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October 2025, question 76

Valuation, Appraisement and Duty Assessment · Rules of origin and trade programs

Orange juice in bulk containers is imported into the United States from Morocco. The orange juice is produced as follows: Oranges classified under heading 0805 are imported from Spain into Morocco. Purified water from France is imported into Morocco. Calcium citrate, a preservative, is manufactured in Morocco. The juice from the oranges (25% by volume and 70% by value), water (74.75% by volume and 29.5% by value), and calcium citrate (0.25% by volume and 0.5% by value) are combined in Morocco and repackaged in bulk containers prior to being exported to the United States. Upon importation, the orange juice will be classified under subheading 2009.12.2500. Which of the following correctly states the originating country, special program indicator, and rate of duty for the described orange juice?

  1. Morocco; MA; Free
  2. Morocco; None; 4.5₵ per liter
  3. Spain; None; 4.5₵ per liter
  4. France; E; Free
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CBP's answer: C. C: Spain; None; 4.5₵ per liter

Adding a preservative, combining with water and repackaging are simple combining, packaging or dilution operations that do not make a new article (10.770(c), 10.195(a)(2)(i)(D), (E), (F)). The Moroccan juice therefore keeps the origin of the Spanish oranges that give it its essential character, so Morocco is not the origin, no MA preference applies and the general rate applies. The question gives subheading 2009.12.25, whose general rate is 4.5 cents per liter (C). CBP's citation of 2009.12.45 is a typo; the rate in the answer matches 2009.12.25.

The addition of substances such as anticaking agents, preservatives, wetting agents, etc. 19 CFR 10.195(a)(2)(i)
a good will not be considered a new or different article of commerce by virtue of having undergone simple combining or packaging operations, or mere dilution with water 19 CFR 10.770(c)
4.5¢/liter 2009.12.25

Search for: simple combining or packaging operations and mere dilution

CBP's key cites: HTSUS 2009.12.4500; 19 CFR 10.770(c); 19 CFR 10.195(a)(2)(i)(D); 19 CFR 10.195(a)(2)(i)(E); 19 CFR 10.195(a)(2)(i)(F); 19 CFR 134.1(b); General Note 27

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).