Country of Origin – Marking

Questions and answers about Country of Origin – Marking

  • Origin Marking

    QUESTION: Origin marking question. Scenario is below: A finished assembled product is imported into US from foreign entity and will be labeled Made in XXXXX. Import will be a regular consumption entry. The importer in US, will remove several key components and rebuild with new different internal unique USA components. The new internal US components […]

  • MADE IN USA MARKING

    QUESTION: Looking to find out from the membership how most companies are handling the labeling of products that are US origin using substantial transformation, but have foreign components or materials and therefore cannot be marked “Made in USA” under the FTC rules. I know that most companies will mark using a qualified statement for domestic […]

  • Labeling of products

    QUESTION: Looking to find out from the membership how most companies are handling the labeling of products that are US origin using substantial transformation, but have foreign components or materials and therefore cannot be marked “Made in USA” under the FTC rules. I know that most companies will mark using a qualified statement for domestic […]

  • Determination and maintenance of Country of Origin Marking for overseas manufacturing facilities?

    QUESTION: What should be the role of a US based Trade Compliance Department in the determination and maintenance of Country of Origin Marking for overseas manufacturing facilities (related party facilities)? Who should be responsible for Determining Origin? And who should be responsible for maintaining origin? Is there anything on the regulations that could point to […]

  • Country of origin marking for prescription drugs

    QUESTION: Are prescription drugs exempt from marking statutes? I noticed that some imported prescription drugs are labeled at the consumer level with the country of origin, while some are not.  Some labels instead mention the manufacturer name which doesn’t help as some have facilities producing the same drug in different countries. ================================================================ Answers: Items made […]

  • Country of Origin / 19 CFR 102

    QUESTION: CROSS ruling NY N202375 utilizes 19 CFR 102 in a way which appears to contradict its scope. In the ruling, origin is being determined by part 102 for product which is non-FTA qualifying and non-textile/apparel. My understanding is that origin for such product is to be exclusively determined by the “new name/character/use” test. Is […]

  • MARKING SHIPMENT WITH MULTIPLE ORIGINS

    QUESTION: We are importing 5 different items from the EU into the USA. The 5 items will be going into further fabrication or production, so we will not be the ultimate purchaser. The 5 different items, all have their own packaging, which will indicate “Made in …”, however, these individual boxes will be packaged and […]

  • Labeling – Medical Device

    QUESTION: We have a third party relationship with a company in Mexico, who handles our US parts assembly, package and then re-shipped to US for our North America market.  The label and IFU show the phrase, “Assembled in Mexico with US parts.”  The question is – ·         Is the phrase “Assembled in Mexico with US […]

  • ORIGIN MARKING SCENARIO

    QUESTION: If a generic imported consumer good (no special requirements such as textile, FDA, etc.) is permanently labeled with the actual name and address of the manufacturer, is that sufficient for origin markings It does not state “Made by” or similar. Would “Made By”, “Made in” or similar verbiage have to be added in order […]

  • 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 […]