The Federal Trade Commission (“FTC”) announced that it reached a settlement with iSpring Water Systems, LLC for allegedly making false claims that its wholly imported Chinese water filtration systems were made in the U.S.A – in violation of a 2017 FTC consent order.

In 2017, the company made certain claims that its water filtration systems and parts were “Built in USA,” “Built in USA Legendary brand of water filter,” and “Proudly Built in the USA.” According to the FTC, these products were imported or were made with a significant amount of imported parts. In the FTC’s 2017 consent order, which we previously wrote about here, iSpring agreed not to make unqualified claims that its water filtration systems were made in the U.S.A. unless it could substantiate those claims.

Now, the FTC alleged that iSpring violated the consent order by advertising that the imported products were “made in USA” or “designed and crafted in USA.” The FTC’s settlement includes a $110,000 penalty, an admission of liability, and a requirement to notify consumers.

TAKEAWAY:  This case signals the FTC’s continuing interest in policing “made in the USA” claims and serves as an important reminder to marketers to comply with any consent order that it enters into with the FTC to avoid severe civil penalties.