UNITED STATES OF AMERJCA 


FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 


Bureau of Consumer Protection
Division of Enforcement
Julia Solomon Ensor 

Attorney 

Email : jensor@ftc.gov
Direct Dial: (202) 326-2377

March I, 2017

VIAFEDEX
Jason K. Walbourn, Esq.
Senior Director, Assistant General Counsel - Regulatory, Operations and Investigations
Target Corporation
I 000 Nicollet Mall
TPS-3155 Floor 7
Minneapolis, MN, 55403
Dear Mr. Walbourn:
We received your submissions on behalf of Target Corporation ("Target" or the
"Company"). During our review, we discussed concerns relating to potentially deceptive "Made
in USA" claims for Target owned-brand products. In this instance, our inquiry focused on
certain Room Essentials-branded pillows that were prominently marked " Made in USA" on
exterior packaging. However, consumers reported that when they opened the packages post­
purchase, they discovered the pillows were marked "Made in China."
In response to our inquiry, Target took several steps to prevent consumer deception, both
with regard to the particular product we identified, and across owned-brand SKUs. First, Target
confirmed and corrected the country-of-origin information for the identified pillows, along with
several other affected pillows the Company self-identified. Specifically, Target removed
affected items from sales floors, hard-locked the items at the point-of-sale system so they could
no longer be sold to consumers, and began work to remediate packaging.

Second, Target implemented several longer-term process enhancements designed to
prevent inaccurate country-of-origin claims by Company vendors. Specifically, upon
notification of the above-described issue, Target immediately: (1) assembled a cross-functional
group of internal experts from the Company's packaging team, product safety and quality
assurance team, merchant team, and law department to identify where it could make process
improvements; (2) began implementing a new flag in the Company' s packaging system to
identify when an unqualified "Made in USA" claim is proposed so Targ~t can alert the vendor to
ensure the claim meets with FTC guidance; (3) started developing new criteria for third-party
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 testing and assessment labs to follow when an unqualified "Made in USA" claim appears on
product packaging so that third-party testing and assessment labs can validate that any tag
affixed to the item is consistent with claims made on the packaging; and (4) commenced a larger
review of domestic vendors for owned-brand products to conduct additional spot checks of
unqualified "Made in the USA" claims made within Target's product assortment.
Based on Target's actions and other factors, the staff has decided not to pursue this
investigation any further. This action should not be construed as a determination that there was
no violation of Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45. The
Commission reserves the right to take such further action as the public interest may require. If
you have any questions, you can reach me at (202) 326-2377.
Sincerely,

Julia Solomon Ensor
Staff Attorney

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