Country of Origin

QUESTION: We purchase mini whiskey barrels made from American White Oak (country of origin is USA) from a US based company. The company ships the lumber to Mexico for manufacture into barrels. The wood experiences a tariff shift from lumber to casks in Mexico. Then the barrels come back to the US based company and […]

QUESTION: In addition to a response I’ve received on this site (which I greatly appreciate!), I’ve seen a few articles published on the internet which allude to the country of origin determination logic found in 19 CFR 102.11 being applicable to all situations. In particular, for an item unassembled as imported with components of various […]

QUESTION: Importing into the US an unassembled machine classifiable in Chapter 84. All components are individually packaged and shipped on the same master b/l. Certain components are from CN, others are from TW and VN. No FTA is in play, so origin is determined by the “new name, character, use test.” Being un-assembled at the […]

QUESTION: Just trying to figure out what FDA and CBP considers Country of Origin. Can they be different? What is main difference? Does FDA consider country of origin to be last country to manufacture? Does CBP consider country of origin to be last country where substantial transformation occurred? Is there anything in the 21CFR where […]

QUESTION: Can anyone provide a substantial transformation test or formula that can help me determine the COO for a product? My understanding is that for preferential treatment, each FTA has its own rules of origin. And for non-preferential treatment, the rule is the “substantial transformation.” Am I correct? Here is the scenario: 1. We currently […]

QUESTION: My company has run into a situation with Chinese Customs in regard to items being labeled with the COO as Taiwan. Customs is now putting more focus on this and are enforcing the regulation of items from Taiwan to be labeled as “TAIWAN PROVINCE OF CHINA”, “TAIWAN, CHINA”, “CHINESE TAIWAN”, etc. What implication would […]

QUESTION: Is there any resource or database that lists the non-preferential rules of origin for all countries? ========== Answers: “Substantial transformation” ========== There is no international standard set of non-preferential rules of origin. See the WTO web-page for more information: https://www.wto.org/english/tratop_e/roi_e/roi_e.htm. Paul Vandevert, Principal paul@ochimtradelaw.com +1 313.737.3675 www.ochimtradelaw.com ========== You can start here…https://www.wto.org/english/docs_e/legal_e/22-roo_e.htm ========== In […]

QUESTION: How are you dealing with issuing a Certificate of Origin document for non US goods when shipping to China? Is anyone using their invoice ONLY in order to fulfill the need for the Chinese regulation? *************** Answers: Invoice is not enough per my experiences. Certificate of origin issued by Chamber of commerce and industry […]

QUESTION: Can some experts help advise the correct country of origin of a KIT contains 2 computer boards form factors (COO = China/Hong Kong) and one computer cable (COO=CN). This KIT (3 items) was assembled (put up together) in Israel. I do not believe there is a change of name or substantial transformation from the […]

QUESTION: We’re looking to determine COO requirements on a global level. For example, The US uses 19CFR102 Rules of Origin and “Substantial Transformation” to determine COO. Where China or Turkey could have a different process to determine COO. In addition, COO labeling requirements, as they kind of go hand in hand. Can someone recommend a […]

QUESTION: Thank you all for your advice. However, the final info received is the 2 PCB “bare boards” themselves were produced in Hong Kong, then they were shipped to Israel and assembled in Israel all the components such as IC, memory, resistors, capacitors made in China. These 2 new boards (COO = HK) with active […]