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Rules of origin

Substantial transformation, Part 102 origin rules, textile origin.

Common traps

Wrong answers on past exams cluster around a few beliefs. Here is each one, and what the rule actually says.

Textile origin

“The seed, fiber, or fabric country is the origin of a garment.”

The rule: Textile origin follows 19 CFR 102.21; for these garments origin is where the good is wholly assembled.

Remember: Garments: where assembled (not where the fiber came from).

19 CFR 102.21

Building a manufacturer identification code (MID)

“Use the shipper's or seller's name, the postal code or P.O. box, or any city or country code.”

The rule: The MID is the ISO country code, the first three letters of the first two words of the manufacturer's name (skipping a, an, and, of, the and single initials; a hyphenated name counts as one word), up to four digits of the largest number in the street address, and the first three letters of the city (19 CFR part 102, Appendix).

Remember: Country + name + street number + city.

19 CFR part 102, Appendix

Definition of a textile or apparel product

“Only Ch. 50-63 goods are textile products.”

The rule: For origin purposes a 'textile or apparel product' is any good of Ch. 50-63 plus listed provisions, including 9113.90.40 (textile watch straps), 9404.90, 9612.10.9010 and 9619.00.21-.79 (19 CFR 102.21(b)(5)).

Remember: Ch. 50-63 + the listed extras.

19 CFR 102.21(b)(5)

'Wholly obtained or produced'

“Assembled goods or goods taken from outer space are not wholly obtained.”

The rule: Wholly obtained goods include minerals extracted, plants harvested, and goods taken from outer space by that country's persons; goods assembled from imported parts are not.

Remember: Any foreign input = not wholly obtained.

19 CFR 102.1(g)

Inventory management for origin

“Inventory methods apply to non-fungible goods or to all fungible goods.”

The rule: Inventory management methods may determine origin only if goods are fungible, commingled, and direct identification is not practical.

Remember: Fungible + commingled + impractical.

19 CFR 102.12(b)

Domestic vs. other material definitions

“Domestic material means indirect, fungible, or natural material.”

The rule: 'Domestic material' is a material whose origin is the same country where the good is produced.

Remember: Same country as the good.

19 CFR 102.1(d)

Try a past question

October 2026 CBLE, question 43

Natty Knickers, Inc. (NK Inc.) submitted a purchase order to a trouser manufacturer for 100 dozen women's woven cotton pajama pants. The manufacturer purchases cotton yarn, grown and spun in Brazil. The yarn is shipped to Turkey where it is woven into fabric and tie-dyed. The tie-dye fabric goes to Vietnam where it is cut and sewn into pajama pants. The pajama pants are then sent to Mexico, where they are washed, packaged, and labeled. NK Inc. imports the pajama pants into the U.S. What is the country of origin of the pajama pants?

ABrazil
BMexico
CTurkey
DVietnam
Show the answer and why

A. Incorrect. Yarn origin does not determine garment origin.

B. Incorrect. Washing, packaging and labeling are minor operations.

C. Incorrect. Weaving and dyeing fabric do not determine origin of the garment.

D. Correct. The pants were cut and sewn (wholly assembled) in Vietnam, which is the origin under the textile rules (19 CFR 102.21(c)(3)).

19 CFR 102.21(c)(3) · law as of 2026-11-09

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