Changing Country of Origin (COO) to reduce Tariffs
- Know the basics Team
- May 11
- 1 min read
Following several posts, seen lately on LinkedIn and other platforms about changing country of origin #COO to circumvent U.S. tariffs on Chinese-manufactured goods, let's bring some clarity! 📌 What you CANNOT do alone to legally change COO for FMCG products:
Repackaging bulk goods into retail containers
Relabeling or adding “Made in” stickers in another country
Adding local language instructions or branding materials
Applying barcodes, logos, or marketing inserts
Simple dilution with water, oil, or fillers
Minor assembly that doesn’t alter core function
Reboxing finished products into gift sets or bundles
Sewing on labels or trim without altering the product
Folding, ironing, or bagging garments
Switching toys into new boxes or kits
Attaching accessories or translated manuals
Conducting basic testing or hygiene prep 🛑 These actions do not qualify as “substantial transformation” under U.S. Customs (CBP), EU, or WTO trade rules. Missteps can result in seizures, fines, or fraud investigations. ✔️ If you want to restructure COO legally, you need clear proof of substantial transformation with a genuine modification that alters the product’s function, composition, or essential use. #ImportExport #TradeCompliance #Tariffs #SupplyChain #AmazonSeller #Logistics
Visual showing illegal methods related to change of country of origin for FMCG products, including repackaging and relabeling. Warning about compliance risks under US, EU, and WTO rules.
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