Country of Origin – Marking

Questions and answers about Country of Origin – Marking

  • Product Labeling

    Question: In compliance language, is there a difference between “Made in” vs “Produced in”.  If there is no difference, can it be used interchangeably? Under what circumstance will either be appropriately applicable? Answer 1: For the United States and compliance with the requirements of 19 USC 1304 (19 CFR 134), there is no difference.   See […]

  • COO Marking for a J-List product

    Question: 19 CFR 134.33 (J-List) exempts nuts and bolts from the requirement that they must have the COO on the physical product itself.  The outer packaging that will reach the ultimate consignee still needs to be marked with the COO for the nuts or bolts. What if the nut and bolt are so large that […]

  • Marking List

    QUESTION: Does anyone know of a list of marking requirements by import country? Thanks! ========== Answer: I am not sure whether there is a list by country however, there are general requirements and separate marking rules for USMCA imports. Please refer to CBP’s Informed Compliance Document on their website and Title 19 CFR 143 for […]

  • US import marking requirement for US goods

    QUESTION: How do the CBP marking rules apply to US origin goods being returned temporarily to the USA for repair?  The goods are not physically marked with CO when exported from the USA.  So upon the reimport, is there any marking requirement at all, and if so I presume it is to the box/outer carton […]


    QUESTION: US Company manufactures Product A in the US. Product made in the US does not need to bear an origin mark. Packaging label may state manufactured by, manufactured for, produced by, or produced for, and identify the US Company name and address. US Company imports Product B in bulk from 4 countries of origin. […]


    QUESTION: How are you managing complex COO carton markings? Proposed label: Tool Assembled in the U.S.A.     [70% of the total value] Batteries: cells made in Japan, China, Singapore, Korea, or Malaysia  [25% of the total value] Further processed in China, Vietnam, or Korea Charger: Made in China or Hungary  [5% of the total value] For […]

  • Declared Origin of a Set

    Answers: It’s not a set under 3b if all items have same HTS classification.  If it’s assembled together a single origin applies ========== The origin rules for sets is different than the classification rule. For sets, which you have described below, you are required to mark the packaging with the COO of all of the […]


    QUESTION: Our operation does kitting of 4 different parts of drains for domestic and international sale.  One of the items is made in China and others are in the U.S.  Most of the total value is U.S. origin.   The package of parts is not put up for retail sale.  They are all classified as the […]


    QUESTION: We are introducing a new display consisting of air fresheners, same classification, manufactured in the USA and Mexico.   The individual air freshener packaging is marked with its country of origin.  My questions are as follows, and can you also advise where to look for the regulation pertaining to this type of situation? 1.  Which […]


    QUESTION: We have a kit in one classification, which imparts the essential character of the kit.  However, the kit is comprised of four other items, none from the country of kitting other than the main item for which the kit is classified. Each item, the essential piece and its supporting items, is marked with its […]

  • Answers to Question on Country of Origin Marking – Product Solely for Export

    QUESTION: Our company currently manufactures beverage products that contain raw materials of foreign origin that are reconstituted with water and bottled in US manufacturing locations.  The products that are intended for US domestic distribution are marked in accordance with 19 CFR 134 and other relevant CBP COO marking rulings due to the manufacturing processes not […]