Country of Origin

Questions and answers about Country of Origin

  • Manufactured in the US

    Question: Our company manufactures a product in the US using globally sourced raw materials, including US raw material. The product is then sold in the US. The product does not have an FTC labeling requirement. The manufacturing and finishing processes all occur in the US, but the originating material (steel) makes up the majority of the […]

  • CoO determination

    Question: Hello.  I need help with a country of origin determination regarding substantial transformation. We have an analyzer we assemble in the United States by means of integrating three main components (measurement case, distributed measurement control, and common electronics).  All components are sourced from Mexico.  Assembly takes about two hours per unit and is highly […]

  • First Sale & Country of Origin

    Question: Factory in Sri Lanka sells to middleman in Sri Lanka, who then sells to U.S. Importer.  Assume the transaction meets all first sale valuation criteria. Country of origin of the finished goods is China.  This because fabric (HS 5208) is formed in China, finished good is classified under 6213, and per tariff-shift rule stated […]

  • Country of Origin of Combined Items for Retail Sale

    Question: We will sell a product that is a battery charger that is packed with two rechargeable lithium ion batteries for use in consumer electronics. The entire product is packaged for retail sale and classified with 8504.40 under GRI 3(b) with the charger imparting the essential character. The charger is manufactured in Vietnam, with SMT […]

  • USMCA, 19 CFR 102, and Section 301

    Question: Ruling NY N317669 is an example of one of several rulings where CBP has determined that the origin for marking purposes (under 19 CFR 102) and Section 301 is China, but the good qualifies for USMCA. How does this work in actual application for listing the country of origin on the USMCA Certification and […]

  • 19 CFR 102, USMCA and Section 301

    Question: With so many CBP rulings issued on USMCA, 19 CFR 102, and Section 301 implications that sometimes seem to conflict, I am curious to know the membership’s input on the following scenarios. #1) Components are sourced from China and processed into a new item in Canada. CBP rules that the country of origin (based […]

  • Country of Origin of Boltless Shelves

    Question: I am looking for advice and suggestions on determining the country of origin of the boltless shelving we’re getting to import from China.  The imported article has the following components:  Metal Parts (no nuts and bolts) are made in China  Wooden Boards are made in Thailand   The Chinese manufacturer opened a facility in Thailand […]

  • Country of origin on old machine

    Question: Hello, Looking for advice and suggestion on how to determine country of origin an old tooling that we own and currently is located in China.  If the machine is being moved to the U.S., how would we value the tooling and determine the origin? Answer 1: The country of origin will be the country […]

  • Country of Origin

    Question: Metal parts country of origin is China; Wooden boards county of origin is Thailand; Metal parts are ship to Thailand to be packaged and shipped with wooden boards. Metal parts (HTS 94039090) are shipped from China to Thailand. Final product packaged and shipped together (9403.20.0075) from Thailand to USA. What will be the COO […]

  • Country of Origin for VN Fan assembled into final product in CN

    Question: We currently import an assembled product as an axial Fan (8414.59.6590). The assembled product does not work without a fan, hence this is the essential character of the end product. If the fan component is sourced in Vietnam (and carries a VN CoO), then sent to China for assembly of the finished item, does […]

  • Country of Origin, County of Production, etc.

    Question: Does anyone have a good whitepaper or definitions of the difference between, Made in, country of origin, country of production, product of, produced in….etc? Answer 1: We use this for pharmaceutical products: API Source Determining COO Wording in Labeling 1. API from one source Country of API source, e.g. India Product of XXXX 2. […]

  • Country of Origin by Lane

    Question: Good day, We are faced with an issue where we need to deal with different COO rulings from different importing countries. The U.S for example interprets substantial transformation for some of our products differently from how most other countries do. We have thus decided to explore the possibility of assigning COO to not just […]