What are the Requirements for Labels of Origin on Non-Food Items?

August 6, 2007

Is there a requirement for non-food items (specifically steel uniform lockers) made in China to have a label of origin? Does it have to be displayed on the item, or only on the packaging? How prominently?



In answer to your first question, the Tariff Act of 1930 requires that "every article of foreign origin . . . imported into the United States shall be marked in a conspicuous place . . . to indicate to an ultimate purchaser in the United States the English name of the country of origin of the article." In response to where and how the country of origin must be displayed, generally, it is not necessary to provide country of origin information on an article if the packaging of the article itself clearly provides this information, and this packaging actually reaches the ultimate consumer. The Customs Regulations, 19 CFR Part 134.32, clearly provide a country of origin marking exception for "articles for which the marking of the containers will reasonably indicate the origin of the article." However, while Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), only requires that the country of origin be legible, indelible, and permanent, as a general rule, the Customs Service (now the Bureau of Customs & Border Protection) recommends that marking requirements are best met by markings worked into an article at the time of manufacturer. For example, it suggests that the country of origin on metal articles be die sunk, molded in or etched.