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On Tuesday, August 11, 2020, U.S. Customs and Border Protection (CBP) announced in Federal Register Notice 85 No. 155 FR 48551 that, “in light of the President’s Executive Order on Hong Kong Normalization issued on July 14, 2020, suspending the application of section 201(a) of the United States-Hong Kong Policy Act of 1992 to the marking statute, section 304 of the Tariff Act of 1930, with respect to imported goods produced in Hong Kong, such goods may no longer be marked to indicate ‘Hong Kong’ as their origin, but must be marked to indicate ‘China.’”

CBP has now issued a Frequently Asked Questions (FAQ) – Guidance on Marking of Goods of Hong Kong – Executive Order (EO) 13936. In this FAQ, CBP notes that:

  1. FR 48551 “affects marking requirements not country of origin.”
  2. The EO “does not affect country of origin determinations for purposes of assessing ordinary duties under Chapter 1-97 of the HTSUS or temporary or additional duties under Chapter 99 of the HTSUS. Therefore, goods that are products of Hong Kong should continue to report International Organization for Standardization (ISO) country code ‘HK’ as the country of origin when required.”
  3. This rule only applies to marking requirements under 19 U.S.C. 1304.

For importers, this means that all products and carton markings for goods from Hong Kong should be marked as “China,” but all documents should continue to indicate country of origin as “Hong Kong” if applicable.  As a result, entry summaries will continue to be filed with ISO code “HK” as the country of origin thus avoiding any Section 301 duties against China.

For more information, please contact your local Noatum Logistics USA representative.