US Product Labeling Requirements for Importers: What Must Be on Every Package

US product labeling requirements come from three main federal agencies, each with distinct jurisdiction: US Customs and Border Protection (CBP) enforces country of origin marking. The Federal Trade Commission (FTC) regulates textile, fur, and wool labeling, and the "Made in USA" standard. The Consumer Product Safety Commission (CPSC) requires safety warnings and certification marks on consumer products in regulated categories.

Additional agencies apply to specific products: FDA regulates food, dietary supplement, cosmetic, and drug labeling; USDA regulates organic claims and meat/poultry; EPA regulates pesticide and certain chemical product labels; NHTSA covers automotive products. An importer's compliance checklist must identify which agencies have jurisdiction over their specific product before finalizing label design.

Non-compliance consequences range from CBP detention and re-exportation of the shipment, to FTC enforcement actions, CPSC civil penalties (up to $100,000 per violation under current law, higher for patterns of violations), and recall obligations. Label compliance is not an area to leave to guesswork.

Every article of foreign origin entering the US must be marked with its country of origin in a conspicuous place, in a legible, indelible, and permanent manner, using English. This requirement comes from 19 USC §1304 and CBP regulations.

"Made in Taiwan" or "Product of Taiwan" is the required marking for Taiwan-origin goods. The marking must be legible without magnification and placed where it will be noticed by the ultimate purchaser — typically on the product itself, the label, or the minimum retail package.

Substantial transformation rule: if a product is manufactured in Taiwan using components from multiple countries, origin is generally the country where the last substantial transformation occurred. If you assemble a product in Taiwan from imported parts, "Made in Taiwan" is typically correct as long as the assembly in Taiwan creates a new and different article with a distinctive name, character, and use.

USMCA and other free trade agreements do not apply to Taiwan-origin goods — Taiwan currently does not have a free trade agreement with the US. Mark clearly as "Made in Taiwan" and ensure accurate import classification to apply the correct tariff rate.

The FTC requires that textile products (clothing, bedding, towels, etc.) carry permanent labels stating: fiber content (e.g., "100% Cotton"), country of origin, manufacturer or dealer identity (RN number or company name), and care instructions. Care labels must be permanently attached and remain legible for the useful life of the product.

"Made in USA" claims are strictly regulated by the FTC and require that the product is "all or virtually all" made in the US — meaning all significant parts, processing, and labor must be of US origin. Taiwan-manufactured products cannot carry unqualified "Made in USA" claims. Qualified claims ("Assembled in USA from globally sourced components") may be permissible in limited circumstances — consult an FTC compliance attorney before using.

Language: all required label information must be in English. A bilingual label (English + another language) is permissible, but English must be included. All mandatory disclosures — origin, safety warnings, ingredient lists — must be legible in English.

For electronics and electrical products, Underwriters Laboratories (UL), ETL, or CSA marks (all OSHA-recognized Nationally Recognized Testing Laboratories) provide safety certification. While not always legally required, US retail buyers (Amazon, Best Buy, Target) typically require a recognized safety mark for listing products. Obtaining UL certification for a new product typically takes 8–16 weeks and costs $1,000–$15,000 depending on complexity.

Children's products: CPSC requires a Children's Product Certificate (CPC) for products intended for children under 12. The CPC must be based on third-party testing by a CPSC-accepted laboratory. Labels must include a tracking label (importer/manufacturer name, date/location of production, batch number) to enable recalls. Lead content must be ≤ 100 ppm in surface coatings.

Dietary supplements: FDA requires a Supplement Facts panel (similar to Nutrition Facts), serving size, ingredient list, net quantity, manufacturer/distributor name, and "These statements have not been evaluated by the FDA..." disclaimer. Supplement labels cannot claim to diagnose, cure, treat, or prevent any disease.

Cleaning products and chemicals: California Proposition 65 warnings may be required even for non-California sales if products are distributed nationally. Products containing listed chemicals above thresholds require "WARNING: This product can expose you to chemicals including [chemical name], which is known to the State of California to cause cancer/reproductive harm."

Practical workflow: finalize your US label design 8–12 weeks before first shipment. Submit to a US compliance attorney or label compliance consultant for review. Print production labels only after legal review — reprinting labels on goods already manufactured is expensive. Consider purchasing pre-made label templates for common product categories from label design services familiar with US requirements.