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

 

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 it

  • And that a sticker is fine, even if the item itself isn’t marked

But 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 consumer

There are exceptions, and here’s what the regulation allows:

  • Items that can’t be marked without damaging them

  • Items 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 all

  • Isn’t realistically markable (like tiny parts)

  • Or sits in a gray area where it’s unclear if direct marking is expected

But 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.


 

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Re: Country of Origin marking - what are the exceptions when it is not required

However, I am not clear about this point here F:

https://www.ecfr.gov/current/title-19/chapter-I/part-134/subpart-D/section-134.32

 

Articles imported for use by the importer and not intended for sale in their imported or any other form;

 

Wouldn't this in thery apply to any vintage item for personal use (not intended for the re-sale), whether it's clothing or household item that shows reasonable signs of use? 


So here is where I asked GPT and but this needs to be verified as there is literraly no informaiton online...

itolduandso_0-1747701054585.png

So this may be the reason shipping the item with Canada Post imprives the chance of getting the package treated as a personal-use item under the "radar"....

 

So used items in particular, without COO marking, if the item doesn't look expensive, and it's not expsnsive, ship by Canada Post. It's not advice but it's logical I guess based on the information above. 

 

How is this being overriden with the tariffs when it comes to COO? How is it that Trump's tariffs now bluntly assume... if it doesn't have COO label on it, it's considered as China item and will get tariff on it. Based on the § 134.32 which seems is still valid, the item should not require COO on it, and that means I could send it as a personal item and should be able to put any sticker on it. So how does it come the poing F doesn't apply in reality? Just curious?

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Re: Country of Origin marking - what are the exceptions when it is not required

I'm confused about the article marking thing. I sell coins and stamps, which are marked in some way (permanently) by nature of what they are. Not all tokens are marked with a COO, some we just guess are Canadian because we got them in Canada from local collectors.

 

So far none of my items have been rejected by Stallion or CBP. But there's always a first time. We make jewellery and handbags as well, and the cards have "made in Canada" stamped on them, and our bags have tags inside, and other jewellery has tags affixed. So I guess I did the right thing to ship to the US with CBP's new rules on COO regarding stuff we made ourselves.

 

C.

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Re: Country of Origin marking - what are the exceptions when it is not required

"Items that can’t be marked without damaging them"

 

Thats what applies to your stamps.

 

However, if you have shipped by Stallion, they still ask you to put that stamp into a bag and put a Made in XX sticjer label on the bag.

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Re: Country of Origin marking - what are the exceptions when it is not required


@itolduandso wrote:

"Items that can’t be marked without damaging them"

 

Thats what applies to your stamps.

 

However, if you have shipped by Stallion, they still ask you to put that stamp into a bag and put a Made in XX sticjer label on the bag.


I went to your link on Stallion. I didn't see it before because it looks like it was put up 3 days ago and I've been away for a bit.

 

Generally speaking my merchandise all goes into bags, so I can have a sticker put on, but the question is does it need to be a computer printed sticker or can we hand write on it?

 

Some stamps are actually marked with the country (well most are, but sometimes not in English, other times the issue doesn't have a marking, like Britain stamps). It's kind of the same as coins, but I found a coin in inventory that says "Tuvalu" on it and it's inside a "China Mint" type of box that says China on it. So I think that's a no go for shipping to the US.

 

Thanks for sharing this link. There are so many changes and very quickly that I can't keep up.

 

C.

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Re: Country of Origin marking - what are the exceptions when it is not required

"China" no good to ship.

My undersanding it's not needed to have printed, but it needs to be legible so that it's not missed by either Stallion or CBP checking packages, otherwise it may add delay if they put aside for inspection, that's my understanding.

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