Proving Providence:
Country of Origin in Cross-Border Trade

Country of origin (CoO), along with description and classification, has always been the main driver of the duty rate of cross-border shipments. The recent changes in trade regulations have seen an increasing focus on completeness and accuracy of the country of origin. In 2026 the US applies different Section 301 rates by origin country, keeps anti-dumping and countervailing duties that can exceed 200% of value, and has removed duty-free de minimis treatment for low-value parcels. The EU ended its €150 customs duty exemption on 1 July 2026 and lists origin among the data it expects on each low-value item.

Origin is also where enforcement is concentrated. US prosecutors are using the False Claims Act against importers who routed Chinese goods through third countries: Ceratizit USA settled for $54.4 million in December 2025, and Everlight Electronics for $5.15 million in August 2026. CBP’s evasion investigations now find against importers who cooperated in full, because a wrong origin declaration is a material false statement whatever the intent behind it.

The legal tests have barely moved: origin goes to the country where goods were wholly obtained, or to the last country that carried out a substantial transformation. The cost of a wrong answer has increased, as has the technology used to identify non-compliance and the audit teams associated with vetting transactions.