The Made-in-USA standard, explained.

Made-in-USA is regulated by the Federal Trade Commission under Section 5 of the FTC Act, which prohibits unfair or deceptive practices in commerce. The 1997 Enforcement Policy Statement on U.S. Origin Claims, codified into Rule 16 CFR Part 323 in 2021, sets the standard.

An unqualified "Made in USA" claim requires the product to be "all or virtually all" made in the United States — meaning final assembly is U.S.-based and all significant processing and components are domestic. Imported components are allowed only if they represent a negligible portion of total cost and would not change a reasonable consumer's understanding of the claim.

A cap that qualifies for an unqualified Made-in-USA claim must have: fabric milled in the U.S. (cotton spun, woven, and finished domestically); sweatband, brim board, and major components sourced domestically; cutting, sewing, and decoration all performed at U.S. facilities; and any imported components (small fasteners, certain plastics) limited to a negligible portion of total cost.

Competition Headwear caps qualify because Denver-based cut-and-sew and decoration use U.S.-milled fabric and U.S.-sourced components. Imported components are limited to negligible items like certain plastic snapback strips, and the cost of those items is well under the FTC's de minimis threshold.

The FTC allows two kinds of country-of-origin claims. An unqualified claim — "Made in USA" with no caveats — requires the all-or-virtually-all standard above. A qualified claim — "Assembled in USA from imported components," "Made in USA of U.S. and imported parts," "Designed in USA" — discloses the level of foreign content explicitly.

Manufacturers who do final assembly in the U.S. but use significant imported components must use a qualified claim. The FTC has pursued enforcement against companies using unqualified claims when the underlying product did not meet the all-or-virtually-all threshold.

The Made-in-USA standard is a civilian marketing rule under the FTC. The Berry Amendment is a DoD procurement rule under federal acquisition law. The FTC standard requires "all or virtually all" U.S. content — a strict but practical standard. Berry requires 100% — no foreign content allowed except for narrowly-defined exceptions.

A cap that satisfies Berry automatically satisfies the FTC Made-in-USA standard. A cap that satisfies the FTC standard may not satisfy Berry if it contains any foreign content beyond Berry's narrow exception list. Buyers who need both should specify both — and most Berry-compliant caps are dual-eligible.

An unqualified Made-in-USA claim on a cap tag, hangtag, marketing copy, or product page is enforceable under the FTC standard. Buyers who care about USA-made marketing want a cap that supports the claim through the full supply chain — not just final assembly in the U.S. with imported fabric.

End clients in trades, government, motorsports, lifestyle brands, and creator merch increasingly ask manufacturers to back the Made-in-USA claim with country-of-origin documentation upstream of final assembly. Competition Headwear provides this documentation on request: mill certifications for U.S.-spun fabric, component source statements, and a manufacturer's signed Made-in-USA compliance affidavit covering the finished cap.