Several origin questions that sound like one
Origin comes up in more than one legal setting, and the answers do not always line up. For customs purposes, most imported goods must be marked so that the eventual buyer in the United States can see where they came from, and Customs and Border Protection decides how that rule applies to a given product and package. When parts from several countries go into one product, the origin usually turns on whether the work done in the last country substantially transformed it, a test that depends heavily on the facts. Preferential trade programs, such as the agreement with Mexico and Canada, apply origin rules of their own, so the answer for marking and the answer for a duty preference are not always the same. Claims printed on packaging, such as Made in USA, fall largely under the Federal Trade Commission rather than CBP, and the standard for an unqualified claim of that kind is demanding.
When CBP or a buyer questions the label
Problems tend to surface when a shipment is detained for missing or incorrect marking, when CBP sends a request for information about where production actually happens, or when a customer's compliance team asks for proof. Goods that arrive improperly marked can often be brought into compliance under CBP supervision, and goods left uncorrected can draw additional duties, with penalties possible as well. An origin claimed in order to avoid higher duties is treated far more seriously than a sticker in the wrong place. Moving final assembly to another country is a common response to tariffs, and CBP looks closely at whether the work done there changed the product's character or merely finished it. Evasion investigations can reach importers who relied entirely on a supplier's word.
Documents that support an origin position
Collect the bill of materials, where each component is made, a description of the manufacturing steps at each location, and the invoices and certificates your suppliers provided. Photos of the packaging and the product as imported help show what a buyer actually sees. If the question is still forward-looking, a binding ruling from CBP can give an answer before you commit to a supply chain or a packaging run. Our first review sorts out which origin rule actually governs your problem, whether past entries need to be corrected, and whether a ruling request makes sense before the next order ships.
