[bcohen5055]

This qualifier is actually more about lawyers and accountants. The US has a very unclear policy about labeling something as USA Made. It comes down to the US content in the BOM cost and it is specific to costs essential to the product, at my last 2 companies these decisions were left to accounting and legal.

In my current company we make sunglasses a non-polarized pair of sunglasses will say made in USA and a polarized pair will say assembled in the USA because the polarized wafers are not domestically made. In both cases the boxes, stickers, and logos are non domestic but aren't counted because they "aren't essential". In my previous company anything that had electronics from overseas had to be "assembled" but electronics from NAFTA areas were "usa made"

In reality it doesn't make much sense to ever have a BOM 100% USA made as that fully negates the benefits of trade but we should have policies that still encourage companies that chose to conduct business here. When consumers are turned off by "assembled in" it drives business out of the country.

*I work as a product development engineer for consumer goods. My current role and previous company both had US MFG sites

Edit: here is a link to the requirements https://www.nist.gov/standardsgov/compliance-faqs-made-usa#4