Country of Origin

Questions and answers about Country of Origin

  • SUBSTANTIAL TRANSFORMATION

      Question:   I have a question about when do we confer COO change.   I’m in manufacturing and our engineers like to make assemblies for testing equipment. Another LCB and I are having a debate on when COO changes for some of them.   We recently shipped a timing system that was a control […]

  • Taiwain Rules of Origin FT

      QUESTION:   Does anyone know where one can research the Taiwan rules of origin and trade agreements?  We are bidding on a Taiwan government project which we can source from several locations – US, Brazil or Japan. 

  • COO certificate

      Question:   My company is purchasing items from a US source who has issued a certificate of origin to us that we disagree with.  Is it possible for us to submit a request for COO ruling to CBP, or is the actual importer required to do submit?  The source we are dealing with is […]

  • COO multiple country components (cont)

    QUESTION: Empty metal tins from Country A are going to be shipped to Country B to be filled with shoe care/shoe wax-like product. For COO purposes, is it just fine to have printed on the tins or a sticker indicating, “Made in Country B,” without any mention of Country A? The essential character is the […]

  • C/O for item w/multiple country components

    Question: I am trying to determine country of origin for a squeegee. There are 3 components to the squeegee – handle, channel, rubber “blade”. The rubber blade slides in to the channel. The handle clamps down on both the channel and rubber blade to complete the unit. The three pieces are imported and packaged together, […]

  • Multiple c/o for same product code

    Question: Can anyone share how they deal with multiple countries of origin for the same product code? The company wants to dual source (one source is the US the other is Thailand) an item, but they don’t want to create a separate SKU number for it. It would mean two inventory pick locations, more SKUs […]

  • COO FOR TEXTILES

    QUESTION: Just wondering if anyone in the association has been having marking issueswith U.S. Customs concerning the location of the country of origin. We arebeing told that it is their opinion that we should have the country of originon the front of our hang tag because that draws the attention of the ultimatepurchaser, even though […]

  • PRODUCT OF VS MADE IN

    Question: I have been asked to explain the difference between “Product of USA” and “Made in USA”.  Would someone kindly point me to the proper source for the definitions and correct usage?

  • CO OF COMINGLED LIQUIDS

    Question: I work for an industry that produces a beverage consumable. There hasbeen some discussion internally, due to some scarcity of raw material,that we may blend foreign and domestic raw materials.  Both of the sameHTS so there is no substantial transformation.  If each part is of equalcharacteristic and it doesn’t meet the content requirement of […]

  • COO END MARKING FOR SETS

    Question: I have a COO marking question. I import a component for my end customer. It is a blank empty bottle.  Outercarton of the merchandise has COO of China shown on it, otherwise the bottleis blank and no COO anywhere.  My customer modifies it slightly (screen printing ) and then put it up in a […]

  • COUNTRY OF ORIGIN DETERMINATION

    Question: I would appreciate any comments regarding Customs Ruling # 9111-14 that allowshardware made abroad to be classified as USA origin once US made firmware andapplication software (necessary for it to operate) is incorporated uponimportation.  Has anyone used this ruling to classify different types ofhardware made abroad as made in USA using this “substantial transformation”methodology?