Law360 Publishes Article by Amy Hoang on Domestic-Origin Claim Risks for Government Contractors

Law360 featured an article by Government Contracts practice co-chair Amy Hoang: “FTC Push May Create Dual Origin-Claim Risks for Contractors.” The piece, published on September 25, 2026, examines how the Federal Trade Commission's heightened scrutiny of US-origin claims may affect federal contractors.

The article highlights how the FTC’s April enforcement sweep and July warning letters signal increased scrutiny of domestic-origin representations and explores the distinctions between the FTC’s “Made in USA” standard, the Buy American Act, and the Trade Agreements Act. Hoang explains why compliance under one regime does not necessarily satisfy another and outlines practical steps companies can take to substantiate origin claims and align marketing and procurement representations.

Emphasizing the importance of understanding the applicable legal framework, Hoang noted:

“Companies should know precisely which origin standard applies, ensure the facts satisfy that standard, and retain documentation capable of withstanding government scrutiny."

She further cautioned:

“Compliance under one regime does not establish compliance under another, and shorthand labels can create risk when they are repeated across marketing, proposals, certifications and contract vehicle listings.”

The full article is available here.