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.
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 Mandatory COOL for beef and pork was repealed in 2015 after a WTO trade dispute.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.