Made in USA / Product of USA

Following the supply chain audit the Standards employed to determine if an item if an item qualifies for MADE and PRODUCT of USA designations, the below Standards are applied:

• The finished good must be manufactured / processed exclusively within the United States, assembly and all associated labor must performed entirely and exclusively within the United States;

• All content materials, raw ingredients and/or component parts, which together comprise the finished article, must each be domestically sourced;

• If any of the component materials, raw ingredients and/or component parts are imported, an analysis must be performed in order to determine the percentage of domestic content of the item. The costs used to make this evaluation include direct cost of each component, direct labor costs, costs of all manufacturing materials per product unit and total manufacturing cost of product. This is done with ever article even where a raw material is nonindigenous to the United States. Any content material not sourced from the US, is a treated as an imported article;

• The evaluation of an item's domestic content is always done against the backdrop of "what is the item". Therefore, if you have an item, with both domestic and imported content materials, the fact that the percentage of imported content may be low based on the above cost analysis, if the product itself is in essence that imported material, the item will not qualify. An example would be a candle made in the USA from imported wax. While the manufacturing process of the imported wax and insertion of a domestically sourced wick costing more than the wax, is performed in the United States. The item would not qualify. The article is in essence a wax candle and the wax is imported;

• An entire subset of standards exists when looking at a finished good that utilizes imported raw materials, as well as that of domestically sourced ingredients or raw materials. When determining if an imported content material retains its foreign origin requiring a percentage of domestic content to be rendered, or if the article is substantially transformed undergoes a substantial transformation by way of we look first to see if under the concept of substantial transformation, that imported content material for purposes of identifying the percentage of domestic content. We often look to determine if that imported article is substantially transformed;

• Customs has applied a “substantial transformation” test, under which a product’s country of origin is the last country in which the merchandise was substantially transformed into new and different article commerce. Customs has explained that substantial transformation further requires that the component materials of the article acquire “a new name, character, or use;

• The origins and applications of the term substantial transformation is rooted in well-established Federal interpretations, particularly by the U.S. Customs and Border;

• Each product may be evaluated on a case-by-case basis. Review of past and current holdings will be utilized in each evaluation. A due diligent effort will be undertaken to find a holding on point with the facts of the pending product. If a clear determination can not be assessed, there will not be a finding of substantial transformation and the original component material will maintain its status as a material of foreign origin and an the deemed to consist of both foreign and domestic content and evaluated as such;

• If an item consisting of an imported content material may still be a product of the USA, if after it arrived in the US it was substantially transformed into the a new and different article of commerce with a name, character and use distinct from that of the original imported article, form which it was transformed;

• Test for determining whether a substantial transformation occurs Is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing;

• Simply refining a product into a purer form or diluting it with water, does not meet the threshold. That is because the process or combining process still leaves identify of the article in tact. The final product is essentially the same thing as the original raw material.

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