So confused about Country of Origin requirements.. Help

[comment]

My company is soon going to begin importing hand tools, such as sockets which attach to wrenches, meant for working on cars. The sockets will be made of Chrome Vanadium Steel and will be coming from China and arriving in the USA (port of Tampa).

I can not find exactly what is required when it comes to "Country of Origin" labeling. I understand in some cases, the product container can be labeled, but in other cases, the actual product has to be physically labeled unless it undergoes significant, value-added change.

The sockets will be shipped in the following format: There will be one master carton, and inside of that will be smaller boxes, each containing 20 sockets.

When the sockets arrive in the USA and are taken delivery of, my company plans on putting each socket in individual packaging which says "Made in China", and then selling it at retail.

Is this sufficient, or will each individual socket need to be machined/stamped with "Made in China", prior to import? Is this a case where it would be acceptable to simply place a sticker on the container (not master container) the sockets come in?

Is there any path I can take to avoid machining/stamping each socket prior to import? Possibly having them packaged in China and having the packaging say "Made in China"?

 

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[jon.a]

Does this help?
http://www.cbp.gov/trade/nafta/country-origin-marking

 

[comment]

Does this help?
http://www.cbp.gov/trade/nafta/country-origin-marking

Not quite.. I've gone through that resoruce, the customs dictionary, and a few other customs resources. I'm just looking at what seems to be a gray area.

The idea is that, the product must be marked "made in china" when it arrives, in a way so that the ultimate purchaser (consumer) will be able to tell what country it came from. Different products have different regulations though. Pipe fittings and watch casings for example, have to be stamped with the country of origin, directly on the metal prior to import. Other products like, say a pair of dice, could simply be inside packaging which says "made in china" (under the condition the product is not repackaged in america).

I am just having a hard time finding where my product lies. I have to either stamp it prior to import, or have packaging made in China and have it packaged prior to import (although customs does not give their definition of "sealed packaging". The socket is shaped like a pipe, so does it fall under the pipe rule? There arent specific hand tool rules, and as far as material goes there arent any rules about steel (as far as country of origin goes). I've emailed customs and posted on a few forums but it doesnt seem like anyone knows for sure.

I think, as silly as it sounds, my best bet for a solid answer is to just go to harbor freight, find products similar to mine which are made in china, and take a look at where the country of origin mark is.

 

[MattR82]

Maybe a customs broker would know?

 

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[Walter Hay]

Maybe a customs broker would know?

Good suggestion @MattR82.
@comment, You could also think outside the box. There are other ways to show country of origin. Even a tiny stick on printed label would satisfy the regulations that require that the country of origin must be clearly legible until the product is in the hands of the customer. (The end user.) Country of origin labels don't have to last even beyond first use of the tool.

Walter

 

[comment]

Well, finally checking in...

I went to harbor freight and found a bunch of products similar to mine, and they were all packaged in either a box, or used a sticker. I then contacted a freight forwarding company I already use sometimes. I pretty much decided to just order 3000 boxes from China and have my product put into them prior to shipment. Should work out nicely. 3000 boxes was only $90 too.

 

[David Young]

If it is clear to customs and the end user then then you are ok.

 

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