Customs, Imports & Country of Origin

Manufacturers, distributors and sellers of products that are either imported from a foreign country or contain foreign-made parts are subject to a comprehensive set of Regulations governed by the Federal Trade Commission (FTC), U.S. Customs & Border Protection and certain state regulators.  These agencies set rules requiring, in certain instances, identification of the country of origin of various products, and limit the use of certain commercially advantageous labels, such as the “Made in the USA” label.

We represent clients in the distribution chain and aid them in complying with the network of laws that regulate the labeling of imports, including the Tariff Act of 1930, the American Automobile Labeling Act, the Buy American Act and California Proposition 64, which restricts the use of the “Made in the USA” label for products sold in the state of California.  We aid these clients in determining the country of origin of their products, fashioning appropriate labeling and complying with relevant law.

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Our services include:

  • Consultation concerning the applicability of country of origin and customs regulations to a given product
  • Determination of a product’s country of origin for labeling purposes
  • Design and creation of appropriate labeling
  • Preparation and filing of Section 177 Requests with U.S. Customs for a country-of-origin advisory ruling or final determination
  • Consultation concerning a client’s ability to use a “Made in the USA” label for its products
  • Review and negotiation of distribution contracts to ensure compliance with distributor’s demands concerning labels on U.S.-made products
  • Negotiation with the FTC, U.S. Customs or other government agencies over alleged violations of law in an effort to avoid litigation
  • When unavoidable, litigation over country of origin or “Made in the USA” labeling