Guidance from the United States Department of Agriculture (USDA) has strengthened the requirements for producers making the claim “Product of USA.” The most notable of which is that producers must have evidence that they meet the new requirements and are prepared to hand it over to the USDA within 24 hours of a demand. The directives will be enforced by the USDA’s Food Safety and Inspection Service (FSIS). The new requirement is intended to send a clear message to processors that FSIS expects them to have appropriate documentation on hand immediately upon request.

While this only applies to entities that fall within USDA's jurisdiction, it is reflective of a labeling trend that goes to products of all types. To wit, if you say it on your label, you must have the required evidence to support your claim. My partners in the advertising space call this “substantiation.”

Far too often I see challenges to a labeling claim made against a producer, and the producer is having to scramble after-the-fact to provide evidence to support it. It is supposed to be the other way around. Manufacturers of all types of products should have substantiation for any claim made on their labels before a challenge is made.

I predict USDA's 24-hour evidence rule will become the norm for products made across multiple industries in the near future. If I am right, you've been forewarned.