Below is a sampling of Step2’s Made in the USA marketing, which makes the deceptive, unqualified claim that its product line meets the standard for “Made in the USA” despite the fact that 90% of Step2 products are wholly or partially made outside the U.S., with 5% made entirely in China, according to the Step2 website.

Promotional postcard:

Days before July 4, 2017, Step2 mailed the postcard below, which includes not one but two U.S. flags together with the unqualified assertion “made in the USA.” Moreover, on one side of the postcard a flag and “made in the USA” representation appears to modify the phrase, “over 300 kids toys to choose from,” which could lead a reasonable consumer to believe that Step2 has over 300 kids toys that are made in the USA.

Social media marketing materials:

Step2 also takes to social media to post patriotic images accompanied by the claim #madeintheusa, among other hashtags.  Below is a sampling of the company’s social media posts. (Click on the arrows on the side of the images to see slideshow.)

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Step2 Homepage –

On its homepage, Step2 again makes the unqualified claim “Made in USA,” accompanied by a map of the United States and the following explanation:

‘Made in U.S.A.’ Labeling Webpage on Step2 website:

Step2 also has an entire webpage devoted to its “Made in the U.S.A.” labeling, which lists 89 products as “Made in U.S.A.”  However, only 18 of the listed products — less than a quarter — are actually labeled as fully made in the United States, according to the individual product pages.  The other 71 listings contain imported parts.

* Note that some of the 89 products listed under the “Made in U.S.A.” heading are listed more than once, and that some of the listings are not individual products, but rather combo sets that combine products.