By Julie Holt, Global Director Regulatory Advisory Services
Key Takeaway: The United States Department of Agriculture now allows voluntary U.S.-origin (“Made in the USA”) claims only when the product is derived from animals that were born, raised, slaughtered and processed in the United States.
FoodChain ID experts in Regulatory and Scientific Consulting offer global guidance to meet the evolving demands of the food and beverage marketplace.
Domestic-origin claims are under increased scrutiny. As of the first of the year, the U.S. Department of Agriculture (USDA) rules are now in effect for when federally inspected meat, poultry and egg products can voluntarily carry “Product of USA” (and related “Made in the USA”) claims.
If a business sells into U.S. retail channels—or supply brands that do—this change directly impacts label compliance, substantiation files and documentation of animal sourcing and processing steps.
What changed with Made in the USA—and why it matters
Under the final rule, the USDA permits voluntary U.S.-origin claims only when the product is derived from animals that were born, raised, slaughtered and processed in the United States.
This is a material shift from prior market practice, where products that were only packaged in the U.S. could still carry “Product of USA.”
USDA’s stated intent is increased sourcing transparency for consumers and stronger support for domestic agriculture and ranchers.
Who is affected (and who is not)
In scope
- Federally inspected meat, poultry and egg products sold at the retail level.
Out of scope
- Food service and restaurants are exempt from these new rules.
Compliance is already in effect
USDA set January 1, 2026, as the compliance date for origin claims. Labels must now be updated to meet the new requirements.
As of January 3, 2026, organizations that have not completed updates should treat this as an immediate compliance priority—especially for any products currently bearing “Product of USA” or similar claims in retail distribution.
While these are considered generic claims, USDA expects companies to maintain documentation to substantiate that the product meets the standard. In practice, that typically means supplier records and internal controls for each relevant lot.
Operational implications across the supply chain
For many businesses, the hardest part won’t be changing label artwork—it will be ensuring that sourcing and traceability systems can consistently support the claim at scale.
Common pressure points include:
- Supplier qualification: confirming upstream partners can provide U.S.-origin evidence consistently.
- Segregation and changeovers: preventing commingling of U.S. and non-U.S. inputs where claims differ.
- Lot-level recordkeeping: proving claim integrity for audits, customer requests or enforcement inquiries.
- Customer alignment: ensuring brand owners, co-packers and private label retailers interpret the standard consistently.
Practical checklist for compliance and risk reduction
- Inventory affected SKUs and labels
- Identify all retail products using “Product of USA,” “Made in the USA,” or similar U.S.-origin language.
- Map end-to-end origin and processing steps
- Validate “born/raised/slaughtered/processed in the U.S.” can be supported for each SKU/plant combination.
- Standardize substantiation files
- Define what “good evidence” looks like (supplier affidavits, certificates, production records, receiving/kill sheets, etc.) and set retention rules.
- Update labels and approvals workflow
- Ensure updated labels are routed through the appropriate internal and regulatory review process before printing and distribution.
- Train commercial and QA teams
- Align Sales, Marketing, QA and Regulatory on what can and cannot be claimed—and what documentation must exist before a claim is used.
Bottom line for USDA’s Made in USA Labeling Rule
USDA’s tightened “Product of USA” claim now requires full U.S. lifecycle and processing alignment—not just U.S. packaging—along with documentation to back it up.
If your business operates in federally inspected meat, poultry or egg supply chain serving retail, your immediate objective should be to confirm claim eligibility at the SKU/lot level, close documentation gaps, and ensure all labels in market meet the new requirements.
About the Author
Julie Holt is a subject matter expert in the areas of food and beverage, additives, and regulatory strategy. She has beverage industry expertise and currently provides consulting support across multiple beverage categories. Ms. Holt has more than 25+ years of regulatory experience in the food and food ingredients industries and managed her own advisory firm, Scientific & Regulatory Solutions LLC, prior to joining FoodChain ID. As a consultant, Julie supported several food and beverage clients including a Fortune 50 company. Julie has provided global regulatory knowledge covering more than 200 countries.