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New Marking Rules for Goods Made in Hong Kong

On August 11th, CSMS 43633412 was issued offering guidance on the new marking rules for goods made in Hong Kong. This CSMS stated, “A transition period (45 days) will be granted for importers to implement marking consistent with this position for imported goods produced in Hong Kong. Such goods, when entered or withdrawn from warehouse for consumption into the United States, after September 25, 2020 must be marked to indicate that their origin is “China” for purposes of 19 U.S.C. 1304.”

U.S. Customs and Border Protection (CBP) clarified the practical effects of this change in regards to the determination of origin for the administration of Section 301 duties. Goods made in Hong Kong should be physically marked “Made in China” but the customs documents should show Hong Kong as the country of origin for the purposes of application of duty.

This action was scheduled to take effect fifteen days after the order, which was July 29th, 2020, but has been moved to September 25th. Please be sure to review your country of origin marking on the physical products and internal databases prior to the effective date.

CBP has published a Frequently Asked Questions article on this topic.

We will continue to follow this story as the implementation nears.

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COVID-19 is a global challenge. Keeping our supply chains moving is important for maintaining the health and wellbeing of citizens and businesses. While the Canada - U.S. border is now closed to non-essential traffic, it is still open for trade and commerce. We are committed to doing our part for global supply chains.

We are protecting the health and safety of our employees. They are working from home, except for critical functions that require certain equipment or managing paper/courier flow. In those cases we are following social distancing guidelines.

We are open and available to assist you, and key players in your supply chains. Our dedicated staff are available 24/7 and our brokerage and logistics experts are available to help you make adjustments to your supply chain, if necessary.

We encourage you to check out the government programs available to families, businesses, exporters and importers. And, while respecting the need for social distancing we encourage everyone, including our staff, to reach out and remain connected to family, friends, colleagues and customers.

Stay safe.

Peter Willson
Chairman & CEO
Willson International

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