Question: We import an electronic assembly from China to the US. In the US it is placed into a housing and packaged. I don’t believe that the US labor would justify a change of origin to US.What labeling responsibility do we have if the finished item is sold within the US in B2B sales? Do […]
Question: We import a product from Vietnam where their rules of origin consider this product to be COO Vietnam and must be labeled as such for export. However according to US rules of origin, the COO is of a different country and should be marked appropriately for US import. How do I proceed to import […]
Question: Are the WCO, FTA and CBP rules of origin adequate when determining if FTA ‘Made in US’ marking is in compliance? Answer 1: The Federal Trade Commission (FTC) — not CBP, WCO, or FTA guidelines — is the governing authority when it comes to claims such as “Made in USA.” The FTC enforces very […]
Question: I’m looking for guidance as to how other members deal with marking issues when a foreign countries marking rules don’t align with U.S. marking rules. Different Customs agencies have differing positions from the U.S. regulations on an article’s country of origin. As an example, China requires that China be marked on packaging even if […]
Question: Can the membership please advise if product that is made in Taiwan that is going to a 3PL in China for consolidation and ultimate shipment elsewhere needs to be marked with “Made in Taiwan China” instead of “Made in Taiwan”? We regularly ship product from our Taiwan contract manufacture in the US and the […]
Question: If the Pack Slip COO is unable to be changed from US, and the OEM labels COO say MX, does that mean the OEM labels are incorrect and should say US? Since it was determined that the part per the BOM is manufactured in the US and assembled in MX. Would the bag labels […]
Question: Scenario: Cotton yarn is woven into fabric in Vietnam then exported to China. In China, the fabric is dyed/bleached, cut to shape, hemmed, finished and packaged for retail sale for medical and/or surgical purposes. The end product is gauze sponges classified under HTS 3005.90.5090. Based on CBP’s textile rules of origin, the country in […]
Question: We’re looking into the Made in America labeling requirements and have a clear understanding that the products that to be labeled Made in America should meet certain requirements. With that in mind, do all the finished products a manufacturer makes need to be labeled Made in America if they meet the requirements or would […]
Question: Greetings, membership! I have a textile product where the fabric is made in Country A and the sewing is done in Country B. U.S. marking requirements (19 CFR 102.21) for this particular product state that the country of origin is dictated by the origin of the fabric (Country A), not where the sewing occurred […]
Question: Dear ICPA Community, We need help with a challenge regarding imported raw materials. We import materials from two foreign countries. They are classified identically however the materials are blended (no manufacturing involved) together 50/5o and repackaged. Does anyone in the community know what country of origin this should be named and labeled for type […]
Question: Looking for some examples of companies receiving fines/penalties from CBP for mis-declaring the C/O on imported products. Looked at CBP website and ICPA Library – unable to find any. Can the membership share some examples? Answer 1: If done intentionally for the purpose of fraudulently circumventing tariffs or duties, misdeclaration of the C/O can […]
Question: We are looking to manufacture a product in the US with a combination of foreign & US sourced raw materials. I believe Made in USA labeling will be applicable through a qualified claim. If it does qualify, will utilizing text such as “Made in USA using foreign & domestically sourced raw materials”, also serve […]
