QUESTION: If a company ships various components, in bulk quantities, of US origin to Costa Rica for further production and/or assembly, would these actions change the origin of the finished item(s) to Costa Rica? Would this depend on the nature of the further processing? How does/would accumulation be considered in this determination? What other factors […]
QUESTION: We are assembling a motor starter (8536.50.4000) where we have sub-components from different countries. These starters can be either DUPLEX or TRIPLEX (for 2 or 3 motors) which changes the number of some components. The assembly takes place in Mexico. The main components are: 1 Enclosure – MEXICO 8536.90 ($47) […]
QUESTION: If an electronic product is designed and developed in Belgium, the software to run it (firmware) is also designed and developed in Belgium, but the electronic product will eventually be completely manufactured in the US – would the origin of the technology and software remain Belgium? There is no US contribution in the design/development […]
QUESTION: Would like the memberships guidance on Made in the USA qualifiers. We would like to change ours to “Made in the US (USA) with Global Materials, – or “Globally Sourced Materials” We manufacture goods that are “substantially transformed” in the US, from US and global parts – complete Tariff shift to a “new and […]
Question: Our products are currently marked “Made in USA with Globally sourced components”. Since this a very long and is required to be put on our parts by laser, we are looking to shorten the qualifier. I’m looking for example of qualifiers that would adhere to the FTC regulations, but perhaps be less characters. […]
Question: We have a leather planner being manufactured in Vietnam without the paper. We then ship to China where the paper portion is inserted. Once complete, the shipment is shipped to the US. Do we need to use both countries as the COO and how should we mark them? ************** Answers: I would need […]
Question: We are a Canadian company serving the scientific research market. We import into Canada plastic tubes from Germany, insert another proprietary piece into the tube, sterilize and package the tube for sale. The cost of the tube from Germany is 20% of the final cost of the product. This does not qualify for Nafta […]
Question: What is the origin of animal tissue samples for laboratory purposes? Is it the country where the tissue sample was extracted,the country where the animal was born or the country where the slide was put together holding the tissue, which has a different classification from the animal or tissue? The slide could be put […]
Question: I am in a discussion about country of origin determination and auditing. Different countries have different rules for determining COO at time of import. At what point do you sit back and accept the COO listed on the invoice or certificate of origin? i.e. some countries, like Mexico, will say that a 35% added […]
Question: We produce some parts under heading 3924, which states: 39.24-39.26 A change to heading 39.24 through 39.26 from any other heading, including another heading within that group, provided there is a regional value content of not less than: (a) 60 percent where the transaction value method is used, or (b) 50 percent where the […]
Question: We are an importer who use several brokers to manage our US imports. We’ve noticed inconsistencies with how one of our brokers is declaring the Country of Export on Form 7501. We had an example in which a product was shipped from United Kingdom, but made a stop in the Netherlands so that the […]
Question: I just received an email from my marketing and service department that they are requesting to remove from our service & operator manuals and other publications the wording “Printed in the USA”… They claim they have researched and it is not a regulatory requirement. I have second thoughts about this and I want to […]
