Come on Charles, impenetrable legal jargon is what this forum is all about! And the answer is I was kind of disagreeing with your interpretation. Sort of..sometimes...............it depends.
I agree that imported raw shrimp that are then cooked in the USA have been substantially transformed and that if a customer requested country of origin the origin would be USA for the purposes of declaring the origin of the cooked product.
I disagree with you that on the package of shrimp you could make a "made in USA" claim, on the basis that FTC would say your product did not meet the "all or almost all" standard expected by consumers, unless the shrimp, packaging, and manufacturing occurred almost entirely within the borders/territories of the US.
Most important bits from the FTC guidance:
What is the standard for a product to be called Made in USA without qualification?
For a product to be called Made in USA, or claimed to be of domestic origin without qualifications or limits on the claim (FF&F: like "cooked" or "packaged in USA"), the product must be "all or virtually all" made in the U.S. The term "United States," as referred to in the Enforcement Policy Statement, includes the 50 states, the District of Columbia, and the U.S. territories and possessions.
What does "all or virtually all" mean?
"All or virtually all" means that all significant parts and processing that go into the product must be of U.S. origin. That is, the product should contain no — or negligible — foreign content.
Cooked shrimp are have COOL for USA based on 7 CFR 65, but "made in USA" might be a misleading statement given that the shrimp were not sourced domestically.