What "Made in the USA" on Pet Treats Actually Means

What the FTC rule requires

The rule is short, and it is a rule rather than a guideline. The FTC’s Made in USA Labeling Rule, 16 CFR Part 323, defines the claim first. “The term Made in the United States means any unqualified representation, express or implied, that a product or service, or a specified component thereof, is of U.S. origin, including, but not limited to, a representation that such product or service is ‘made,’ ‘manufactured,’ ‘built,’ ‘produced,’ ‘created,’ or ‘crafted’ in the United States or in America, or any other unqualified U.S.-origin claim.”

Then it says when the claim is allowed. It is “an unfair or deceptive act or practice” to label any product as Made in the United States “unless the final assembly or processing of the product occurs in the United States, all significant processing that goes into the product occurs in the United States, and all or virtually all ingredients or components of the product are made and sourced in the United States.” Three conditions, and all three have to hold. A treat baked in Ohio from chicken raised somewhere else does not meet the third one, so an unqualified claim on that bag would be deceptive under the rule. The word that does the work is “unqualified.” A label that says “Made in the USA with imported ingredients” is making a different, qualified claim, and the rule as written defines the unqualified one.

The rule also says what it does not displace. It “shall not be construed as superseding, altering, or affecting the application of any other federal law or regulation relating to country-of-origin labeling requirements,” and it names the Federal Meat Inspection Act and the Poultry Products Inspection Act among them. A violation “shall be treated as a violation of a rule” under the FTC Act, which is what gives the commission the power to seek penalties for it.

What FDA found about jerky treats

The reason the question comes up for treats in particular is an FDA investigation that is still open. FDA’s page, FDA Investigates Animal Illnesses Linked to Jerky Pet Treats, opens with the date: “Since 2007, FDA has received reports of illnesses in pets associated with the consumption of jerky pet treats.” As of December 31, 2015, it had “received approximately 5,200 complaints of illnesses associated with consumption of chicken, duck, or sweet potato jerky treats, many of which involve products imported from China, which produces much of the jerky pet treats on the market. The reports involve more than 6,200 dogs, 26 cats, three people, and include more than 1,140 canine deaths.”

Two sentences on that page keep the finding where FDA left it. “Although it is impossible to conclude definitively in every case whether the events reported were caused by eating jerky pet treats, FDA continues to believe that there is an association between some of the reports and consumption of jerky pet treats.” And on the cause: “To date, testing for contaminants in jerky pet treats has not revealed a single root cause for the many different reported illnesses.” FDA says it tested roughly 530 treat samples tied to complaints and more than 450 retail samples, and that its testing “included measuring the nutritional composition of jerky pet treats” to verify “that they contain the ingredients listed on the label and do not contain ingredients that are not listed on the label.” This post reports those statements and adds nothing to them. An association is not a cause, and FDA says so.

What a treat label can leave out

The sentence on FDA’s page that matters most for a shopper is about the label. “Pet owners should be aware, however, that manufacturers are not required to list the country of origin for each ingredient used in their products.” So a bag can name the country where it was made or packaged and say nothing about where the chicken or the sweet potato came from. The FTC’s unqualified claim is the one label statement that, by rule, speaks to the ingredients as well as the processing. A bag without it has not made that statement, and a bag that says “distributed by” a company in one state has said nothing about origin at all.

What this post does not say is that any treat is safe or unsafe, or that origin decides either. FDA’s own page draws that line, and so does this one. How to Read a Pet Food Label covers the parts of a label that are required, and What the VOHC Seal on Dog Dental Chews Actually Means covers one mark that is checkable against a public list. When Runlow holds records for pet treats, each record will carry what the brand’s own page says about origin, in the brand’s words, with the date it was read.

Where this comes from

Every statement above is quoted from two sources, read on October 12, 2026: the FTC’s Made in USA Labeling Rule as published in the Code of Federal Regulations at 16 CFR Part 323, and FDA’s page on its jerky pet treat investigation. Runlow has not tested any treat, holds no product records for pet treats yet, and makes no claim about any product’s origin or safety. Nothing here is veterinary advice.