Question: We have chemical products mostly sold in bags that are manufactured in the US that use both foreign and US component materials/ingredients. For import/export country of origin purposes, we apply tariff shifts and the substantial transformation principle to determine the country of origin for exports from the US. However, if we sell the products […]
Question: Imported bulk grain and seed products arrive in 1000 kg totes. Plastic sleeve sewn on to each tote includes a piece of paper with the country of origin. Is this plastic sleeve considered indelible and permanent? One could rip the sleeve off or put their hand in the sleeve and […]
Question: Our company is kicking off an origin marking campaign to bring our products and packaging into compliance. From an export perspective, we have used substantial transformation as the basis for our origin claim. Our products are sold domestically as well. It appears to me that the definitions of “Made in the U.S.A” […]
Question: 6 years ago our company secured a binding ruling with U.S. customs on our marking procedures that allowed us to only mark the inner box of our product. The products are discrete integrated circuits and can not be marked individually for obvious reasons. The U.S. ruling allows our company to name […]
QUESTION: We have a situation where the manufacturer has applied the COO on the inside of a plastic, see through umbrella with a heat seal process. The problem is that they used the wrong information. They are suggesting that they could cut out the incorrect tag and add a sticker to the […]
Question: Can anyone tell me where to find rules of origin for individual countries? I can find the Free Trade Agreement rules but general rules are frequently different. Would also find marking requirements useful if there is a source available.
QUESTION ON INCORRECT COO MARKINGS, FINES, PENALTIES AND 171 APPENDEX B(C) Question: We have a situation where the market (branded and generic) is in short supply of a critical pharmaceutical product. Typically, we supplied the US market with a version of this product made in country X and rest of world markets supplied from […]
QUESTION ON DUTCH 55 GALLON DRUMS NOT LABELED WITH COO Question: We are planning to import 55 gallon drums of vegetable oil from the Netherlands. The drums, stored in a 3rd party Dutch warehouse, are not marked with Country of Origin (Netherlands). The vendor says it’s “not required” for EU trade. The Dutch vendor […]
QUESTION: If a product is produced in the US for UK distribution, wouldn’t the packaging have to state “Made In USA” if there is a UK address? I was told this is not a requirement so long as the UK address did not include a provenance claim. Is that correct? How can I […]
QUESTION: OK – this is a first for me. And I’m hoping it’s really as ridiculous as it seems. One of our customers in Korea is saying that they want our marking to be “Made in U.S.A.” instead of “Made in USA” Has anyone ever, for any country, had an issue […]
Question: We are an OEM currently looking the various country of origin marking regulations to support selling Kits to our customers. The kits would be packed with foreign and domestic items at our manufacturing sites. The regulations that I have seen stipulate that all foreign items in the kit must be marked with the country […]
Question: Empty metal tins from Country A are going to be shipped to Country B to be filled with shoe care/shoe wax-like product. For COO purposes, is it just fine to have printed on the tins or a sticker indicating, “Made in Country B,” without any mention of Country A? The essential character is the […]
