Country of Origin – Marking

Questions and answers about Country of Origin – Marking

  • Made in America

    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 […]

  • COO Marking conflict between foreign and U.S. Customs

    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 […]

  • Country of Origin Marking for Identical Comingled Products

    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 […]

  • C/O misdeclaration

    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 […]

  • Made in USA/COO labeling

    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 […]


    Question: Hello, We will initiate import from our factory in Mexico producing a couple products only and we are debating what would be the recommended option, all the raw material will be imported from US to MX. The first question and keeping in mind the legal manufacturer still the USA what’s the more favorable option: […]

  • Country of origin marking of warantee replacement parts

    Question: We import products that are marked with country of origin on the consumer packaging as well as on the product itself.  We also import parts of the products used for warranty replacement that come from the same manufacturer.  These warranty replacement parts are not sold at retail, but only provided to customers who had […]

  • Acceptable TW origin marking for Imports into the US

    Question: Are the below Country of Origin marking statement acceptable as origin marking for Imports into the US? “Taiwan Province of China” “Taiwan, China” “Chinese Taiwan” “Taipei, China” “Chinese Taipei” Answer 1: Why don’t you just say Made in Taiwan and throw out all the rest? Taiwan is recognized on its own, does not have […]

  • Metal Spoon Individual and Package Marking

    Question: We’ve got a shipment in with individually sold spoons, and we’re wondering if we need to label each spoon separately.  If so, do you know how we can go about doing this after the import?  Is there any requirement for customs approval post-importation for this kind of labeling? Also, could you shed some light […]

  • Origin Marking for Labels

    Question: We are working labels with origin markings to ensure there are no risks are present which may confuse the consumer.  Would the following label be sufficient for product that we have toll manufactured in Canada? Is there risk based upon how we phrase the produced by followed by our US company name and address? 1st Line: […]

  • Phrasing for Country of Origin Marks

    Question: Can anyone provide a regulatory citation that speaks to the requirement or lack thereof for including the words, “Country of Origin” preceding the name of the origin country in the mark? I find references to the preceding phrases “Assembled In” and “Made In”, but nothing for “Country of Origin” as a preceding phrase. Answer […]

  • J List Items- Re-packaged

    Question: Our company imports J List items in bulk and the outer container is marked with the country of origin according to CBP regulations. We then sell those J List items individually in the US market. They each have an individual label with the US company name and address, and they all sit in a […]