• Determining Country of Origin

    Question: We make 2 products that are made from raw materials sourced from Canada in the US.  Until recently we have considered our products COO as US but after a recent training session we are questioning that.  The products are Laminated Veneer Lumber and I-Joist.   All the Veneer, Lumber and OSB are obtained from Canadian […]

  • Steel and Aluminum Tariffs

    Question: Is anyone having difficulty getting certs or breakouts from foreign suppliers? If so, how are you handling this? Answer 1: I received this from my Customs Broker: Here is some information by CBP regarding the country of smelt or cast/melt and pour. https://www.cbp.gov/trade/programs-administration/entry-summary/232-tariffs-aluminum-and-steel/faqs

  • Country of Origin for pharmaceutical products Canada

    Question: US Customs considers the country of origin (COO) to be the last location of substantial transformation- most of the time for pharmaceutical products COO is API manufacturing location.    Does Canada Customs align with US Customs on COO for pharmaceuticals to be an API manufacturing location?  Does Canada Customs have something similar to CROSS […]

  • Pharmaceutical Country of Origin – Tariffs

    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 […]

  • Substantial Transformation 301 Tariffs

    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 […]

  • Ace report

    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”.  […]

  • Methodology for determining COO on returned goods

    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 […]

  • Country of origin determination method

    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 […]

  • Philippines – Rules of Origin

    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 […]

  • Philippines – Rules of Origin

    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 […]

  • Country of origin & HS code determination

    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 […]

  • Regional Value Content and Country of Origin

    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 […]