• MARKING WAIVER

    QUESTION: In the answer database I see some responses to this requirement from back in 2011. It is now 2017 I am questioning the necessity of our Marking Waiver as we review and update it every year.   I am wondering if back in the day maybe many years ago we used to have problems […]

  • PRODUCT OF VS. MADE IN USA FTC

    QUESTION: Below is my understanding of CoO labeling in regards to the FTC standard. Does anyone in the membership have a different understanding? “Product of USA” and “Made in USA” must meet the “virtually all” standard, and there is no difference between the two. “Assembled in USA” is compliant provided that a substantial transformation occurs […]

  • ORIGIN LABELING SCENARIO

    QUESTION: Shipping goods to various countries. Two major components in 1 crate  – 1 is “Made in the USA” (verified), the other is “assembled in Mexico.” The second good (MX Origin) becomes the 1st part (US Origin) – (customs rulings support this). We invoice both parts as 1 line item – the good that is […]

  • GARMENT HANGERS ORIGIN MARKING

    QUESTION: This is a question for Apparel importers who import Garments on Hangers. There are three scenarios for importing these hangers; disposable/flimsy hangers classified and entered with the garment; hangers suitable for reuse and separately classified in chapter 39 (3923.90.0080) and hangers suitable for reuse that are classified as Instruments of International Traffic, chapter 98 […]

  • MADE IN USA AND ORIGIN MARKING

    QUESTION: I have a US product that is sent to China for further processing. The country or origin remains the US as the processing wasn’t enough to have a substantial transformation. The product is then sent to MX for packaging and shipped back to the US. This product now consists of the first product shipped […]

  • ORIGIN MARKINGS

    QUESTION: If I have one component from Germany and one from China sent to Mexico for assembly (the country of origin for this is Germany) does each component have to be called out on the packaging or can it just state Made in Germany. 2.     With the same scenario as above two parts one from […]

  • MARKING CONFLICT

    QUESTION: We have a request from our marketing department to use “Casted In China” on casted parts for Country of Origin markings.   They feel the markings “Made In China” that are visible after the assembly causes too much confusion to our customers based on us marketing  the product as “Assembled In USA”. We have placed […]

  • MADE IN EU ORIGIN MARKING

    QUESTION: We are having a debate with our European counterparts.  They purchase a part from a French company that shows “Made in EU”.  (I know it cannot say that when coming to the US). The bigger issue is this item is manufactured in Tunisia.  The French company, due to the company in Tunisia being an […]

  • MADE IN USA FTC QUALIFIERS

    Question: Our products are currently marked “Made in USA with Globally sourced components”. Since this a very long and is required to be put on our parts by laser, we are looking to shorten the qualifier. I’m looking for example of qualifiers that would adhere to the FTC regulations, but perhaps be less characters. I […]

  • ORIGIN DETERMINATION AND MARKING

    Question: We have a leather planner being manufactured in Vietnam without the paper. We then ship to China where the paper portion is inserted. Once complete, the shipment is shipped to the US. Do we need to use both countries as the COO and how should we mark them? ************** Answers:   I would need […]

  • ORIGIN OF KIT SCENARIO

    Question:   We sell a kit that is comprised of two small liquid vials packaged together. One of the vials, comprising about 11% of the cost of the product (Exceeding de minimis), is sourced from Germany. The second vial is manufactured by us domestically. I believe this is material to this situation – neither component […]

  • UNMARKED SPARE PARTS

    Question: We have many boxes of manufacturing machinery parts that are not marked with country of origin. We want to ship some boxes from Canada into USA and others from USA into Canada. What can we do to meet Customs marking requirements? Is a certificate or declaration from the Mfg. / OEM suitable? What is […]