Country of Origin Marking: "Made in" Rules for the US, EU and Asia

Origin marking, certificates of origin and which origin rule applies

Origin marking is the statement of the country of origin, such as "Made in Vietnam", printed, moulded, sewn or labelled on the goods or their packaging. It tells buyers and customs where the goods were made. A certificate of origin is a separate document that travels with the shipment. Customs may ask for either, and having one never replaces the other.

Most countries decide the origin to mark with their non-preferential rules of origin, the rules also used for most-favoured-nation duty, anti-dumping duties and trade statistics; the WTO lists labelling and marking among their uses. Preferential rules in free trade agreements decide only whether goods get a lower duty, and are claimed with a certificate or declaration of origin. The two can give different answers for the same product, so check marking origin separately from FTA origin.

When more than one country is involved, origin is usually the country where the goods were last substantially transformed. The US asks whether processing made a new article with a different name, character or use (19 CFR 134.35); the EU asks where the last substantial, economically justified processing took place (Union Customs Code, Article 60(2)); Japan asks where a substantial change took place. Labelling, packing or repacking and simple assembly normally do not change origin.

United States: mark every article and its container

19 U.S.C. 1304 and 19 CFR Part 134 require every article of foreign origin, or its container, to be marked "in a conspicuous place as legibly, indelibly, and permanently as the nature of the article... will permit" with the English name of the country of origin. The mark is for the ultimate purchaser: usually the last person in the US who receives the article in its imported form. A US manufacturer that substantially transforms an imported part is the ultimate purchaser of that part, so the part itself need not be marked, though its outermost container must be (19 CFR 134.35).

The mark must stay on until the goods reach the ultimate purchaser unless someone deliberately removes it, and the purchaser must be able to find it easily and read it without strain (19 CFR 134.41). Use the full English country name; abbreviations and variant spellings are accepted only when they unmistakably show the country, such as "Gt. Britain" or "Brasil" (19 CFR 134.45).

• Other place names: if "USA", "American", a US city or a foreign place other than the origin appears and could mislead, add the origin close to it in at least comparable size, preceded by "Made in", "Product of" or similar words (19 CFR 134.46). A US importer's or distributor's address on a container needs a nearby mark such as "Contents made in France" (19 CFR 134.22(c)).
• Exceptions: some articles need no mark on the article itself, such as articles that cannot be marked, crude substances or goods for the importer's own use (19 CFR 134.32), and the J-list, which includes items such as buttons, rope, wire, sawn lumber and natural products (19 CFR 134.33). The outermost container in which they normally reach the ultimate purchaser must still be marked.
• Assembly: an article whose origin is the country of final assembly may be marked "Assembled in [country]", optionally adding "from components of [countries]" (19 CFR 134.43).
• Unmarked goods: CBP notifies the importer on CBP Form 4647 to mark the goods, or to return released goods for marking, export or destruction under CBP supervision. If released goods are not marked or redelivered within 30 days of the notice, CBP demands liquidated damages equal to their entered value (19 CFR 134.54).
• Extra duty: goods not marked, exported or destroyed before the entry is liquidated pay an additional 10% ad valorem duty, which cannot be remitted (19 U.S.C. 1304(i)).
• Removing or covering a required mark to conceal the origin is a crime, punishable by a fine of up to USD 100,000 for a first offence and USD 250,000 for later ones, up to one year in prison, or both (19 U.S.C. 1304).

US special cases: Hong Kong, Canada and Mexico

Goods produced in Hong Kong must be marked "China", not "Hong Kong", when entered for consumption in the US after 9 November 2020. CBP says the change does not affect origin for duty, so Hong Kong remains the origin for ordinary duties and for the additional duties in Chapter 99 of the tariff. A WTO panel found the requirement inconsistent with WTO rules in December 2022; the US appealed in January 2023, the appeal is stalled because the Appellate Body is not functioning, and Hong Kong's government reports that the requirement is still in force.

For goods of Canada and Mexico, the origin to mark is decided by the rules in 19 CFR Part 102, which are based mainly on changes in tariff classification, rather than by the substantial transformation test. These goods may be marked with the country name in English, French or Spanish, a few have their own exceptions from marking, and a USMCA container that is the usual container for its contents needs no mark of its own.

European Union and United Kingdom: voluntary for most goods, required for some foods

The EU has no general rule requiring a "Made in" mark on non-food goods. EU textile labelling, for example, covers fibre composition only (Regulation (EU) No 1007/2011), and an origin labelling scheme was left for later study. If you do mark origin, it must be true: the Unfair Commercial Practices Directive treats false or deceptive information about a product's "geographical or commercial origin" as a misleading action (Directive 2005/29/EC, Article 6(1)(b)).

Food is different. Under Regulation (EU) No 1169/2011, origin must be shown where leaving it out could mislead consumers, for example when the name, pictures or flags on the pack suggest another country, and specific rules require it for beef, unprocessed pig, sheep, goat and poultry meat, fishery products, fresh fruit and vegetables, honey, olive oil and eggs. Food origin follows the EU customs origin rules. From 14 June 2026, honey blends must list each country of harvest, in descending order with its percentage, in the principal field of vision (Directive (EU) 2024/1438).

The UK follows the same pattern. There is no general marking rule for non-food goods; since 6 April 2025 misleading claims about a product's origin fall under the unfair commercial practices rules of the Digital Markets, Competition and Consumers Act 2024; and food law requires origin for meat, fish and seafood and wherever its absence could mislead.

China, South Korea, Japan, India and Saudi Arabia

Outside the US and the EU the rules vary by product, so confirm the current rule with your importer for each item. The main points:

• China: where goods or their packaging carry an origin mark, it must match the origin determined under the Regulations on the Origin of Import and Export Goods (Article 16), and customs orders a correction if it does not (Article 24). Imported prepackaged food needs a Chinese label showing the country or region of origin (GB 7718); GB 7718-2025, which applies from 16 March 2027, keeps this requirement.
• South Korea: origin marking is required for commercial shipments of goods designated under the Foreign Trade Act (Article 33), and Korea Customs Service lists the requirements by HS code. Korean-language labels may be added in the bonded area, but the origin mark must be shown at customs clearance. It may be in Korean, Chinese characters or English, must be easy to find and read, and is applied by printing, stamping, casting, etching, sewing or similar methods. Accepted wording includes "원산지: [country]", "Made in [country]" and "Product of [country]"; abbreviated wording such as "COO: [country]" is not accepted. False or misleading marking can bring up to five years in prison or a fine of up to KRW 100 million.
• Japan: origin marking is not generally required at import, but goods with a false or misleading origin indication, on the goods or on their packaging, cannot be imported (Customs Act, Article 71). A foreign country name, flag or place name that suggests another origin can count. Customs tells the importer to remove or correct it permanently, not just for clearance, or to re-export the goods. Imported processed food must show its country of origin under the Food Labelling Standards.
• India: every retail package of an imported product must state the country of origin, manufacture or assembly, together with the importer's name and address (Legal Metrology (Packaged Commodities) Rules, 2011, Rule 6, as amended from 1 January 2018).
• Saudi Arabia: the Swiss export agency S-GE (March 2026) says imported products must carry a country of origin mark that cannot be removed, applied by engraving, sewing, printing or pressing. Saudi customs procedure rules ask for a certificate of origin for goods that cannot easily carry an origin indication, and SASO technical regulations set label content; the footwear regulation, for example, requires the country of origin in Arabic, or Arabic and English.

How to word and place the mark: product, retail pack and carton

"Made in [full English country name]" or "Product of [country]" works for most destinations: it meets the US rule, matches wording Korea accepts and is clear to buyers everywhere. Avoid ISO codes, flags on their own and regional names: the US requires the name of a country, so "EU" or "Made in Europe" is not enough. Add local-language versions where the destination or importer asks for them.

Mark the article itself where possible, by moulding, printing, stamping, weaving or a sewn-in label; CBP's marking guidance warns that adhesive labels can come loose. Also mark the retail package when it hides the article, and the outermost container for articles excepted from marking. In the US a container need not be marked when the goods inside are marked and it can readily be opened for inspection, but many buyers want "Made in [country]" in the carton shipping marks too; Triplicate's shipping marks and carton label tools can print it.

Keep the origin the same everywhere: on the goods, the commercial invoice and packing list, any certificate of origin and the customs declaration. Where the marking origin and the duty origin differ, as for Hong Kong goods sent to the US, show each correctly and tell the importer's broker in advance.