Country of Origin marking - what are the exceptions when it is not required | Selling

itolduandso · 2025-05-20T00:15:53.720000Z

Stallion Express asks shippers to put white stickers on the items shipped. https://help.stallionexpress.ca/portal/en/kb/articles/us-shipping-guide I did some digging and realized that slapping a country of origin (COO) sticker onto a product isn’t always acceptable — it really depends on the item type. I couldn’t fully tell what the second item in Stallion’s example was (the one in the white sleeve or pouch), so maybe it’s a low-value item that normally wouldn’t require a COO mark? Not sure.What triggered my concern is that U.S. Customs and Border Protection (CBP), under 19 CFR Part 134, actually mandates that items must have the country of origin marked directly on them — and not with something temporary like a sticker. The rule is clear: if the product can be permanently marked, it must be. That means the COO needs to be applied in a way that’s visible, legible, and not easily removed.When I looked at the example photos Stallion provides, it gave me the impression that:Every product just needs a sticker slapped on itAnd that a sticker is fine, even if the item itself isn’t markedBut based on the actual regulation, that’s not accurate.To be compliant, the COO should be:On the item itself (not just the box or sleeve)Non-removable or permanent, especially if it's going to a consumerThere are exceptions, and here’s what the regulation allows:Items that can’t be marked without damaging themItems that would be too expensive to mark individually (relative to their value)https://www.ecfr.gov/current/title-19/chapter-I/part-134/subpart-D/section-134.33 https://www.ecfr.gov/current/title-19/chapter-I/part-134/subpart-D/section-134.32 So in plain terms, CBP is okay with stickers or container-based markings only for things like:Very small or soft items (screws, washers, rubber bits)Fragile goods (glass beads, feathers, etc.)Unique or delicate things (antiques, handmade items, etc.)That likely explains why the screws in the example don’t have the country marked directly — they probably qualify as an exception.That said, it still raises the question: what exactly qualifies as an “antique”?According to customs duty rules, anything 100 years old or older can be classified as an antique under the Harmonized Tariff Schedule (HTSUS), which CBP also references. That might earn it more lenient treatment. But the issue is — how do you prove the item is over 100 years old?Now, if you’re shipping something clearly vintage or antique-looking, even if it’s not 100+ years old, and it’s either too delicate or too small to reasonably mark, or it’s low in commercial value, CBP might still allow a container label instead of direct marking — but that’s discretionary.So back to Stallion — why are they requiring these white COO stickers?It looks like it ties into this part of the CBP rule:19 CFR §134.32(d):“Articles for which the marking of the containers will reasonably indicate the origin of the articles.”This basically means if the item itself can't (or realistically shouldn't) be marked, you can mark the packaging — as long as the buyer sees it before using the item.So Stallion is probably using these white stickers on the outer package to comply with that rule — especially when the product inside:Has no origin marking at allIsn’t realistically markable (like tiny parts)Or sits in a gray area where it’s unclear if direct marking is expectedBut here’s the catch: even with the sticker on the packaging, CBP can still reject the shipment if they feel the item should’ve been marked directly — like for retail items where the box could be tossed before the buyer sees it.Ultimately, whether a sticker on the packaging counts as sufficient depends on whether CBP thinks it “reasonably indicates origin”. That’s up to the officer inspecting it.

Discussions

Country of Origin marking - what are the exceptions when it is not required | Selling | eBay Canada EN