Mistake, Pattern, Or Deceptive Scheme? A Forensic Expert’s Framework For Evaluating Deceptive Trade Practices Allegations

Regulators are taking a closer look at how companies describe what they sell. In April 2026, following a March 2026 executive order on truthful “Made in America” advertising, the Federal Trade Commission announced a “Made in the USA” series of enforcement actions against companies that advertised their products as American made when the products, or key components of those products, came from outside the United States. Recent enforcement actions have included a manufacturer that completed assembly in the United States but relied on imported chips, cameras, and monitors; a footwear company that sourced key components from the Dominican Republic and Brazil; and a U.S. flag seller that marketed products as American-made even though they were manufactured entirely in China. These cases highlighted recurring deceptive-practice issues, including false country-of-origin claims, unsubstantiated advertising and labeling, and undisclosed foreign content.