Country of Origin – Marking

Questions and answers about Country of Origin – Marking

  • Country of Origin on Labels

    QUESTION: I am curious about how to determine country of origin for a label. Would it be based on the country of origin of the blank label material or is the label substantially transformed when it is printed on? ========== Answers: I would not count the printing on a label to be a substantial transformation. […]

  • Taiwan Country of Origin marking

    QUESTION: In the past week my company has seen 4 shipments stopped upon import into China because the commercial invoice is showing a country of origin TW. China customs is refusing to enter the shipment until the invoice is updated to show a country of origin Taiwan, China. Have other members been experiencing the same […]


    QUESTION: I have a question about origin marking requirements. Where does it state that a marking waiver must be requested and approved to be excepted from marking each item in a carton with the country of origin? 19 CFR 134.32 (d) states that “articles for which the marking of the container will reasonably indicate the […]

  • Origin Marking

    QUESTION: Is there issue if an item is marked “Made with US materials and assembled in Mexico” ? A literal reading of the Customs origin rule would seem to dictate that “Assembled in Mexico….” Should come first. ========== Answers: “Assembled in Mexico of…” is the way to go. =========== What CO are you actually trying […]


    QUESTION: US made products are sent to Mexico for finishing. The further work in Mexico does not cause tariff shift under the 19 CFR 102.20 rules of origin. Per the NAFTA Preference Override rule in 19CFR 102.19(b) Mexico is the country of origin for DUTY purposes and Field 10 of the NAFTA certificate of origin […]


    QUESTION: I have recently started at this manufacturing company. My predecessor had PRODUCT OF THE USA added to our boxes. So far, China and Saudi Arabia have both had problems with these boxes and require us to cover that with MADE IN USA. We are going to order new boxes that say MADE IN USA. […]

  • COO Marking Scenario

    QUESTION: One of our U.S. plants imports an item from China. This item is further processed and manufactured in the U.S., along with other U.S. sourced components, into a finished assembly and then sold to our U.S. OEM customer, who will incorporate into their automotive vehicle application. The imported component is substantially transformed into a […]


    QUESTION: We are importing chairs from China that are 98% complete. The only process we perform is upholstering the seat. We remove the seat upholster it and put it back in the same box and ship it to the customer. The country of origin on the box and chair should indicate China correct? ========== Answers: […]

  • Marking of labels for cartons

    QUESTION: Our company is in the process of rolling out labeling & packaging instructions to our vendors . Currently, the instructions are to include COO as one of the items along with PO, part number, etc… Question is, does the label need to state “made in XXXX ” , “product of XXXX ”, “assembled in […]


    Is this valid? Does it apply to all of China, all of Shanghai, or just some specific factories? ========== I’ve never heard of such a marking in my 30 years in the business – but times change and what the heck you still have the COO on the boxes. When importing in bulk, you are […]


    QUESTION: We import aluminum rails and balusters from Canada that will be used in the assembly of deck railing panels. The Canadian rails and balusters are commingled in the US with identical, US-made products. When we kit together the components in a box to sell to a US retail customer, we’re not sure what the […]

  • COO products labeling

    QUESTION: Do the countries name required to be spelled out and not appreciated on the label?  I have seen in most cases the label for USA origin show at ” COO: U.S.A” instead of spelled out the full name.  However the other countries spelled out. ================== ANSWERS: Per 19CFR Part 134.45, the full English name […]