The FCC seems to count some level of assembly and packaging as qualifying as “Made in the US” so as long as it’s not a complete sham it should count.

Of course, getting a router SOC with firmware from the factory , soldering on the Ethernet ports and adding RAM and storage, installing an OS, throwing it in a case with a power supply into a box isn’t solving the problem of insecure foreign firmware but is meeting the “Made in US” demand.

So what counts and who gets exemptions will be telling.