Under Country of Origin (COO) rules, when more than one country is involved, origin is determined by the location of what?

• A. the place where the article was wholly obtained
• B. the location of the last substantial transformation
• C. the location where there is a change in the product designation number
• D. the location where final labeling occurs

Answer: (B)

When multiple countries are involved, the country of origin is set by where the product last underwent a substantial transformation—the step that gives the product its final name, character, and use. Substantial transformation is a change strong enough to create a new article with its own identity. For example, raw coffee beans grown in one country and roasted in another: the roasting is the substantial transformation that gives the product its final form, so the origin is the country where roasting occurs. If the product were wholly produced in a single country with no other country involvement, that country would be the origin, but with multiple countries, the last substantial transformation determines it. Labeling location or changes in product designations don’t determine origin.