Background

In the Oct. 13, 2021, Customs Bulletin and Decisions, U.S. Customs and Border Protection is proposing to modify two rulings regarding the country of origin marking of two different medical kits each containing a variety of individual components sourced from various countries. 

Currently, under rulings HQ H016800 and HQ H190655, the sealed outer containers of these goods must 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, it is now CBP’s 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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