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April 2024, question 49
Entry / Entry Summary · Country of origin marking
A liquid sauce is prepared in Japan by mixing raw materials from Japan, China, Thailand, and the United States. The raw materials from Japan are water, liquid sugar, salt, apple pulp, orange pulp, bonito extract, squid extract, citric acid, konbu, and paprika. The raw materials from China are garlic, fermented vegetables, chili pepper and ginger. The raw materials from the United States are soy protein hydrolysate and xanthum gum. The raw material from Thailand is s-inosinate. What is the country of origin marking on the bottles of sauce, all of which are to be shipped to the United States and sold in United States grocery stores?
- Product of China
- Product of Thailand
- Product of Japan
- Product of the USA
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CBP's answer: C. C: Product of Japan
The country of origin is the country of manufacture, production or growth, and further work in another country counts only if it substantially transforms the article. The sauce is made in Japan from many ingredients into a new product, so the origin to mark is Japan (C), not the countries that supplied some raw materials.
Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” 19 CFR 134.1(b)
Search for: substantial transformation country of origin
CBP's key cites: 19 CFR 134.1(b)
Question and key from CBP's April 2024 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).