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Country of Origin

Bosch VENDOR GUIDELINES For Country of Origin Marking

Made in the USA (MIUSA) Certificate Form

Supplier Instructions

  • Suppliers to Bosch must adhere to the following Country of Origin part marking instructions.
  • The information provided is to assist suppliers when shipping goods to Bosch. These procedures should not be interpreted as a substitute for compliance to the U.S. Customs & Border Protection (CBP) regulations, nor the Federal Trade Commission (FTC) regulations. Bosch shall not be responsible for your failure to understand and comply with all applicable governmental regulations.
  • For additional information on marking requirements, please contact your procurement agent.

Marking

  • All products shall be accurately marked or labeled with the country of origin in compliance with applicable laws and including those of the country of manufacture.
  • Suppliers of finished products that are marked “Made in USA” or similar, or by virtue of their design or packaging imply that they are “Made in USA” shall comply in all respects with the U.S. Federal Trade Commission Guidelines regarding product marking and shall be made of all, or virtually all, domestic (US) content.
  • Where an article is produced as a result of an assembly operation and the country of origin of such article is determined to be the country in which the article was finally assembled, such article may be marked, as appropriate, in a manner such as the following:

(1) Assembled in (country of final assembly)
(2) Assembled in (country of final assembly) from components of (name of country or countries of original of all components); or
(3) Made in, or product of, (country of final assembly)

Foreign Country of Origin Marking Requirements

  • Bosch requires that every article of foreign origin (or it’s container) imported into the United States be marked in English, legibly, conspicuously, indelibly and permanently with the country of origin. Because Bosch parts may be subject to import, export and re-import, this requirement applies to all imported parts including returns and repairs.
  • Each article must have the full English name of its country of origin (manufacture) marked on the article (unless excepted). If excepted, the outer container of the imported part must be marked with the country of origin.
    Examples:

    • Made in China
    • Product of Korea
    • Manufactured in India

Country of Origin Marking Requirements

  • The actual Bosch item and or the usual container in which a good will ordinarily reach its ultimate purchaser must be marked.
  • The marking must be in English, legible to the naked eye, in a conspicuous location and indelibly and permanently applied.
  • In any case in which the words “United States” or “American” the letters “U.S.A.” or any variation of such words or letters, or the name of any city or location in the United States, or the name of any foreign country or locality other than the country or locality in which the article was manufactured or produced appear on an imported articles or its container, and those words, letters or names may mislead or deceive the ultimate purchaser as to the actual country of origin of the article, there shall appear legibly and permanently in close proximity to such words, letters or names, and in at least a comparable size, the name of the country of origin preceded by “Made in”, “Product of,” or other words of similar meaning.

Suggested Methods of Marking

  • Section 304 of the U.S. Tariff Act of 1930, as amended (19 USC 1304) requires that the marking of the country of origin be legible, indelible, and permanent. Definite methods of marked are prescribed only for articles provided for in 134.43 for articles which are objects of special rulings by Customs. As a general rule, marking requirements are best met by marking worked into the articles at the time of manufacture. For examples, it is suggested the country of origin on metal articles be die sunk, molded or etched.
  • Other acceptable methods of marking:
    • Articles marked with paper sticker labels. If paper sticker or pressure sensitive labels are used, they must be affixed in a conspicuous place so securely that unless deliberately removed they will remain on the article while it is in storage or on display until it is delivered to the ultimate purchaser
    • Ultimate purchaser. 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.

Exceptions to Marking Requirements

  • Articles appearing on the “J” list
    • This list is found in 19 CFR 134.33 of the Customs Regulations and in 19 USC 1304J. It names specific goods that do not have to be marked on the good itself, but allows the ‘packaging’ to carry the country of origin marking. Goods on this list which are imported by Bosch include small ball bearings, bolts, nuts, washers, rivets, etc. Items on the J-list are excepted from individual marking. However their outer container MUST be marked with the country of origin.
    • If you feel any item is subject to this list, it is suggested that you confirm your marking process with the appropriate Bosch purchasing personnel.
  • Special Marking Requirements 134.43
    • Except for goods of a NAFTA country, articles of a class or kind listed below shall be marked legibly and conspicuously by die stamping, cast in the mold lettering, etching, engraving or by means of metal plates which bear the prescribed marking and which are securely attached to the article in a conspicuous place by welding, screws or rivets; knives, forks, steels, cleavers, clipper, shears, scissors, safety razors, blades for safety razors, pliers, pincers, nippers and hinged hand tools for holding and splicing wire, vacuum containers and parts of the above articles. Goods of a NAFTA country shall be marked by any reasonable method which is legible, conspicuous and permanent as otherwise provided in this part.
  • Subpart D to Part 134 of Customs Regulations (CFR 19) lists general exception to marking requirements. Note that these exceptions do not apply to any marking required by other agencies.
    • Because Bosch parts may be subject to import, export and re-import over the lifetime of the part, Bosch requires country of origin marking on individual parts unless:
      • The exported part is a product of the U.S. exported and returned
      • The article is incapable of being marked (as defined by U.S. Customs Regulations)
      • The articles cannot be marked prior to shipment to the U.S. without Injury (as defined by U. S. Customs Regulations)
  • CF 134.26 (a) states that if an imported article is intended to be repacked, the importer shall not obscure or conceal the country of origin marking or else the new container shall be marked to indicate the country of origin
  • If an article subject to these requirements is intended to be repacked in new containers for sale to an ultimate purchaser after its release from Customs custody, or if the port director having custody of the article has reason to believe such article will be repacked after its release, the importer shall certify to the port director that if the importer does the repacking, the new container shall be marked to indicate the country of origin of the article in accordance with the requirements of this part.

Foreign Suppliers: Please contact Bosch Compliance if you have any questions on how to mark product supplied to Bosch.