Question: In the context of preferential origin determination (EU rules), does the margin has to be considered in the “added value” (for added value rule satisfaction), even when the margin represents 90% of saling price (like for a luxury bag) ? Answer 1: There is no single answer to the question. Origin rules in the […]
Question: Has anyone heard about a Certificate of Non-Chinese Origin? What experience have you had with the form? What do we need to know if we want to use it? What are the requirements to use the form? Any further suggestions would be most appreciated.Thank You Answer 1: This is an often seen contractual clause. […]
Question: I’m trying to determine if exhausted/spent vanilla bean seeds continue to have Madagascar origin after the extraction process or become U.S. origin. The vanilla beans used in the extraction process to produce Vanilla Extract are of Madagascar origin. The Vanilla Extract is produced in the U.S. The Country of Origin for the spent vanilla […]
Question: I work for an importer of apparel and we are working on processes for regular Country of Origin audits on our products, including reaching out to vendors for documentation to justify Country of Origin determination. What document or sets of documents do you request from vendors for Country of Origin justification? On the off […]
Question: I am still seeing and hearing conflicting answers on the practical application of this, so I would appreciate if the membership weighed in on this example: Under substantial transformation, a product is properly determined to be of Chinese origin. However, the 19 CFR 102 rules say it’s Mexico, and it qualifies for USMCA. Which […]
Question: Regarding Country-of-Origin RegulationI understand that if a product has undergone any type of transformation, the following three rules will apply: > Change in tariff classification > Ad Valorem percentage ( value-added) > Specific manufacturing or processing operation If we have a product manufactured i i.e. Malaysia creating a new H.T.S. i.e. 3701.10.00 medical laser however, after production, the […]
Question: Our broker has been requesting the US state of manufacture for products we import that have a US country of origin. Is this really required for clearance into Canada? I cannot find any written regulations that say this is required. Answer 1: Look at D17-1-10. They need state for the Place of Export (if […]
Question: I have a product manufactured in Thailand, then sent to India for final coating process. There is some question about Country of Origin. The base film (PET) is extruded and made in Thailand; one side is coated in Thailand for printing. They send to their India facility for 2nd side top coating for print […]
Question: We have a client that sends goods of American origin to Canada for repair. Goods are returned to the United States after repair. Question: What would the country of origin be on the CF7501? We have conflicting information that indicates if the repair did NOT result in substantial transformation of the item, then the […]
Question: How do members manage fasteners and country of origin? For example, a European location sources fasteners (bolts, washers, etc.) from a couple of suppliers within the EU. Each supplier can advise they source their fasteners from countries A, B, and C, but they may not be able to advise the origin on a per-shipment […]
Question: Hello ICPA Community, We have recently come across a scenario where we are being asked for the manufacture information for products that do not contain US country of origin, because we are exporting out of the US. We have products that are OEM’d from other suppliers that we both do not want to provide […]
Question: We are a semiconductor company, and we know that U.S. rule considers substantial transformation to happen at the assembly site not the fabrication site of the die. We have product shipping from Taiwan into the U.S. where it meets the substantial transformation principle used to determine COO Taiwan. Recently Taiwan announced that their regulatory […]
