"Made in China" Labels: US Country-of-Origin Marking Rules for Sellers
"Made in China" on a product or box is not just a label; it is a US legal requirement, and getting it wrong can cost an extra 10% duty or force you to re-label goods at the port. Many factories selling to US marketplaces also print US brand names and addresses on packaging, which triggers extra rules. This guide explains the country-of-origin marking rules in US customs regulations (19 CFR Part 134) in plain language.
This is a general summary, not legal advice. Complex cases, such as products assembled in several countries, may need a CBP ruling or a customs broker's advice.
The basic rule
Under 19 CFR 134.11, unless an exception applies, "every article of foreign origin (or its container) imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit," showing the ultimate purchaser in the US "the English name of the country of origin."
- Country of origin means the country of manufacture, production or growth. Work done in another country must cause a "substantial transformation" to change the origin (19 CFR 134.1).
- Ultimate purchaser is generally the last person in the US who receives the article in the form in which it was imported. For most marketplace goods, that's the consumer.
The cost of getting it wrong
According to 19 CFR 134.2, articles not properly marked "shall be subject to additional duties of 10 percent of the final appraised value" unless exported or destroyed under customs supervision before liquidation. The duty applies both for failing to show the English country name and for missing words needed "to prevent deception or mistake."
| Shipment value (appraised) | Extra marking duty (10%) |
|---|---|
| $10,000 | $1,000 |
| $25,000 | $2,500 |
| $50,000 | $5,000 |
Calculation: appraised value × 10%, per 19 CFR 134.2. This is on top of normal duties, and goods may also be held until they are re-marked.
How to mark: method and permanence
19 CFR 134.41 says marking is "best met by marking worked into the article at the time of manufacture," for example die-sunk or molded on metal, glazed on ceramics, or printed on paper articles. The marking should stay on "until it reaches the ultimate purchaser unless it is deliberately removed," must "survive normal distribution and store handling," and the purchaser "must be able to find the marking easily and read it without strain."
Common situations
| Situation | What the rules require | Rule |
|---|---|---|
| Standard product made in China | "China" in English, conspicuous and permanent, on the article (or container where allowed) | 134.11 |
| Abbreviations or variant spellings | Allowed only if they unmistakably indicate the country (e.g. "Gt. Britain") | 134.45 |
| "USA," "American" or a US city appears on the product or box | The origin, preceded by "Made in" or "Product of," in close proximity and at least comparable size | 134.46 |
| Box shows a US importer's or brand's name and address | Origin marked near the address, e.g. "Contents made in China" | 134.22(c) |
| Article itself is excepted from marking | The outermost container that reaches the purchaser must still be marked | 134.22(a) |
Source: 19 CFR Part 134 via eCFR (accessed Nov 8, 2026).
The most common trap for private-label brands: a box printed with "Designed in California" or a Los Angeles address. Under 134.46, that needs "Made in China" (or the actual origin) close by and in comparable size.
Practical checklist for factories and brands
- Confirm the true country of origin, especially for products with parts from several countries.
- Mold, print or sew "Made in China" (or the right country) into the product where practical.
- Check packaging for any US names, cities or "USA" wording and add origin marking next to them.
- Use the full English country name; avoid unclear abbreviations.
- Make sure labels survive shipping and handling; avoid easily removed stickers where permanent marking is possible.
- Keep photos of markings on file for each SKU.
- Share marking requirements with your factory in the purchase order.
Marking is only one part of compliance; also see our guides on how to find your HTS code and the CPSC eFiling guide.
How Atronia Innovations can help
We help Chinese factories prepare products and packaging for the US market, from compliance checklists to marketplace launch, with teams in Shenzhen and Los Angeles. Explore our Brand Accelerator or talk to our team.
