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Vinotemp Wine Coolers

FTC publishes first closing letters since Made in USA Labeling Rule went into effect in August.

Vinotemp’s made in the USA claims were recently the subject of an FTC inquiry that resulted in a closing letter to the company. The FTC wrote:

During our review, we discussed concerns that marketing materials may have overstated the extent to which certain wine coolers and wine cellar cooling units are made in the United States. Specifically, certain marketing materials were not sufficiently clear that they applied to particular wine cooling and storage products assembled in the USA, and may have suggested to consumers that all Company products underwent significant USA processing. Although Vinotemp assembles certain products in the United States, it also sells a line of wholly imported products.

The agency continued:

As discussed, it is appropriate for Vinotemp to promote the fact that it employs workers, performs certain functions, and sells a line of products that are assembled in the United States. However, marketing materials should not convey that products are “all or virtually all” made in the United States unless the Company can substantiate those claims. Accordingly, to avoid deceiving consumers, Vinotemp removed unqualified U.S.-origin claims from all marketing materials, including social media, required dealers to update marketing materials consistent with this change, and trained all staff.

The FTC told the company based on these actions and other factors, it decided not to pursue the investigation any further.

Vinotemp is among the first companies to receive a closing letter from the FTC regarding U.S.-origin claims since the agency’s Made in USA Labeling Rule went into effect in August, a direct result of a petition for rulemaking filed in 2019. The letter notes that the rule allows the FTC to seek civil penalties of up to $42,792 per violation of the rule.

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

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