Do I need to label with country of origin
We are a UK SME. One of our activities is the sale of filter tips for roll your own cigarettes. We have our own brand and these are made and packaged for us by a company in Indonesia. We import these products for sale in the UK and also for export to the EU and worldwide, specifically Israel and USA. Currently the products are labelled ‘Made in Indonesia’. Our client wants us to remove this labelling.
Any advice or guidance on whether we can/ can’t, should/ shouldn’t do this would be much appreciated.
Hope some-one else can but a bit more into this for you, but I hope this helps…
In general, the country of origin for any goods is the country in which it was manufactured, produced or grown. If further work or material is added to the goods by another country, then , in order to to change its country of origin it must substantial transform the goods. "Substantial transformation" is production that results in a new and different goods, which then has a name, character, use, and tariff code different from those of its constituent materials. Take a razor blade made in country 1, sent to country 2 where they re-package five blades into one packet and re-package that with the Razor itself…it is my understanding, that this would meet the criteria to "change" the country of origin.
What you MIGHT be able to do (I really dont know if this is allowed), is to remove the label as long as you were not trying to claim the item was made else where (ie you would have no country declaration shown…this would probably be OK for Israel..although they could not ask you for and you could not provide an EUR1 which is what I suspect they want.) I assume the "made in Indonesia" is not an issue for the USA…(or at least it shouldnt be).
Hope this helps a bit.