcement actions and underscore that MUSA claims remain an FTC priority, consistent with the Trump administration’s focus on U.S. manufacturing.  Notably, these matters focused on explicit, unqualified claims, which pose higher risks due to the level of substantiation required for such claims.  Although these cases send a strong message to industry about the FTC’s priorities, FTC guidance makes clear that qualified and implied MUSA claims are also subject to scrutiny. Advertisers may benefit from reviewing their claims to ensure compliance with FTC law and guidance.  Covington’s Advertising and Consumer Protection Investigations team regularly advises clients on MUSA compliance, FTC enforcement risk, and supply‑chain substantiation issues and is available to discuss questions arising from these developments.

Photo of Jehan Patterson Jehan Patterson

Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection…

Jehan Patterson leverages her extensive experience as a civil litigator and trial attorney in private practice and for the federal government to provide actionable advice that is informed by deep regulatory insight to clients across industries on a wide range of consumer protection matters.

Jehan is a member of the Advertising and Consumer Protection Investigations group. She represents corporate and individual clients in consumer protection investigations and litigation by the FTC and state Attorneys General and state financial regulators. She advises clients on consumer protection considerations relating to generative and agentic artificial intelligence, state and federal laws governing autorenewal programs, sustainability and other environmental claims, the FTC’s Made in USA rule, the USDA’s National Organic Program, adtech, and other advertising matters. Jehan also represents clients in complex civil litigation involving consumer protection claims.

Before joining Covington, Jehan was a Senior Litigation Counsel in the Office of Enforcement at the Consumer Financial Protection Bureau, where she led investigations into numerous providers of consumer financial products and services for violations of federal consumer financial laws and regulations, including the Consumer Financial Protection Act’s prohibition against unfair, deceptive, and abusive acts and practices.

Photo of Ryan Miller Ryan Miller

Ryan Miller is an associate in the Washington, DC office. His practice focuses on both trademark matters, with an emphasis on counseling and litigation, and regulatory matters related to consumer protection.

Ryan helps technology and consumer brands to navigate the increasingly complex regulatory…

Ryan Miller is an associate in the Washington, DC office. His practice focuses on both trademark matters, with an emphasis on counseling and litigation, and regulatory matters related to consumer protection.

Ryan helps technology and consumer brands to navigate the increasingly complex regulatory landscape pertaining to trademark, advertising, and consumer protection issues. He provides counseling and compliance advice on a variety of advertising matters, working with clients to minimize regulatory and litigation risks while advancing their business and marketing goals.

Ryan has an active and diverse pro bono practice consisting of both litigation and regulatory matters.