Red Wing Shoes

When the rubber meets the road, this $360 pair of Red Wing women’s boots is not a legally defensible “Made in USA” product. And we mean that literally: the rubber outsole on the bottom of the shoes is made in Italy.

According to the FTC, one of the factors considered by the agency in determining whether a product meets its Made in USA standard is the importance of the foreign content or processing to the overall function of the product. Given that it provides the wearer traction, the outsole of a shoe is a pretty important piece of the puzzle. On its website Red Wing even promotes this particular outsole for “21st century adventures.” So in this case, the foreign content is not, to use the FTC’s term, negligible. As a result, claims on the outside of the box that the shoes are “Made in USA,” and a statement about “USA-made excellence” on a piece of paper inside the box, are deceptive under FTC law.

The first sign that the boots did not meet the FTC’s legal definition for “Made in USA” came when TINA.org peeled back the tongue of the shoe and read the following: “Made in U.S.A. of U.S. and Imported Parts.” That’s what you would call a qualified claim, as opposed to an unqualified claim like “Made in USA.” (We would venture to say that the FTC would likely have no problem with the use of a qualified claim on the box or in the written statement.) The tongue did not name the imported parts but our suspicion that they included the Vibram outsole was confirmed by a Red Wing customer service representative.

“The outsole is from Italy,” the representative said in an online chat on the shoemaker’s website, which doubles down on the “Made in USA” claims.

In fact, Clara Style No. 3406 is not the only Red Wing women’s boot with a Vibram outsole that is marketed as “Made in USA.” On the Red Wing website, six women’s boots in 18 styles identify Vibram as the maker of the outsole, though none of the product pages reveal where the outsole is made. (Vibram is based in Albizzate, Italy, about 30 miles northwest of Milan.) Meanwhile, a conspicuous “Made in USA” logo hovers above, seeming to imply that all of the boots are 100-percent American-made.

TINA.org reached out to Red Wing for comment. Check back for updates.

Find more of our coverage on made in the USA claims here.

This article was updated on 5/22/20.