Question: Hello ICPA Membership, With recent tariffs on specific countries, have you seen guidance on if CBP will continue to view COO as the country where API was produced for generic pharma products? For example, the API supplier could be in Israel, but vials are filled and finished in China. Currently CBP says Israel is […]
Question: We have a good that we want to have partially made in China and then move the semi-finished material to the EU for further and substantial processing. It is unusable before it is further processed but carries the same name and tariff code as the finished product. The semi-finished material can be used for […]
Question: Has anyone developed an ACE report or query to identify entries with products that have countries of origin that differ from their country of export, e.g., a company imports a Swiss origin product from Germany. If yes, then would you mind sharing it? Answer 1: I’m not sure what you mean by “sharing it”. […]
Question: CBP allows for averaging in most FTA agreements. Is this methodology possible for determining COO on regular imports? We send 50% CN origin and 50% TW origin product to a company. Several months later they send the same product back to us. Is it possible that for the ensuing quarter we can claim for […]
Question: COO scenario: Chinese vendor moved manufacturing to Vietnam, but some components still imported from China to Vietnam. There is not major transformation on the components after fully assembled. We want to ensure claiming Vietnam origin is in compliance. Wondering if any colleague would know what’s the proper methodology to determine COO for this non-preferential […]
Question: What is the percentage of local content to qualify Philippines as the country of origin? Answer 1: You haven’t indicated what the product is, which is important to know when determining origin. Generally the local content percentage would be no more than one factor in the origin analysis, and with many products the local […]
Question: What is the percentage of local content to qualify Philippines as the country of origin? Answer 1: You haven’t indicated what the product is, which is important to know when determining origin. Generally the local content percentage would be no more than one factor in the origin analysis, and with many products the local […]
Question: I hope the members will be able to help me. We are an EU company producing cement additives and I have some doubts regarding the HS classification and the country of origin determination for the finished products. If the finished product (intended to be used as a cement additive) consists of one chemical (chapter […]
Question: We are curious when we can use regional value content (RVC) to determine the country of origin, for example, we import an electronic component, the majority of the components are from China and a few of the parts, such as the “brains” are manufactured in Cambodia, Malaysia or Vietnam, the finished product is assembled […]
Question: Two Questions: (1) Country of Origin (2) FTA, i.e. CAFTA, applicability under de minimis. A frozen ready-to-eat vegetable mixture contains frozen vegetables of the following: %40 sweet corn (HTS 0710.40), 40% fire-roasted sweet corn (HTS 2004.90), 5% red bell peppers (HTS 0710.80), and 5% poblano peppers (HTS 0710.80). Corn was grown, harvested, processed in […]
Question: I’m looking for guidance as to how other members maintain country of origin information within their ERP not only from a US perspective but globally as well. A situation recently arose where our related entity showed a COO on an invoice for US import that was unusual. After I dug into it, I found […]
Question: I’m looking for assistance with where I start to look for rules and regulations around assigning country of origin to a retail set. We are looking to import a set which contains items of 2 different origins, and I want to be sure that we are reporting correctly. The 2 items are of different […]
