Analysis of Proposed Consent Order to Aid Public Comment 

In the Matter of Williams-Sonoma, Inc., also d/b/a Williams Sonoma, Williams Sonoma 

Home, Pottery Barn, Pottery Barn Kids, Pottery Barn Teen, West Elm, Rejuvenation, 

Outward, and Mark & Graham, File No. 2023025 

The Federal Trade Commission (“FTC” or “Commission”) has accepted, subject to final 

approval, an agreement containing a consent order from Williams-Sonoma, Inc., also d/b/a 

Williams Sonoma, Williams Sonoma Home, Pottery Barn, Pottery Barn Kids, Pottery Barn Teen, 

West Elm, Rejuvenation, Outward, and Mark & Graham (“Respondent”). 

The proposed consent order has been placed on the public record for thirty (30) days for 

receipt of comments by interested persons. Comments received during this period will become 

part of the public record. After thirty (30) days, the Commission will again review the 

agreement and the comments received, and will decide whether it should withdraw from the 

agreement or make final the agreement’s proposed order. 

This matter involves Respondent’s marketing, sale, and distribution of home products as 

made in the United States. According to the FTC’s complaint, Respondent represented that its 

Goldtouch Bakeware products, Rejuvenation-branded products, and Pottery Barn Teen and 

Pottery Barn Kids-branded upholstered furniture products, including the materials and 

subcomponents used to make such products, are all or virtually all made in the United States. In 

fact, in numerous instances, Respondent’s Goldtouch Bakeware products, Rejuvenation-branded 

products, and Pottery Barn Teen and Pottery Barn Kids-branded upholstered furniture products 

are wholly imported or incorporate significant imported materials or subcomponents. Based on 

the foregoing, the complaint alleges that Respondent engaged in deceptive acts or practices in 

violation of Section 5(a) of the FTC Act. 

The proposed consent order contains provisions designed to prevent Respondent from 

engaging in similar acts and practices in the future. Consistent with the FTC’s Enforcement 

Policy Statement on U.S. Origin Claims, Part I prohibits Respondent from making U.S.-origin 

claims for its products unless either: (1) the final assembly or processing of the product occurs 

in the United States, all significant processing that goes into the product occurs in the United 

States, and all or virtually all ingredients or components of the product are made and sourced in 

the United States; (2) a clear and conspicuous qualification appears immediately adjacent to the 

representation that accurately conveys the extent to which the product contains foreign parts, 

ingredients or components, and/or processing; or (3) for a claim that a product is assembled in 

the United States, the product is last substantially transformed in the United States, the product’s 

principal assembly takes place in the United States, and United States assembly operations are 

substantial. 

Part II prohibits Respondent from making any country-of-origin claim about a product or 

service unless the claim is true, not misleading, and Respondent has a reasonable basis 

substantiating the representation. 

Parts III through V are monetary provisions. Part III imposes a judgment of $1,000,000. 

Part IV includes additional monetary provisions relating to collections. Part V requires 

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Respondent to provide sufficient customer information to enable the Commission to administer 

consumer redress, if appropriate. 

Parts VI through IX are reporting and compliance provisions. Part VI requires 

Respondent to acknowledge receipt of the order, to provide a copy of the order to certain current 

and future principals, officers, directors, and employees, and to obtain an acknowledgement from 

each such person that they have received a copy of the order. Part VII requires Respondent to 

file a compliance report within one year after the order becomes final and to notify the 

Commission within 14 days of certain changes that would affect compliance with the order. Part 

VIII requires Respondent to maintain certain records, including records necessary to demonstrate 

compliance with the order. Part IX requires Respondent to submit additional compliance reports 

when requested by the Commission and to permit the Commission or its representatives to 

interview Respondent’s personnel. 

Finally, Part X is a “sunset” provision, terminating the order after twenty (20) years, with 

certain exceptions. 

The purpose of this analysis is to aid public comment on the proposed order. It is not 

intended to constitute an official interpretation of the proposed order or to modify its terms in 

any way. 

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