Country-of-Origin Rules:

• A practical understanding of procurement waivers
• Buy America requirements in government subsidies (IRA and CHIPS)
• Content versus origin: Which one applies?
• Common compliance concerns: Changing suppliers, not knowing which program applies, training procurement staff
• Types of origin rules, non-preferential and preferential rules
  • Applying the appropriate rules of origin for different tariff determinations
  • Where Substantial Transformation Occurs or Simple Assembly
  • Textile and apparel rules
  • Applying special tariffs: Tariff shifting
  • Biding ruling requirements
  • Free Trade Agreements (e.g., USMCA) rules
• Ensuring compliance with country-specific labeling and marking requirements to avoid penalties and facilitate smooth customs clearance
• How to eliminate duties through origin changes (IEEPA, 232, 301, etc.)
• Working with your supplier to get the origin information you need
• Responding to CBP enforcement
• CF 28s and origin verifications
  • Documents and analysis needed to support origin claims
  • Penalty Risks and Mitigation
  • CBP rulings, legal opinions, and recent court cases