Origin-claim checks that people do not learn to ignore

The failure mode for any automated origin-claim check is not missing things. It is training the marketer to click past it. A tool that flags every sentence containing “made” ends up ignored on the unqualified “Made in USA” badge that actually carries FTC risk. A pre-print check has to earn its seat on every run: deliberate about what it blocks on, what it warns about, and what it refuses to judge. The FTC Made in USA Labeling Rule (16 CFR Part 323) is more useful as an ordering of attention than as a legal textbook, because it already separates claims that mislead by their very structure from claims that merely need a clearer qualifier.

Block on what is categorically wrong in the wording

Some constructions are facts about the paste, not opinions about your supply chain. Copy that asserts a US origin (“Made in USA”) and a foreign origin (“Made in China,” “Imported”) in the same label is internally contradictory and a false designation of origin whichever half is untrue — that is a block, full stop. So is an unqualified “Made in USA” / “American-made” that § 323.2 holds to all-or-virtually-all domestic; if it is not, the wording claims a certainty the rule forbids without qualification. Block before print on these, because these are the findings that escalate into FTC enforcement and relabels.

Warn on what is fixable by qualifying

The middle tier is where a good check earns its keep. A “Designed in USA” line that could imply US manufacture; an “Assembled in USA” with no statement of where the parts came from; a “Made in Vermont” state claim; an “80% US content” figure with no disclosed basis — each is usually fixable by adding a clear qualifier or stating the true origin, and whether the fix is urgent depends on how prominent the claim is and which surfaces carry it. Warn, quote the sentence, and let a human attach the supply-chain facts.

Leave alone what cannot be decided from the text

Whether your product really is all-or-virtually-all US, whether the final assembly is “substantial,” whether your bill of materials supports the percentage, whether a customs origin determination matches your label — those live in cost accounting, factory records, and filings, and an origin checker that pretends otherwise is producing confident noise. The honest move is to say plainly: I read your wording; I cannot audit your supply chain. A tool that claims your label is now “FTC-approved” is lying about what a text scan can do.

Qualification logic beats a banned-word list

The naive approach is a list of forbidden phrases: block “Made in USA,” block “American,” block “assembled.” It fails twice. First, it blocks lawful, fully-domestic products that may truthily say “Made in USA,” and lets through paraphrases the list never anticipated. Second, the rule is not a word list at all; § 323.1 and § 323.2 turn on what a reasonable consumer would take from the label and on whether a qualifying disclosure clears the implication. The same “Assembled in USA” is fine with a parts-origin note and deceptive without one. That context — is the qualifying language present, and prominent — is deterministic to check, and is exactly what a pre-check should rank findings by instead of blacklisting words.

The tiers shift with surface

An origin claim baked into a product or brand name (“AmeriBuilt”) has almost no room to carry the nearby qualifier that makes it honest, so it deserves stricter handling than the same claim in website body copy where a “Made in USA from imported parts” line can sit right beside it. And the rule reaches beyond physical packaging — § 323.3 covers mail-order and online advertising, so a product page counts. A pre-check that lets you say the surface — label, ad, web page, brand name — and escalates accordingly is more useful than one that treats every paste identically.

A habit that stays alive

Teams who keep an origin check alive run it on a fixed cadence: one scan per label or ad draft, before print, never after the packaging file is locked. The scan stays fast because it is mechanical — locate US-origin phrases, spot assembled/designed claims, find foreign designations, look for qualifiers, catch state and percentage claims — and produces the same ranks every time against the same published rule. If the block tier is cleared before a human reads the draft, the human then spends their effort on the supply-chain evidence the tool deliberately refused to invent, and the check earns its place instead of being muted in a week.

Heuristic pre-check only — not a country-of-origin certification or legal advice. No bill-of-materials, cost-accounting, customs, or facility verification is performed; those facts live outside the wording a checker can read. For binding guidance, consult the FTC Made in USA Labeling Rule (16 CFR Part 323) and a qualified professional.