What qualifies a product to be labeled “Made in USA”?

To make an unqualified “Made in America” claim, a product must be “all or virtually all” made in the United States. This means final assembly occurs in the U.S., and nearly all materials, parts, and processing are of domestic origin. If significant imported content is involved, companies should use a qualified claim (e.g., “Assembled in the USA with imported parts”).

Why are “Made in America” claims facing increased enforcement?

Enforcement is increasing due to a 2026 executive order directing the FTC to prioritize action against deceptive U.S.-origin claims. Combined with existing rules that allow civil penalties, companies making unsupported claims face greater scrutiny, financial penalties, and reputational risk.

How can companies ensure their U.S.-origin claims are compliant?

Companies should treat country of origin claims as a compliance process by collecting and validating supply chain data, documenting sourcing and manufacturing details, and aligning marketing language with evidence. Claims should be reviewed across all channels — including labels, websites, and marketplaces — to ensure consistency and accuracy.

What changed in the 2026 EU Deforestation Regulation (EUDR) update?

The EU Council adopted revisions that postpone the application of the EU Deforestation Regulation (EUDR) while introducing simplification measures. Large and medium operators must comply by December 30, 2026, and small and micro operators have until June 2027. A new category of “downstream operator” was introduced, and certain small or micro primary operators may submit a simplified declaration instead of a full due diligence statement (DDS). These changes provide additional preparation time but do not reduce the regulation’s core due diligence and traceability requirements.

What are companies required to do under EUDR by 2026?

Companies placing in-scope products on the EU market must demonstrate that their goods are deforestation-free as of December 31, 2020; produced in accordance with the relevant legislation of the country of production; and covered by a DDS. This requires tracing commodities to the exact geolocation of the plot of land, conducting a risk assessment, mitigating identified deforestation risks, and maintaining auditable supply chain documentation. Commodities in scope include cattle, cocoa, coffee, palm oil, rubber, soya, and wood, along with many derived products.

What are the risks of non-compliance with EUDR?

Non-compliance penalties are determined by EU member states and may include fines of up to 4% of total annual EU turnover, confiscation of goods or revenues, temporary exclusion from public procurement, and public naming of non-compliant companies. Beyond financial penalties, the most immediate risk is loss of EU market access. Without a valid Due Diligence Statement, in-scope products cannot legally be placed on the EU market.

How should companies use the 2026 delay strategically?

The postponement to 2026 should be viewed as a strategic preparation window, not a pause. Companies should use this time to improve supplier engagement, close data gaps in traceability, implement structured risk assessment processes, centralize supply chain data management, and evaluate EUDR compliance software. Building traceability and defensible due diligence processes now will also strengthen readiness for related EU sustainability requirements.

AD-DSL Compliance Software With AI to Drive Productivity & Reduce Risk

Lead the industry with AI-native AD-DSL compliance. Assent simplifies Aerospace and Defense Declarable Substances List (AD-DSL) processes to help you move faster, reduce risk, and achieve unmatched supply chain visibility.

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Assent Eliminates Surprises & Simplifies AD-DSL Reporting

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Our AI can accept and analyze supplier declarations, even when they don’t use IPC-1754 or the AD-SRT Excel template.

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Simplify AD-DSL Compliance, Accelerate Productivity

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Automate supplier outreach, AD-DSL data collection, and validation with AI tools that flag inconsistencies and reduce review time.

Superior Supplier Engagement

The Assent Sustainability Platform offers AI-enhanced tools, 24/7 multilingual support, and expertise that make it easy for suppliers to proactively upload declarations.

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Case Studies

Supercharged Productivity With Automation

Woodward, an independent designer, manufacturer, and service provider of control solutions used in aerospace and industrial markets, is in scope of REACH, RoHS, and conflict minerals regulations. Their manual approach to compliance became insufficient as their requirements grew. With Assent, Woodward is now able to handle 10 times the compliance inquiries, creating deep insights without having to engage additional resources.

Joseph Auer

Product Material Compliance Project Manager, Woodward

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Ryerson joined forces with Assent in 2020 to overhaul their compliance processes. Using Assent for product compliance, including TSCA PFAS, streamlined their operations and drove cost savings equivalent to 20 full-time salaries. The company has seen a 50% improvement in supplier outreach campaign completion time and accuracy, as well as a reduction in resources needed to achieve compliance.

Andrea Okun

Deputy General Counsel & Chief Compliance Officer, Ryerson

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FAQ: AD-DSL Compliance

What is the AD-DSL?

The Aerospace and Defense Declarable Substances List (AD-DSL) defines which substances must be reported across aerospace and defense supply chains for compliance and environmental safety.

How does AI improve AD-DSL compliance and security?

AI automates supplier declarations, detects errors early, and generates insights that improve productivity and reduce risk. Assent supports multiple data submission formats, including IPC-1754, AD-SRT, and IMDS. We reduce risk with clear safeguards around data privacy, security, and confidentiality. We are also SOC 2 Type II compliant and do not train AI models on customer data to protect security and confidentiality.

How often is the AD-DSL updated?

The International Aerospace Environmental Group (IAEG) updates the AD-DSL periodically. Assent’s platform provides automatic alerts so you can act before changes affect your business.

How does the AD-DSL differ from REACH or RoHS?

REACH and RoHS are regulations that apply broadly across industries, while the AD-DSL is a substance list that focuses on aerospace and defense. Assent’s unified platform helps you manage all major regulations with a single AI-native solution.