Country-of-Origin Marking for Products Imported into the U.S.

Understand the general marking principle and why product-specific review is still important.

Overview

Understand the general marking principle and why product-specific review is still important.

U.S. customs law generally requires imported articles to be marked with the English name of the country of origin so that the ultimate purchaser can identify where the product was made. The marking should be conspicuous, legible, indelible, and permanent to the extent permitted by the nature of the article.

 

The correct origin is not always determined solely by the country of final packaging or simple assembly. Substantial-transformation analysis, tariff rules, special trade remedies, and product-specific regulations may affect the conclusion.

 

The product, retail packaging, master carton, commercial invoice, and customs entry should be reviewed for consistency. Phrases such as “Designed in USA” do not replace a required country-of-origin statement and should not obscure or contradict it.

 

Because exceptions and special marking rules exist, importers should obtain product-specific customs advice when origin is unclear or manufacturing occurs across multiple countries.

APEX CS practical takeaway: Confirm the product-specific regulatory pathway before production, testing, labeling, or shipment. Requirements vary by device design, intended use, claims, market channel, and final configuration.

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