Guide
What are the country of origin marking requirements for imported metal parts?
Country of origin marking is the legal requirement that an article of foreign origin, or in some cases its container, show the English name of the country where it was made, so that the last person in the United States who receives it in its imported form knows where it came from. For metal parts, the rules sit in section 304 of the Tariff Act of 1930 and in part 134 of title 19 of the Code of Federal Regulations.
By Saola Manufacturing engineering team · Published · Updated
This guide explains who has to see the mark, which parts are excepted, which methods the law prescribes for certain metal articles, and how to put the requirement on a drawing. It summarizes public regulations and is not legal advice. For a binding answer on a specific part, the route is a ruling request to U.S. Customs and Border Protection (CBP) under 19 CFR part 177.
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Which law requires country of origin marking on imported metal parts?
Section 304 of the Tariff Act of 1930, codified at 19 USC 1304, requires every article of foreign origin to carry the English name of its country of origin, marked “in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit”. CBP implements that statute in 19 CFR part 134, which applies to a machined bracket or a die-cast housing exactly as it does to a consumer product.
In part 134, Subpart A holds the definitions, Subpart C covers containers, Subpart D lists the exceptions (including the J-list of §134.33), Subpart E covers the method and location of the mark, and Subpart F covers shipments found not legally marked (eCFR, 19 CFR part 134).
Two definitions do most of the work. The country of origin is the country of manufacture, production or growth, and work done in a second country only changes the origin if it effects a substantial transformation (19 CFR 134.1). In the regulation’s words, “conspicuous” means “capable of being easily seen with normal handling of the article or container.” For goods of Canada or Mexico, the USMCA marking rules of 19 CFR part 102 decide origin instead; this guide deals with parts made elsewhere, such as in Vietnam.
The same origin concept drives duty rates, which the tariffs and country of origin page covers; a correctly declared part can still be held because the mark is missing.
Who is the ultimate purchaser for an OEM component?
Under 19 CFR 134.1(d), the ultimate purchaser is generally “the last person in the United States who will receive the article in the form in which it was imported.” When an OEM turns an imported part into a different article with a new name, character or use, the OEM itself is the ultimate purchaser, and the part may be excepted from individual marking.
This is the most important point for component buyers. Under 19 CFR 134.35, which follows the court decision in United States v. Gibson-Thomsen Co., a U.S. manufacturer that converts or combines an imported article into a different article is the ultimate purchaser of that article, and the article is excepted from marking. The exception has a condition that is easy to miss: the outermost containers of the imported parts must still be marked with the country of origin.
The exception depends on what happens to the part after it lands:
- Built into a new product. A die-cast gearbox housing that becomes part of a finished pump is typically treated under the substantial-change principle, so the carton needs the mark and the housing may not.
- Minor processing only. If the U.S. step is minor and leaves the part’s identity intact, such as deburring or repackaging, 19 CFR 134.1(d)(2) makes the later user the ultimate purchaser, so the part itself needs the mark.
- Sold as a spare. The same housing sold through a service channel as a replacement part reaches an end customer in its imported form, so it needs the mark on the part.
Because one part number often serves both production and spares, many buyers simply mark every piece.
Which metal parts are excepted from marking, and what still has to be marked?
Some metal articles are excepted from individual marking, either under the general exceptions of 19 CFR 134.32 or because they appear on the J-list in 19 CFR 134.33. In almost every case the exception moves the mark to the container rather than removing it.
The general exceptions, such as articles that cannot be marked without injury or except at a prohibitive expense, are decided by CBP case by case. The J-list instead names classes of goods, several of them metal.
| J-list entry | What it means for a parts buyer |
|---|---|
| Bolts, nuts, and washers; screws; rivets | Standard fasteners need no mark on each piece; the box or carton does. |
| Nails, spikes, and staples | Same container rule. |
| Metal bars (except concrete reinforcement bars); billets, blocks, blooms; ingots; pigs; plates; sheets (except galvanized sheets); shafting; slabs; and metal in similar forms | Covers stock and semi-finished forms, not a machined or cast part made from them. |
| Blanks, metal, to be plated | Unfinished blanks only; the finished, plated article is a different case. |
| Bearings, ball, 5/8-inch or less in diameter | Small balls only, not bearing assemblies. |
| Buckles, 1 inch or less in greatest dimension | Size-limited entry. |
| Wire, except barbed; rope, including wire rope; bands, steel; steel, hoop | Wire and strip products. |
| Parts for machines imported from same country as parts | Read narrowly; confirm with a ruling before relying on it. |
Two cautions apply. First, the J-list describes classes of goods, and a custom part that happens to contain a thread is not automatically a “bolt” or a “screw”; a turned fitting or a machined shaft with features is its own article. Second, 19 USC 1304(c)–(e) removes the exceptions entirely for the pipe, fitting, gas cylinder and casting articles listed in the next section. When a part sits near the edge of an entry, the importer can ask CBP for a binding ruling through the eRulings program and search earlier decisions in the CROSS rulings database.
Which marking methods does CBP accept on metal parts?
For most metal parts any method is acceptable if the mark is conspicuous, legible and permanent enough to reach the ultimate purchaser, and 19 CFR 134.41 suggests that metal articles “be die sunk, molded in or etched.” A short list of metal goods must be marked by specific methods named in the statute or regulation, and for the pipe, fitting, gas cylinder and casting articles in 19 USC 1304(c)–(e) the statute also rules out the usual exceptions under 1304(a)(3).
| Article | Required or suggested method | Where it is written |
|---|---|---|
| Metal parts in general | Any method that is conspicuous, legible and permanent until the ultimate purchaser receives it; “die sunk, molded in or etched” suggested; labels and tags allowed if securely attached | 19 CFR 134.41, 134.44 |
| Pipe of iron, steel or stainless steel; pipe fittings of steel, stainless, chrome-moly steel, or cast and malleable iron | Die stamping, cast-in-mold lettering, etching, engraving or continuous paint stenciling; an equally permanent method, or tagging containers or bundles for small-diameter items, only where those are technically or commercially infeasible | 19 USC 1304(c) |
| Compressed gas cylinders | Die stamping, molding, etching, raised lettering or an equally permanent method | 19 USC 1304(d) |
| Manhole rings, frames and covers, inlet frames, grates, hydrants, utility boxes, bollards, lampposts and bases, cast utility poles | Die stamping, cast-in-mold lettering, etching, engraving or an equally permanent method, on the top surface, visible after installation | 19 USC 1304(e) |
| Knives, scissors, pliers, pincers, surgical, dental, scientific and laboratory instruments, vacuum containers, and parts of these | Die stamping, cast-in-the-mold lettering, etching (acid or electrolytic), engraving, or a metal plate attached by welding, screws or rivets | 19 CFR 134.43(a) |
| Articles whose origin is the country of final assembly | Wording such as “Assembled in” the country of assembly, optionally naming the origin of the components | 19 CFR 134.43(e) |
Two details in the table matter for OEM buyers. The fitting provision names steel, stainless, chrome-moly and cast or malleable iron fittings; brass and bronze fittings are not in that list, so they fall under the general rule, though a permanent mark is still the safe choice. And the instrument provision covers “parts of the above articles”, so a machined component for a dental or laboratory instrument can fall under the prescribed methods even when it is sold as a part.
From a process point of view, the four practical options for a metal part are:
- Cast-in lettering. Raised or recessed text cut into the die of a die-cast part. It adds no per-part step, but it has to be decided before the die is cut, kept off machined faces and parting lines, and placed where ejector pins and gates are not.
- Die stamping. Text pressed in during a stamping operation. It is permanent but needs a flat area.
- Engraving or etching after machining. Engraved, dot-peened, laser-etched or chemically etched text on a machined face.
- Labels and tags. Acceptable under 19 CFR 134.44 if they stay attached until the ultimate purchaser receives the article, which is hard on a part that is later washed or coated.
Surface finish affects each option. A thick coating can fill shallow engraving, and masking a marked area changes the appearance of the part, so the mark and the finish should be specified together. The finish comparison guide covers how each coating behaves.
How should the marking requirement be written on the drawing?
Put the marking on the drawing as a controlled feature: the exact text, the method, the location in a view, and whether it must remain visible after assembly and finishing. A general note such as “mark country of origin” leaves every one of those decisions to the supplier.
A complete note covers five things:
- Text. For example “MADE IN VIETNAM” or “VIETNAM”. The law needs only the country name; “Made in” becomes mandatory when other place names appear, as explained below.
- Method. Cast-in raised, cast-in recessed, stamped, engraved or etched. For the articles in the table above, choose one of the methods the provision names.
- Location. A view or a flag on a specific face, clear of sealing, datum and machined surfaces.
- Size and legibility. A character height and depth or height of relief agreed with the supplier for the process, since the regulation asks only that the ultimate purchaser can read it without strain.
- Finish interaction. Whether the mark is masked, coated over, or applied after coating.
Watch for other names on the part. Under 19 CFR 134.46, if the article carries “USA”, the name of a U.S. city, or the name of a country other than the origin in a way that could mislead, the country of origin must appear in close proximity, in at least comparable size, preceded by “Made in”, “Product of” or similar words. An OEM logo with a U.S. address cast into a housing is the typical trigger. If the part is usually combined with other articles before it reaches the purchaser, 19 CFR 134.14 can also require wording that makes clear the origin applies to that part only.
The RFQ package guide explains where a note like this fits among the other requirements sent with a drawing.
What country name goes on a part made or finished in Vietnam?
A part manufactured in Vietnam carries the country’s name in English, normally “Vietnam”. When the part is only finished in Vietnam from a casting, forging or blank made elsewhere, the mark depends on whether that finishing is a substantial transformation, which is decided part by part.
19 CFR 134.45 requires the full English name unless CBP has authorized another form, and accepts abbreviations and variant spellings that unmistakably indicate it; “Vietnam” is the plainest choice.
The harder case is split production. Machining an imported casting, plating an imported stamping, or assembling imported components may or may not change the origin. CBP decides substantial transformation by asking whether the article emerges with a new name, character or use, and it applies that test to the facts of each product, as its rules of origin publication explains. Minimal operations such as simple finishing or repacking generally do not move the origin, and the mark must follow the manufacturing route, not the shipping route.
How CBP is currently treating transshipment and minimally processed goods from specific countries changes with trade actions, and this guide does not state a current position on it. The official documents are the Federal Register notices and CBP’s evasion enforcement page. For a part where the answer matters, ask for a binding ruling under 19 CFR part 177 before the first shipment, not after.
In the RFQ, ask the supplier to confirm in writing where the casting, stamping or bar stock for each machined part comes from.
What happens if parts arrive unmarked or wrongly marked?
CBP can withhold delivery of the whole importation until the goods are marked or the estimated marking duty is paid, and unmarked articles that are not marked, exported or destroyed under CBP supervision before liquidation owe an additional marking duty. Per 19 CFR 134.2, that duty is 10 percent of the final appraised value, and 19 USC 1304(i) says it cannot be remitted.
Under 19 CFR 134.51, CBP notifies the importer on Customs Form 4647 to mark the goods, or to return released goods for marking, export or destruction. Marking after arrival means handling every part again at a U.S. warehouse under supervision, and the importer reimburses the cost of that supervision (19 USC 1304(i)–(j)). Deliberately removing or obscuring a required mark to conceal origin is a criminal offense under 1304(l).
Marking is cheapest when it is designed into the tooling. If the part will be finished by plating, anodizing or painting, check a first article with the finish applied, so the mark is confirmed legible before production shipments leave the plant.
Frequently asked
Is a label on the carton enough for OEM parts?
Only when an exception applies, such as a J-list article or a part that the U.S. manufacturer substantially changes under 19 CFR 134.35. Parts sold in their imported form, including spares, need the mark on the part itself unless CBP has agreed otherwise.
Does the mark have to say “Made in”?
Not in general; the English country name is enough. “Made in” or “Product of” becomes required when another place name, such as “USA” or a U.S. city, appears on the article in a way that could mislead, per 19 CFR 134.46.
Can the mark go on a face that is hidden after assembly?
If the OEM is the ultimate purchaser, the part may not need a mark at all. If the part reaches a buyer in its imported form, the mark must be conspicuous, which part 134 defines as “capable of being easily seen with normal handling of the article or container,” so a hidden face works only when it is visible at that point.
Are brass valve bodies and fittings covered by the special pipe-fitting rule?
The statute names fittings of steel, stainless steel, chrome-moly steel, and cast and malleable iron. Brass fittings fall under the general marking rule, where any permanent, conspicuous and legible method is acceptable.
Who is responsible if the parts arrive unmarked?
The importer deals with CBP and pays any marking duty. That is why the marking requirement belongs on the drawing and in the purchase order, where the supplier is bound to it.
Sources
- 19 U.S.C. 1304, Marking of imported articles and containers, U.S. Code, 2023 edition (text as amended by Pub. L. 116-113, 2020)
- 19 CFR part 134, Country of Origin Marking, eCFR, accessed September 2026
- 19 CFR 134.1, Definitions, eCFR, as amended by CBP Dec. 21-10, 2021
- 19 CFR 134.33, J-List exceptions, eCFR, accessed September 2026
- 19 CFR part 134 subpart E, Method and Location of Marking Imported Articles, eCFR, accessed September 2026
- What Every Member of the Trade Community Should Know About: U.S. Rules of Origin, CBP informed compliance publication, May 2004
- Marking of Country of Origin on U.S. Imports, CBP informed compliance publication page, accessed September 2026
- 19 CFR part 177, Administrative Rulings, eCFR, accessed September 2026
- Notice of actions in Section 301 investigations, Federal Register, July 28, 2026
- Enforce and Protect Act (EAPA), CBP, accessed September 2026