GDLSK: Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP
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Country of Origin and Marking

The country of origin of imported products can impact the tariff status and marking requirements of imported merchandise. Origin determinations become complex when imported products undergo processing in more than one country and in instances where components or raw materials are sourced from multiple countries. Depending on the countries involved, different origin tests may be applicable including substantial transformation, tariff shift rules and/or regional value content. In some instances, manufacturing scenarios can be strategically planned to secure more favorable tariff treatment.

The U.S. Customs laws also require imported merchandise to be marked accurately and conspicuously to reflect its country of origin. Regulations relating to the labeling of imported merchandise have also been promulgated by other Federal agencies, including the Federal Trade Commission, the Food and Drug Administration, and the Federal Communications Commission. Non-compliance with these labeling requirements can delay or prevent the clearance of merchandise and subject the importer to significant monetary penalties.