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Example Question:

How do you determine the country of origin for parts/components you are purchasing – do you physically inspect the parts as they are received,do you require the vendor provide this information prior to shipping,or do you employ a combination? According to our purchasing group, we purchase from distributors who may, or may not, know the actual country of origin of the parts/components which we will receive.


As the importer it is your responsibility to know the country of origin of the products you import. Unless the products falls within the exceptions in CBP Regulations or you have obtained a ruling from CBP that permits it, you are required by law to have each article marked with the English name of the country of origin. In any case your documents are required to show the correct country of origin. Though the product marking is almost uniquely a U.S. requirement, having the correct information on the documents is pretty must universal in all countries. You may be facing an educational challenge with your purchasing group, but they need to get with it and conform to the law–else eventually you are going to have some very hard and expensive questions to answer to a CBP officer


We require written documentation from the supplier on the commercial /proforma invoice declaring the actual country of origin for parts /components. We also require our procurement group complete a product description form which includes the supplier name and country of origin/manufacture, and record this information in our classification database. If there is a discrepancy between the two, we investigate prior to entry. In general, we do not physically inspect the parts as they are received for country of origin marking, although that has been discussed as a possibility on a random / sample audit basis in the future. We do have one or two suppliers that act as foreign distributors for multiple origin parts. For those suppliers, we carefully scrutinize the c/o for each part, record the c/o and actual manufacturer name if we can obtain this, and review any discrepancies with the buyer to ensure the documentation / information is correct prior to entry.


We require our vendors to supply the country of origin. However, we don’t import parts so our situation is somewhat different than yours. I imagine an inspection would be needed if you don’t have a high level of confidence in what you’d receive. After all, IOR is responsible for the accuracy of the information provided to CBP


1) Are you manufacturing a new article with the imported components? If so you may be able to take advantage of an exemption for the marking requirements–check your sources.

2) Are the items arriving in retail packaging, and are they from countries with similar duty treatments…you may be able to request permission from Customs to mark them “made in one of the following countries: aaa,bbb,ccc” where a,b,c etc. are all of the possible origins identified by your distributors. Then you could provide this information to the distributor for the paperwork AND for marking the products.

3) Can you require distributors as part of their agreement to work with you to agree to 1) track origin and 2) provide origin BOTH on the shipping documents and on the products? 4) Bottom line is the paperwork has to identify the origins at time of import, and the products have to be marked at time of import unless you can find an exemption or come up with another solution. You do need to audit this when you receive product, but if you do have a Customs inspection, and the products are not marked, the fact that you mark them after you receive them will not help.


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