US-China TariffsGlobal Trade Intelligence

Country of Origin Marking Requirements

25 January 2025·Updated Jan 2026·7 min read·GuideIntermediate
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In this article
  1. Country of Origin Marking Requirements
  2. Substantial Transformation Rules
  3. Marking Exceptions and Special Cases
Key Takeaways

Comply with marking rules or face penalties — every imported article must be marked with its country of origin

  • Country of Origin Marking Requirements
  • Substantial Transformation Rules
  • Marking Exceptions and Special Cases

Country of Origin Marking Requirements#

19 USC 1304 requires every imported article to be conspicuously marked with its country of origin in English. Failure to mark correctly results in 10% marking duties on top of regular duties. CBP regularly audits marking compliance — it's one of the most common penalty triggers.

Substantial Transformation Rules#

Country of origin changes when a product undergoes substantial transformation — a new name, character, or use. Assembling Chinese components in Vietnam doesn't automatically make it Vietnamese origin. The transformation must be meaningful. CBP looks at the nature of the processing, not just its location.

💡 Key Insight

Some goods are exempt from marking: bulk commodities, goods incapable of being marked, and articles for the importer's own use (not resale).

Marking Exceptions and Special Cases#

Some goods are exempt from marking: bulk commodities, goods incapable of being marked, and articles for the importer's own use (not resale). But claiming an exemption incorrectly is worse than over-marking. When in doubt, mark it. The cost of a label is nothing compared to marking duty penalties.

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Key Takeaways
  • Comply with marking rules or face penalties — every imported article must be marked with its country of origin

People also ask

What is the business impact of country of origin marking requirements?

Comply with marking rules or face penalties — every imported article must be marked with its country of origin

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Foreign Trade Zone Benefits for Importers
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