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.