• ORIGIN MARKING SCENARIO

    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 […]

  • ORIGIN MARKING OUTER CARTONS

    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 […]

  • ORIGIN MARKING SCENARIO

    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 […]

  • CHINA EXPORT MARKING

    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 […]

  • CO-MINGLED PRODUCT ORIGIN MARKING

    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 […]

  • COO Labeling Parts used in Production

    QUESTION: What are the COO rules as they apply to parts my company produces that are used ONLY in production of finished goods?  That is, they are not sold or re-sold to customers directly. I discovered that parts we’re producing in Europe did not have COO in system (I’ll address that myself), but COO is […]

  • COO Labeling Parts used in Production

    QUESTION: What are the COO rules as they apply to parts my company produces that are used ONLY in production of finished goods?  That is, they are not sold or re-sold to customers directly. I discovered that parts we’re producing in Europe did not have COO in system (I’ll address that myself), but COO is […]

  • CoO marking obligations when not the IOR

    QUESTION: I was conducting a CoO marking audit of product we buy domestically. It turns out the product is manufactured overseas and imported by the parent company of the overseas manufacturer.  We are a US distributor and will sell the product to other end users domestically and outside the US. The product is not marked […]

  • COO MARKING FOR REPAIRED GOODS,,

    QUESTION: An item is made in Non-NAFTA country A, exported from the US for repair in Non-NAFTA country B, and returned to the US after repair. The repair just makes the item functional again. Is the Country of Origin in Box 10 A or B and why?  I think it should be B, but if […]