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Manufacturing steps matter
The marking framework starts with manufacture, production or growth and considers whether further work effects substantial transformation. The rule directs relevant NAFTA/USMCA-country marking cases to the special Part 102 provisions; one general transformation approach cannot be assumed for every product.
In a fictional case, components are made in one country and assembled in another. The words assembled in another country do not themselves establish that origin changed. What happened to the materials and product before and after the work matters.
What the general marking rule requires
Foreign-origin articles, or their containers as applicable, generally must show the English country name conspicuously, legibly, indelibly and with sufficient permanence for the ultimate U.S. purchaser. A country mentioned only in paperwork does not necessarily meet those qualities.
Exceptions and special rules can change the answer for particular articles, containers or subsequent operations. This guide determines neither the fictional product’s origin nor a marking exception.
Marking is not a tariff-preference decision
Brand ownership, departure port, marking origin and preferential tariff origin are distinct. A conclusion for a label does not automatically establish tariff preference or trade-remedy treatment. A supplier or manufacturing-process change can also make an old label conclusion unsuitable for the new goods.
Scope
- No product-specific substantial-transformation, Part 102, marking-exception, preference or trade-remedy finding is made here; other product labels need their own review.
Next step
Check the actual production steps and proposed label together before printing it for the U.S. shipment.
Sources & review notes
U.S. Customs and Border Protection
Passage, dates and research notes
primary · §134.1(b)
Further work or material added to an article in another country must effect a substantial transformation
Read country-of-origin definition and express part-102 marking-rule treatment for NAFTA/USMCA country goods. No product-specific origin or substantial-transformation ruling made.
U.S. Customs and Border Protection
Passage, dates and research notes
primary · §134.11
in a conspicuous place
Read full general requirement, subject to the part’s exceptions. Tariff preference, trade remedies and product-label rules are distinct; no all-purpose origin determination inferred.
Detailed rule records (1)
Section 134.11 states the general imported-article origin-marking requirement subject to exceptions. Section 134.1(b) defines marking origin by manufacture/production/growth and substantial transformation, with a specific part102 rule for relevant NAFTA/USMCA-country goods.
19 CFR §134.1: definitions for country-of-origin marking 19 CFR §134.11: country-of-origin marking requiredKeep this reading in your learning library.
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