Separate where a business operates from where a product is made

Capture the impression as well as the sentence

Record the visible words, nearby imagery, badge, caption and page location together. The FTC guidance considers the overall impression, including implied US-origin claims. Reviewing only the text inside a product description can miss a sitewide banner or image that appears to describe the same goods.

The distinction between qualified and unqualified wording matters. An unqualified US-origin claim invokes the FTC's all-or-virtually-all standard; a qualified claim states a limitation. Adding a qualification does not automatically establish that the result is substantiated or that the surrounding presentation is consistent with it. Preserve the exact limitation for review instead of treating any added qualifier as approval.

An ordinary, nonprominent US address alone is not necessarily an implied origin claim under the guidance. Do not automatically classify every contact address as one. Record how it is presented and what surrounds it, so the review can distinguish a statement about the business from a statement about the products.

Match manufacturing evidence to the goods actually covered

Identify whether the statement names one product, one batch, a product line or the whole catalog. Then index the sourcing and manufacturing records that address that scope. For each record, note the product identifiers it covers, its date, the manufacturing facts it actually states and the person or organization that supplied it. A document about a supplier's office address does not answer where a particular product was made.

The FTC guidance says product-line claims need support across the covered products. A record tied to one item cannot establish the unexamined manufacturing history of the rest. Mark uncovered items explicitly in the internal review. The practical decision is whether the public claim extends further than the available substantiation, not whether one impressive document can be placed beside every listing.

When a record describes only one activity, preserve that limit. Do not rewrite it internally as proof of the entire manufacturing origin. Identify the missing manufacturing or sourcing fact and request evidence that addresses it. A list of documents is useful only when the reviewer can see which part of the claim each document supports.

Keep seller location in a separate record

A business can have a documented headquarters location while the origin of a particular product still needs substantiation. The FTC guidance separates headquarters from manufacturing origin. Keep the business-location evidence in its own column so that an unresolved product-origin question does not disappear behind a verified company address.

For a WooCommerce store, the configured store address is the seller location used for tax and shipping calculations. That setting is not manufacturing evidence and does not establish that the address is a laboratory or public facility. The settings documentation also does not establish what the public homepage displays. Read the actual public claim and match it to the type of record it requires.

Revisit support when sourcing changes

Record the effective period of the sourcing evidence and any known supplier or manufacturing change since it was obtained. The FTC guidance warns that changing sourcing can undermine earlier substantiation. A previously reviewed sentence should not be treated as supported indefinitely when the goods behind it have changed. Identify the affected products and public surfaces before deciding what wording can remain.

The resulting record should distinguish a documented location fact, manufacturing evidence that addresses the claim, and an unresolved gap. Where scope exceeds the records, hold or remove the unsupported claim while obtaining the missing facts and appropriate review. Qualified counsel should assess the specific US-origin statement and applicable labeling requirements. The FTC does not preapprove a particular claim, and this worksheet does not extend its guidance to every jurisdiction.

Prism can discuss the affected public pages through a scoped website-review consultation. Send the website, research-only products and the origin wording you want reviewed, with a summary of the evidence gap rather than private supplier files. Scope, fees and terms are discussed before work; legal conclusions and provider eligibility remain separate. The public inquiry receives email follow-up and does not book an appointment, purchase a review or submit a processing application.

Origin-claim record

Complete one record for each distinct origin claim and its covered products. Keep private sourcing documents in your own controlled records and enter only non-sensitive references here. A location record cannot close a manufacturing gap; unresolved scope or sourcing changes become a specific evidence request and counsel question.

Worksheet entries are not submitted by Prism’s worksheet and are not saved by the site. Use record types, availability, anonymized observations, or match/mismatch results. Do not enter government identifiers, customer names or addresses, customer messages, receipt-access links, card or bank details, passwords, or keys. Send sensitive documents only through the provider’s verified secure channel.

These are temporary notes. Leaving or reloading this page may clear them. Worksheet entries are not sent automatically. If you copy notes into the consultation message and submit the form, Prism receives them as part of your request.