Yes, you are right. When I read those rules, I was thinking 1 or 2 or 3, but rereading the rules, I see that it is 1 and 2 and 3. I guess that explains why Purism decided to use the “Made in USA electronics” label instead of just “Made in USA”.
I doubt that there is any electronic device of significant complexity on the market today that can be labeled as “Made in USA” under those rules. Given the rules, Purism should use the label “Made in USA circuit boards” in my opinion. Of course, the critics would point out that the M.2 Wi-Fi and modem cards also contain circuit boards.
It is still a significant achievement for Purism to do board assembly and final assembly of a smartphone in house in a developed country. It is reported that 8% of Samsung’s smartphones are made in S. Korea (the high-end S/X/Note models), but those are mainly for the Korean domestic market, and Samsung also has a factory in Taiwan. Samsung has been cost cutting its operations to compete with the Chinese brands in recent years, so I’m not sure what is the situation today, but almost all Galaxy’s sold in the West were assembled in Vietnam.
Sony is reported to make some Xperias in Japan, but those were mainly for the Japanese domestic market. Most Xperias for Western markets are made in Thailand, although some people reported buying the Xperia 1 ii in the West which had “made in Japan” labels on them. Bittium says that it makes its phones in Finland, but it is unclear if that includes board assembly as well. I read that Asus makes some phones in Taiwan. This article says that some ASUS and HTC phone models are made in Taiwan, but I don’t know if I believe it, since both ASUS and HTC have manufacturing in China.