Question: Hello ICPA Community, We have recently come across a scenario where we are being asked for the manufacture information for products that do not contain US country of origin, because we are exporting out of the US. We have products that are OEM’d from other suppliers that we both do not want to provide […]
Question: We are a semiconductor company, and we know that U.S. rule considers substantial transformation to happen at the assembly site not the fabrication site of the die. We have product shipping from Taiwan into the U.S. where it meets the substantial transformation principle used to determine COO Taiwan. Recently Taiwan announced that their regulatory […]
Question: What would the country of origin be for a pump has 100% Chinese components but is assembled and tested in Singapore and then shipped to the US? Are Singapore’s rules of origin different than the WTOs Answer 1: In this scenario, the country of origin of the pump for U.S. customs purposes would likely be […]
Question: I have been told that Singapore has rules of origin that differ from the WTO rules of origin and that simple assembly constitutes that a finished product is COO Singapore regardless of the origin of the inputs. Does anyone know if that is true? There has been talk in the office of sending our […]
Question: We make 2 products that are made from raw materials sourced from Canada in the US. Until recently we have considered our products COO as US but after a recent training session we are questioning that. The products are Laminated Veneer Lumber and I-Joist. All the Veneer, Lumber and OSB are obtained from Canadian […]
Question: Is anyone having difficulty getting certs or breakouts from foreign suppliers? If so, how are you handling this? Answer 1: I received this from my Customs Broker: Here is some information by CBP regarding the country of smelt or cast/melt and pour. https://www.cbp.gov/trade/programs-administration/entry-summary/232-tariffs-aluminum-and-steel/faqs
Question: US Customs considers the country of origin (COO) to be the last location of substantial transformation- most of the time for pharmaceutical products COO is API manufacturing location. Does Canada Customs align with US Customs on COO for pharmaceuticals to be an API manufacturing location? Does Canada Customs have something similar to CROSS […]
Question: Hello ICPA Membership, With recent tariffs on specific countries, have you seen guidance on if CBP will continue to view COO as the country where API was produced for generic pharma products? For example, the API supplier could be in Israel, but vials are filled and finished in China. Currently CBP says Israel is […]
Question: We have a good that we want to have partially made in China and then move the semi-finished material to the EU for further and substantial processing. It is unusable before it is further processed but carries the same name and tariff code as the finished product. The semi-finished material can be used for […]
Question: Has anyone developed an ACE report or query to identify entries with products that have countries of origin that differ from their country of export, e.g., a company imports a Swiss origin product from Germany. If yes, then would you mind sharing it? Answer 1: I’m not sure what you mean by “sharing it”. […]
Question: CBP allows for averaging in most FTA agreements. Is this methodology possible for determining COO on regular imports? We send 50% CN origin and 50% TW origin product to a company. Several months later they send the same product back to us. Is it possible that for the ensuing quarter we can claim for […]
Question: COO scenario: Chinese vendor moved manufacturing to Vietnam, but some components still imported from China to Vietnam. There is not major transformation on the components after fully assembled. We want to ensure claiming Vietnam origin is in compliance. Wondering if any colleague would know what’s the proper methodology to determine COO for this non-preferential […]
