Country of Origin Marking for Imports

Determine what is imported, what processing occurs after importation and who receives the article in its imported or transformed form. Part 134 defines the relevant concepts and contains special provisions. Origin may require analysis of manufacturing operations rather than a simple reference to the final shipping country or the seller’s business address.

Covered foreign-origin articles generally require marking that identifies the country of origin to the ultimate purchaser. The rule addresses conspicuousness, legibility and permanence, as well as exceptions and container marking. An exception must be connected to its conditions; it should not be inferred merely because placing a mark on the article would be inconvenient.

Repacking, combining articles and processing after importation can affect how origin information reaches the purchaser. Review these activities before approving packaging artwork. NCQM practice consideration: include origin marking in the change review for a new pack size, distributor package or assembly operation. A mark present at importation may not remain visible through the final distribution arrangement.

CBP marking requirements do not resolve every claim regulated by the Federal Trade Commission or every preferential trade program rule. Textile and other product-specific labeling provisions may also apply. Keep separate records for customs origin, preferential eligibility and advertising substantiation, with the legal basis and intended use of each conclusion clearly identified.

NCQM practice consideration: retain the manufacturing sequence, component origins, supplier declarations and relevant rulings or advice used in the assessment. Establish a trigger for review when production moves or processing changes. A supplier’s invoice description can support identification but may not explain the operations needed to determine the article’s origin.

Connect the approved origin conclusion to the actual label, article or container and shipment configuration. Record who authorized the marking and how packing operations verify it. Where interpretation is uncertain, use CBP’s appropriate ruling or guidance route. NCQM does not issue origin determinations or replace the importer’s responsibilities.