Country of Origin

Questions and answers about Country of Origin


    QUESTION: Wondering if anyone in the membership has any advice on how to validate country of origin for massive list of over 100 component parts?  Specifically looking for country of origin of Vietnam.  Are there are any basic rules to ask yourself before confirming the origin or do you really take into account the “wholly […]


    QUESTION: I am wondering if anyone else has had this problem and if so, how was it resolved. We import bulk goods from a company in Germany and they are not able to tell us the country of origin. They say their suppliers don’t even know the country of origin because they get the nuts, […]

  • Managing Roo’s

    QUESTION: What should a company do to manage differing non-preferential ROOs for one part? CFR 102 non-preferential ROOs differ from the EU non-preferential ROOs.  The assembled part will import both into the US and have global distribution on the same ERP part #. I can’t find the WCO ROOs online. ************ Answers: The rules of […]

  • Kits Country of Origin

    Question: Need assistance from ICPA members regarding country of origin for kits. We have the following scenario, is a kit that consist of washer, nut, carton, bag, label, label. The kit is put together for retail sale.  But not to sure on the country of origin will be, as there is 2 washers one from […]

  • Country of Origin

    QUESTION: Our company work with steel and iron products. We obtain a mill certificate for each item of purchase.  My question is this.  If the origin of the melt is say Spain but then the item is formed into a new item in Malaysia, what is the origin?  Where the transformation takes place or where […]


    QUESTION: Since joining my company a few years ago, I have struggled to communicate to leadership the importance of collecting and maintaining Country of Origin information from suppliers in our ERP system.I am responsible for Trade Compliance and government funding certification, so Country of Origin is a critical element of any analysis. Unfortunately, we don’t […]


    QUESTION: I plan on filing PSC and Protest for declaring incorrect COO on the entry. These are all purchased products, so I do not have a BOM or the specifics, so my only option is to rely on the supplier or the manufacturer’s certificate of origin. According to the recent answers from membership, that I […]


    QUESTION: What kind of certificate of origin do I need to have in order to file protest to update Country of origin? What are all the data elements that are needed to be on the certificate? ========== Answers: You need to establish the correct country of origin based on a qualifying substantial transformation, whether you […]

  • Customs Country of Origin determination on pharmaceutical products

    QUESTION: What would be the country of origin, for customs purposes, on a pharmaceutical product that has two Active Pharmaceutical Ingredients from two different countries? The API’s from Germany and Italy are manufactured into dosage form in the United States. ============ Answers: USA is the CoO in this instant case.  See these rulings H290684, HQ […]


    QUESTION: If I have a repair “kit” that meets the GRI 3(c) rule (different materials or made up of different components, put up in sets for retail sale, but no one item confers the essential character, so classified by heading which occurs last), but the components are both domestic and foreign, how do I address […]

  • Country of Origin

    QUESTION: We buy items such as screws and hardware from a local distributor and export as spares. The items are low in value from .03 to .98 cents each. When we ask distribution for a specific country of origin they says — VARIOUS and name 5 or 6 countries as the possible country of origin. […]

  • Answer to Question on COO of non substantially transformed goods

    QUESTION: How are other companies marking their commercial invoices for imports to the US from Mexico to communicate COO for Section 301 purposes when general COO = MX but Section 301 = CN? ============ Answer: The Energizer case already has the answer.  Distilled, however, it’s a China origin with regards to Section 301, but it’s otherwise Mexican […]