CBP Issues Marking Guidance for Goods Produced in Hong Kong

Goods produced in Hong Kong will need to be marked as a product of China starting Sept. 25, CBP said in a notice. The marking changes are the result of the July 14 Executive Order that ended Hong Kong's special trade status.

CBP said “the position set forth in this document is applicable as of July 29, 2020,” but the agency is allowing for a 45-day transition period. “Given the commercial realities, affected parties may need a transition period to implement marking consistent with the position announced in this notice,” it said. “Therefore, this document notifies the public that, unless excepted from marking, goods produced in Hong Kong, which are entered or withdrawn from warehouse for consumption” into the U.S. after Sept. 25 “must be marked to indicate that their origin is 'China' for purposes of 19 U.S.C. 1304.”

The notice doesn't say how the changes affect tariff treatment of Hong Kong goods, but an administration official said last month (see 2007230069) that the EO doesn't “provide for new U.S. tariffs on goods from Hong Kong.” A CBP spokesman didn't respond to a request for comment on whether additional guidance related to the tariff treatment would be coming from the agency.