What "Made in USA" legally means on a walk-in tub

Published by Aging Safely Baths. Facts checked October 15, 2026.

The standard: "all or virtually all"

The Federal Trade Commission has applied the same test to U.S. origin claims for decades, and it published its business guide, Complying with the Made in USA Standard, in updated form in July 2024. The core idea is simple: when a maker says a product is made in the United States without any qualifier, buyers are entitled to assume it has no foreign content, or only a negligible amount.

To decide whether a product meets that bar, the FTC first requires final assembly or processing in the United States. It then weighs:

• Cost share. How much of the total manufacturing cost is U.S. parts and processing.
• Distance. How far removed any foreign content is from the finished product. Imported raw resin several supplier steps back weighs less than an imported finished door.
• Importance. Whether the foreign part matters to the product's form or function. The FTC's own example is a food processor with an imported motor: it cannot be sold as unqualifiedly made in the USA.

For a walk-in tub, that last point is the one to think about. The shell, the door and its seal, and on jetted models the pump, blower and heater do the real work. If any of those is imported, an unqualified "Made in USA" claim is hard to support.

The 2021 Labeling Rule: 16 CFR Part 323

In July 2021 the FTC published the Made in USA Labeling Rule in the Federal Register, codified at 16 CFR Part 323. It took effect on August 13, 2021. The rule does two things that matter to buyers:

1. It defines the claim broadly. Section 323.1 covers any unqualified representation that a product is of U.S. origin, including saying it is "made," "manufactured," "built," "produced," "created" or "crafted" in the United States or in America.
2. It sets the test in regulation. Section 323.2 makes it an unfair or deceptive act to label a product "Made in the United States" unless final assembly or processing happens here, all significant processing happens here, and all or virtually all ingredients or components are made and sourced here.

The rule applies to labels on the product and its packaging, and to mail order and online promotional material, which is how many walk-in tubs are marketed. Violations can bring civil penalties for each violation, at a dollar amount that is adjusted for inflation every year. Claims outside the rule's scope, such as a TV ad, are still covered by Section 5 of the FTC Act.

The claim ladder, from strongest to weakest

Each rung below tells you less about where the tub's parts came from. The bar under each one is our plain-language illustration of how much U.S. content the wording promises, not a legal percentage.

1. Made in USAAll or virtually all U.S. parts and processing, with final assembly here. Also covers "built," "manufactured" or "crafted" in the USA.
2. Made in USA of U.S. and imported partsA qualified claim. Fine to use when the product has a significant amount of U.S. content or processing. A specific variant names the share or the part, such as "60% U.S. content" or "imported pump."
3. Assembled in USAPrincipal assembly happened here, the assembly was substantial, and the last "substantial transformation" of the product happened here. Bolting together a kit of imported parts ("screwdriver assembly") usually does not qualify.
4. Designed in USAA claim about design work only. The FTC's example is "Designed in USA, Made in Finland." The tub itself may be imported.
5. Made in [another country]Imported goods must carry a foreign origin mark under the Tariff Act. A U.S. brand name or a flag on the box does not change that.

Reading real walk-in tub wording

Here is how that vocabulary applies to the kinds of phrases walk-in tub makers actually publish. The exact statements, with sources, are on our list of U.S. walk-in tub manufacturers.

• Made in followed by a city and state, or built in the USA: an unqualified U.S. origin claim. The maker is saying all or virtually all of the tub is domestic.
• Designed and assembled in a named city: an assembly claim. Useful and specific, but it does not tell you where the shell, door, pumps or faucet came from.
• Drilled, jetted and assembled in the United States: a claim about specific processing steps. It tells you what happens here; ask where the shell is formed.
• American company, American owned or a flag in the logo: not an origin claim about the tub at all. Ask directly.

Things the rule does not do

• It does not certify anyone. The FTC does not pre-approve origin claims. Private "certified" seals are separate programs with their own criteria.
• It does not require a label. There is no general federal requirement to label a product "Made in USA." Silence is not a claim either way.
• It does not set a percentage. The FTC uses the cost, distance and importance factors above instead of a fixed number.
• It is not the government purchasing test. Federal agencies buying under the Buy American statute use a different, percentage-based test. See our Buy American guide for VA and government buyers.
• It does not grade quality. A true U.S. origin claim says where a tub was made, not how good it is. Our guide on comparing U.S.-made and imported tubs covers what to check instead.

California's separate rule

California has its own Made in U.S.A. statute, Business and Professions Code section 17533.7. As amended by SB 633 (2015), effective January 1, 2016, it allows a "Made in U.S.A." label on products sold in California when foreign parts make up no more than 5% of the final wholesale value, or no more than 10% when the maker can show those parts cannot be made or obtained in the United States. A tub sold nationwide has to satisfy the FTC standard as well.