Using Domestically Sourced Recycled Content? Look Beyond The Recycling Process Before Claiming It's "Made In USA"

We periodically stumble across older FTC investigations that have new relevance, and post about them as reminders. That happened recently as we get more questions about the use of recycled content and the desire to tout U.S.-based manufacturing. Although the FTC's Enforcement Policy Statement and regulation regarding Made in USA claims do not mention how to evaluate recycled content, in a 2014 FTC Staff Advisory Opinion the Staff declined to consider the recycling process as a "new life cycle" and disregard the origin of the jewelry returned for recycling.

The requestor acknowledged that jewelry returned for recycling is often of unknown origin, but asserted that significant time and resources go into collecting recyclable material, delivering it to refiners in the United States, and processing it to a purity level of almost 100%, equating this to a "new life cycle" that resets the origin of the recycled material. Consumer perception testing submitted with the