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'Product of USA' and country-of-origin labels

'Product of USA' on a pack of meat used to mean surprisingly little. A USDA rule that took effect in 2026 changed that — but it's voluntary, and it doesn't tell you the origin of every product. Here is what the label now means.

Updated June 19, 2026 · 3 min read · Sourced from FDA guidance

The old loophole, and the fix

Until recently, a meat product could carry 'Product of USA' if it was merely processed in the United States — even if the animal was raised abroad. The USDA's Food Safety and Inspection Service (FSIS) closed that gap with a final rule finalized in March 2024, effective May 17, 2024, with a compliance date of January 1, 2026.

What 'Product of USA' now requires

On meat, poultry, and egg products (the products FSIS regulates), the claims 'Product of USA' or 'Made in the USA' may be used only if the animal was born, raised, slaughtered, and processed entirely in the United States. For a multi-ingredient product, all FSIS-regulated components must meet that standard, all other significant ingredients must be of U.S. origin (spices and flavorings are excepted), and the processing must occur domestically.

Note

The claims stay voluntary — a company doesn't have to use them. But if it does, it must now meet the full born-raised-slaughtered-processed standard and keep documentation to back the claim (under 9 CFR 412.3). State-pride imagery — flags, state outlines, maps — is held to the same standard.

What it does NOT do

Crucially, this rule does not require origin labeling on every package, and it does not reinstate mandatory country-of-origin labeling (mCOOL). Imported meat can still be sold with little or no origin information — if there's no claim on the pack, you still can't tell where it came from. The rule polices the accuracy of a voluntary claim, not the disclosure of origin across the board.

'Product of USA' vs. mandatory COOL

Two different things are easy to confuse:

  • Mandatory Country-of-Origin Labeling (mCOOL) — administered by USDA's Agricultural Marketing Service (AMS) — requires origin labeling for certain commodities (for example, fish and shellfish, fresh produce, and some nuts). Mandatory COOL for beef and pork was repealed in 2015 after a WTO trade dispute.
  • The FSIS 'Product of USA' rule — governs whether a voluntary U.S.-origin claim on meat, poultry, or eggs is truthful.

In short, mCOOL is about whether origin must be disclosed for some foods; the FSIS rule is about whether a 'Product of USA' claim is accurate when a company chooses to make it.

And FDA-regulated foods?

This rule is USDA/FSIS territory — meat, poultry, and eggs. For most other foods (the FDA-regulated grocery aisle), country-of-origin marking is handled under customs law by U.S. Customs and Border Protection, separate from the FSIS claim and from the FDA label rules covered across our guides.

Frequently asked questions

What does 'Product of USA' mean on meat now?
After the USDA FSIS rule that took effect January 1, 2026, 'Product of USA' or 'Made in the USA' on meat, poultry, or egg products means the animal was born, raised, slaughtered, and processed entirely in the United States. For multi-ingredient products, all FSIS-regulated components must meet that standard and other significant ingredients (except spices and flavorings) must be domestic.
Is 'Product of USA' required on every package?
No. The claim is voluntary. Companies don't have to use it, and imported meat can still be sold with little or no origin information. The rule only governs the accuracy of the claim when a company chooses to make it.
Did this rule bring back mandatory country-of-origin labeling?
No. It does not reinstate mandatory COOL. Mandatory country-of-origin labeling for beef and pork was repealed in 2015; the FSIS rule simply tightened the standard for the voluntary 'Product of USA' claim.
What's the difference between COOL and 'Product of USA'?
Mandatory COOL (run by USDA's AMS) requires origin labeling for certain commodities like fish, produce, and some nuts. The FSIS 'Product of USA' rule governs whether a voluntary U.S.-origin claim on meat, poultry, or eggs is accurate. One is about required disclosure; the other about claim accuracy.

Sources

Related tools & guides

This guide is general educational information, not legal advice, and labeling rules can change. Your obligations depend on your specific products, claims, sales, and state. Verify your situation against the current FDA guidance and eCFR linked above, or consult a qualified food-labeling professional, before printing a label.