On March 13, 2026, President Trump signed an Executive Order aimed at strengthening federal enforcement against false or misleading “Made in America” claims. The Executive Order directs the Federal Trade Commission (FTC) and other federal agencies to take coordinated action to ensure accuracy in country‑of‑origin labeling and to protect both consumers and legitimate U.S. manufacturers.

Overview of the Executive Order

The Executive Order is designed to combat fraudulent or inaccurate “Made in America” advertising—a practice the Administration says has increased in the digital marketplace, particularly among foreign manufacturers targeting U.S. consumers. The Executive Order aims to protect “True American-made businesses” by providing “undiluted branding benefits and protection from unfair competition by fraudsters.”

Key federal priorities now include:

  • Prioritizing FTC Enforcement. The Executive Order directs the FTC Chairman to prioritize enforcement actions against manufacturers or sellers who falsely claim their products are “Made in America” or make similar U.S.-origin claims in violation of existing law.
  • Coordinated Agency Rulemaking and Guidance. The Executive Order directs federal agencies with country-of-origin labeling authority to consult with the FTC to consider new regulations and unified guidance promoting voluntary, accurate U.S.-origin labeling for products made or manufactured in the United States.
  • Federal Procurement Scrutiny. The Executive Order directs agencies overseeing government‑wide acquisition contracts to review and verify domestic‑origin claims for products sold to the federal government. Per the Executive Order, misrepresented products must be removed from procurement programs, and violators are to be referred to the Department of Justice for potential False Claims Act actions.

Takeaways for Businesses

Companies making U.S.-origin claims—explicit or implied—should expect increased scrutiny from the FTC and other federal agencies, including increased risk of False Claims Act investigations by the Department of Justice. Sellers on digital marketplaces in particular may face an uptick in scrutiny due to the Executive Order’s emphasis on online misrepresentation.

Companies who make “Made in America” claims should consider reviewing:

  • All marketing materials referencing “Made in America,” “Manufactured in the USA,” or similar origin claims;
  • Labeling and packaging practices; and
  • Supplier certifications and origin documentation.

Moreover, given the anticipated cross‑agency coordination, businesses should evaluate whether their internal systems are able to document manufacturing location, assembly steps, and material sourcing.

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Photo of Timothy A. Butler Timothy A. Butler

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia…

Tim Butler helps companies thrive by developing tailored strategies to address their regulatory compliance challenges and vigorously defending them in government enforcement actions and bet-the-company lawsuits.

A former prosecuting attorney for the Federal Trade Commission (FTC) and former senior official in the Georgia Attorney General’s Office, Tim has led the defense of dozens of government investigations and enforcement actions brought by the FTC, the Consumer Financial Protection Bureau (CFPB), and the various state attorneys general. Tim also regularly defends clients in bet-the-company lawsuits, including complex business disputes and consumer class actions alleging privacy, false advertising, and unfair or deceptive business practice claims.

Tim is an experienced guide for companies struggling with regulatory complexity. He offers clear advice that helps his clients meet the demands of the ever-growing set of laws and regulations governing data privacy and cybersecurity, advertising and marketing practices, and consumer financial products and services. Clients rely on Tim’s business-minded and practical strategies to address their most difficult regulatory compliance challenges.

A graduate of the University of Chicago and Stanford Law School, Tim is a prolific author and regularly speaks to industry and trade groups about the evolving privacy landscape, about cutting-edge issues affecting payments and fintech companies, and about developments at the FTC, the CFPB, and within the state attorneys general community.

Photo of Matthew White Matthew White

Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.

Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the…

Matt White guides clients through regulatory compliance challenges and represents clients in regulatory and civil investigations and litigation.

Matt has counseled fintech and payment companies on regulatory compliance matters, including those involving the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Truth in Lending Act, and their respective implementing regulations (Regulations E, V, P, and Z). Adept with the Consumer Financial Protection Bureau’s (CFPB) Prepaid Rule, Matt has provided guidance regarding prepaid cards and related compliance.

Matt has also aided clients in developing regulatory compliant products and functionalities, including an earned wage access program, reimbursement prepaid card programs, new merchant cash advance products, and tokenized payment capabilities. In connection with products on which Matt advises, he has also negotiated high-stakes technology sales agreements involving complex regulatory issues, including compliance with data privacy laws, financial regulations, and card network rules.

Beyond helping clients strategize for regulatory complexity, Matt also helps clients navigate government investigations and enforcement actions brought by the Federal Trade Commission (FTC), CFPB, and state attorneys general.

Photo of Tessa Cierny Tessa Cierny

Tessa Cierny advises companies on financial technology and data privacy issues. She has experience counseling companies on state and federal regulatory compliance, including existing and emerging privacy laws, such as the E.U.’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act

Tessa Cierny advises companies on financial technology and data privacy issues. She has experience counseling companies on state and federal regulatory compliance, including existing and emerging privacy laws, such as the E.U.’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), as well as financial and banking regulations, such as the CFPB’s Section 1071 Small Business Lending Rule (Regulation B). In addition, she assists clients in defending business disputes and data breach litigation.

Prior to joining Greenberg Traurig, she served as global records manager for WestRock, where she developed and implemented email and data retention policies for global data privacy regulation compliance. In this role, she also advised on data privacy concerns related to data retention, data loss prevention, and data governance.