Entry / Entry Summary · CBLE study guide
Country-of-origin marking
Marking requirements, exceptions, containers, marking duties.
- 50past questions in CBLE Pass
- ≈2questions on a typical 80-question exam
- 19 CFR Part 134where the rules live
Common traps
Wrong answers on past exams cluster around a few beliefs. Here is each one, and what the rule actually says.
Sanction for missing origin marking
“Unmarked goods draw criminal penalties, 25% duty, or a value penalty.”
The rule: Articles not properly marked are subject to an additional duty of 10% of the final appraised value unless exported or destroyed under CBP supervision before liquidation.
Remember: 10% marking duty.
19 CFR 134.2
Origin follows substantial transformation
“Origin is where the most ingredients, or the U.S. ingredients, came from.”
The rule: The country of origin is where the article was manufactured, or where the last substantial transformation occurred (non-USMCA goods).
Remember: Where was the new article made?
19 CFR 134.1(b)
Notice to mark and liquidated damages
“There are 60 days, and LDs are double duties or 10%.”
The rule: On CBP Form 4647 the importer has 30 days (or an allowed extension) to mark, export or destroy. Otherwise LDs equal the entered value of the unmarked articles (134.51; 134.54(a)). The 10% marking duty (134.2) is separate.
Remember: 4647 → 30 days → entered-value LDs.
19 CFR 134.51 · 19 CFR 134.54(a) · 19 CFR 134.2
The J-list
“Any raw or semi-processed good is on the J-list.”
The rule: 134.33 lists specific articles excepted from marking (e.g., steel bands, briarwood in blocks, staples, rawhides); cotton fabric is not on the list.
Remember: Check the list itself.
19 CFR 134.33
General marking exceptions
“Old goods (15 years) are excepted, or personal-use goods aren't.”
The rule: 134.32 exceptions include goods produced more than 20 years before import, goods that can't be marked without injury, goods whose container marking suffices, goods for the importer's own use, and certain NAFTA/USMCA goods.
Remember: 20 years, not 15.
19 CFR 134.32
Marking standard
“Marking may be temporary or brief.”
The rule: Country of origin marking must be legible, indelible, and permanent.
Remember: Legible, indelible, permanent.
19 CFR 134.41(a)
Try a past question
October 2026 CBLE, question 41
Which of the following does NOT qualify for an exception to the country-of-origin marking requirements?
Show the answer and why
A. Not the answer. U.S. products exported and returned are excepted (134.32(m)).
B. Not the answer. Articles produced more than 20 years before import are excepted (134.32(i)).
C. Not the answer. Articles for the importer's own use are excepted (134.32(f)).
D. Correct (NOT an exception). When a U.S. location appears as part of a souvenir marking, the article must be marked with its country of origin in close proximity or another conspicuous place (19 CFR 134.47).
19 CFR 134.32 · 19 CFR 134.47 · law as of 2026-11-09
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