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October 2025, question 62

Entry / Entry Summary · Rules of origin and trade programs

When is country of origin based on an inventory management method?

  1. When the goods are non-fungible, consist of indirect materials, and have been disassembled.
  2. When the goods are non-fungible, have been commingled, and direct physical identification of the origin of the goods is not practical.
  3. When the goods are fungible, have been commingled, and direct physical identification of the origin of the goods is not practical.
  4. Anytime the goods are fungible, regardless of other attributes.
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CBP's answer: C. C: When the goods are fungible, have been commingled, and direct physical identification of the origin of the goods is not practical.

Section 102.12(b) allows country of origin to be determined by an inventory management method only if the good is fungible, has been commingled, and direct physical identification of the origin of the commingled good is not practical (C). Non-fungible goods or fungibility alone are not enough.

If the good is fungible, has been commingled, and direct physical identification of the origin of the commingled good is not practical 19 CFR 102.12(b)

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CBP's key cites: 19 CFR 102.12(b)

Question and key from CBP's October 2025 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).