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Changing Country of Origin (COO) to reduce Tariffs

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.
    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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