QUESTION: What should be the role of a US based Trade Compliance Department in the determination and maintenance of Country of Origin Marking for overseas manufacturing facilities (related party facilities)? Who should be responsible for Determining Origin? And who should be responsible for maintaining origin? Is there anything on the regulations that could point to […]
QUESTION: Are prescription drugs exempt from marking statutes? I noticed that some imported prescription drugs are labeled at the consumer level with the country of origin, while some are not. Some labels instead mention the manufacturer name which doesn’t help as some have facilities producing the same drug in different countries. ================================================================ Answers: Items made […]
QUESTION: CROSS ruling NY N202375 utilizes 19 CFR 102 in a way which appears to contradict its scope. In the ruling, origin is being determined by part 102 for product which is non-FTA qualifying and non-textile/apparel. My understanding is that origin for such product is to be exclusively determined by the “new name/character/use” test. Is […]
QUESTION: We are importing 5 different items from the EU into the USA. The 5 items will be going into further fabrication or production, so we will not be the ultimate purchaser. The 5 different items, all have their own packaging, which will indicate “Made in …”, however, these individual boxes will be packaged and […]
QUESTION: We have a third party relationship with a company in Mexico, who handles our US parts assembly, package and then re-shipped to US for our North America market. The label and IFU show the phrase, “Assembled in Mexico with US parts.” The question is – · Is the phrase “Assembled in Mexico with US […]
QUESTION: If a generic imported consumer good (no special requirements such as textile, FDA, etc.) is permanently labeled with the actual name and address of the manufacturer, is that sufficient for origin markings It does not state “Made by” or similar. Would “Made By”, “Made in” or similar verbiage have to be added in order […]
QUESTION: I am curious about how to determine country of origin for a label. Would it be based on the country of origin of the blank label material or is the label substantially transformed when it is printed on? ========== Answers: I would not count the printing on a label to be a substantial transformation. […]
QUESTION: In the past week my company has seen 4 shipments stopped upon import into China because the commercial invoice is showing a country of origin TW. China customs is refusing to enter the shipment until the invoice is updated to show a country of origin Taiwan, China. Have other members been experiencing the same […]
QUESTION: I have a question about origin marking requirements. Where does it state that a marking waiver must be requested and approved to be excepted from marking each item in a carton with the country of origin? 19 CFR 134.32 (d) states that “articles for which the marking of the container will reasonably indicate the […]
QUESTION: Is there issue if an item is marked “Made with US materials and assembled in Mexico” ? A literal reading of the Customs origin rule would seem to dictate that “Assembled in Mexico….” Should come first. ========== Answers: “Assembled in Mexico of…” is the way to go. =========== What CO are you actually trying […]
QUESTION: US made products are sent to Mexico for finishing. The further work in Mexico does not cause tariff shift under the 19 CFR 102.20 rules of origin. Per the NAFTA Preference Override rule in 19CFR 102.19(b) Mexico is the country of origin for DUTY purposes and Field 10 of the NAFTA certificate of origin […]
QUESTION: I have recently started at this manufacturing company. My predecessor had PRODUCT OF THE USA added to our boxes. So far, China and Saudi Arabia have both had problems with these boxes and require us to cover that with MADE IN USA. We are going to order new boxes that say MADE IN USA. […]
