In the Jan. 19, 2022, Customs Bulletin and Decisions, U.S. Customs and Border Protection is modifying two rulings regarding the country of origin marking of two different medical kits each containing a variety of individual components sourced from various countries. This action will be effective with respect to subject goods entered or withdrawn from warehouse for consumption on or after March 20.

Rulings HQ H016800 and HQ H190655 required the sealed outer containers of these goods to be marked with a list of the countries of origin of all components contained within, without reference to the country of origin of each individual component (e.g., “contains products of Mexico, China, U.S.”).

However, ruling HQ H265715 reflects CBP’s current position that the kits must be marked to specify the country of origin of each component (e.g., “catheters made in Mexico, hemostats made in Pakistan,” etc.). CBP explains that T.D. 91-7 requires each item, if not substantially transformed as a result of its inclusion in a set, to be individually marked to indicate its own country of origin.

For more information on how to seek or utilize CBP rulings, please contact attorney Deb Stern at (305) 894-1007 or via email.

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