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Is the Country Where a Product is Assembled Considered the Country of Origin?


With respect to Country of Origin (COO) labeling requirements, could a complete system that is assembled in Finland, with goods that come from over the world, be labeled as “Made in Finland”?


Under the Tariff Act of 1930, every article of foreign origin (or its container) imported into the U.S., unless exempted, must be marked in a manner that will indicate to the ultimate purchaser the article's country of origin. In the U.S., non-preferential standards for goods manufactured in, assembled in, or using materials originating in more than one country specify that the COO is the last place in which the good was substantially transformed into a new and distinct article of commerce, based on a change in name, character, or use.

© 2020 Keller and Heckman LLPNational Law Review, Volume IX, Number 316


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PackagingLaw.com is the premier online resource for the global packaging industry. It provides a wide range of information on laws and regulations—both in the U.S. and other countries throughout the world—that affect packages and packaging materials. PackagingLaw.com features news articles on current issues affecting the packaging industry, in-depth features, an Ask an Attorney section, links to packaging industry and government websites, and detailed information on the U.S. Food and Drug Administration (FDA) Food Contact Notification system.