Country of Origin

Questions and answers about Country of Origin

  • Un-assembled bicycles – COO

    QUESTION: Complete, un-assembled bicycles (HTS 8712.00.1510) are being shipped from Vietnam to the US. Wheel & tire assembly are China origin Crank set and pedals are Taiwan origin Rest of components are Vietnam origin Chinese and Taiwanese components are imported into Vietnam and, without further processing, are packaged with the unassembled Vietnamese components for export. […]

  • Country of Origin Determination

    QUESTION: We purchase mini whiskey barrels made from American White Oak (country of origin is USA) from a US based company. The company ships the lumber to Mexico for manufacture into barrels. The wood experiences a tariff shift from lumber to casks in Mexico. Then the barrels come back to the US based company and […]

  • COUNTRY OF ORIGIN LOGIC

    QUESTION: In addition to a response I’ve received on this site (which I greatly appreciate!), I’ve seen a few articles published on the internet which allude to the country of origin determination logic found in 19 CFR 102.11 being applicable to all situations. In particular, for an item unassembled as imported with components of various […]

  • ORIGIN “NEW NAME NEW CHARACTER TEST”

    QUESTION: Importing into the US an unassembled machine classifiable in Chapter 84. All components are individually packaged and shipped on the same master b/l. Certain components are from CN, others are from TW and VN. No FTA is in play, so origin is determined by the “new name, character, use test.” Being un-assembled at the […]

  • Country of Origin / 19 CFR 102

    QUESTION: CROSS ruling NY N202375 utilizes 19 CFR 102 in a way which appears to contradict its scope. In the ruling, origin is being determined by part 102 for product which is non-FTA qualifying and non-textile/apparel. My understanding is that origin for such product is to be exclusively determined by the “new name/character/use” test. Is […]

  • Country of origin between FDA and CBP

    QUESTION: Just trying to figure out what FDA and CBP considers Country of Origin. Can they be different? What is main difference? Does FDA consider country of origin to be last country to manufacture? Does CBP consider country of origin to be last country where substantial transformation occurred? Is there anything in the 21CFR where […]

  • COO and Substantial Transformation Question

    QUESTION: Can anyone provide a substantial transformation test or formula that can help me determine the COO for a product? My understanding is that for preferential treatment, each FTA has its own rules of origin. And for non-preferential treatment, the rule is the “substantial transformation.” Am I correct? Here is the scenario: 1. We currently […]

  • COO from Taiwan

    QUESTION: My company has run into a situation with Chinese Customs in regard to items being labeled with the COO as Taiwan. Customs is now putting more focus on this and are enforcing the regulation of items from Taiwan to be labeled as “TAIWAN PROVINCE OF CHINA”, “TAIWAN, CHINA”, “CHINESE TAIWAN”, etc. What implication would […]

  • NON-PREFERENTIAL RULES OF ORIGIN

    QUESTION: Is there any resource or database that lists the non-preferential rules of origin for all countries? ========== Answers: “Substantial transformation” ========== There is no international standard set of non-preferential rules of origin. See the WTO web-page for more information: https://www.wto.org/english/tratop_e/roi_e/roi_e.htm. Paul Vandevert, Principal paul@ochimtradelaw.com +1 313.737.3675 www.ochimtradelaw.com ========== You can start here…https://www.wto.org/english/docs_e/legal_e/22-roo_e.htm ========== In […]

  • ORIGIN CERTIFICATION FOR CHINA

    QUESTION: How are you dealing with issuing a Certificate of Origin document for non US goods when shipping to China? Is anyone using their invoice ONLY in order to fulfill the need for the Chinese regulation? *************** Answers: Invoice is not enough per my experiences. Certificate of origin issued by Chamber of commerce and industry […]

  • Country of Origin of a KIT

    QUESTION: Can some experts help advise the correct country of origin of a KIT contains 2 computer boards form factors (COO = China/Hong Kong) and one computer cable (COO=CN). This KIT (3 items) was assembled (put up together) in Israel. I do not believe there is a change of name or substantial transformation from the […]

  • Global COO Determination

    QUESTION: We’re looking to determine COO requirements on a global level. For example, The US uses 19CFR102 Rules of Origin and “Substantial Transformation” to determine COO. Where China or Turkey could have a different process to determine COO. In addition, COO labeling requirements, as they kind of go hand in hand. Can someone recommend a […]