Analysis of Proposed Consent Order to Aid Public Comment

In the Matter of iSpring Water Systems, LLC, File No. 1723033

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

approval, an agreement containing a consent order from iSpring Water Systems, LLC.

(“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 water filtration 

systems and associated parts and accessories with claims that the products are of U.S.-origin.

According to the FTC’s complaint, respondent represented that all of its products are “Built in 

USA.” In fact, in many instances, respondent’s products are wholly imported. In other

instances, respondent sources significant inputs to its products from overseas.

The complaint alleges that respondent’s claims that its products are “Built in USA” were 

false or misleading, or not substantiated at the time the representations were made. Accordingly, 

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 iSpring 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; or (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, and/or processing.

Part II prohibits respondent from making any “Made in the USA” or other country-oforigin 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 VI are reporting and compliance provisions. Part III 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 IV requires the filing of compliance 

reports within one year after the order becomes final and within 14 days of any change in 

respondent that would affect compliance with the order. Part V requires respondent to maintain 

certain records, including records necessary to demonstrate compliance with the order. Part VI
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 VII 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.