Quick answer. Country of origin on Amazon must be right in three places. On the product, U.S. Customs and Border Protection (CBP) requires most imported articles, or their containers, to be marked conspicuously, legibly and permanently with the English name of the origin country (19 CFR Part 134). In the listing, Amazon wants one origin per listing, per store, being where the product was made or last substantially transformed. In the copy, any “Made in USA” claim must meet the FTC’s “all or virtually all” standard, codified for labels in 16 CFR Part 323. Amazon says origin claims must be backed by verifiable evidence, and misleading claims can lead to product removal, listing restrictions and account penalties.

Country of origin looks like the easiest field on a listing. Most new sellers fill it from memory, copy it from a competitor’s page, or leave whatever the catalog shows. Then a listing drops out of search under a claims policy, a buyer complains that the box says one country and the page says another, or Amazon asks for proof behind a “Made in USA” badge in an image. The seller is surprised, because as far as they knew origin was a dropdown.

That dropdown sits on top of two federal rules and one Amazon policy. Below is how they fit together, how to verify and document origin, and what to do when a listing is pulled over it. This is educational information, not legal or customs advice.

Why one product has three origin rules

CBP asks what the buyer must be told about an imported article. The FTC asks when a product may be called American. Amazon asks for one accurate value in a listing attribute. Treat them as one rule and you usually get one of them wrong.

CBP. The marking on imported goods

Under 19 CFR 134.11, unless an exception applies, every article of foreign origin (or its container) imported into the United States must be marked to show the English name of the country of origin to the ultimate purchaser in the United States. Section 134.1(b) defines country of origin as the country of manufacture, production or growth of an article of foreign origin. Work in a second country changes origin only if it is a substantial transformation. The ultimate purchaser, under 134.1(d), is generally the last person in the U.S. to receive the article in its imported form, which for an Amazon seller is usually the customer.

FTC. Claims that a product is American

The FTC’s staff guidance, “Complying with the Made in USA Standard,” says that for an unqualified claim the product must be “all or virtually all” made in the United States. That means final assembly or processing in the U.S., all significant processing in the U.S., and all or virtually all ingredients or components made and sourced in the U.S. The guidance also says that passing CBP’s marking rules does not by itself permit a Made in USA claim.

Amazon. One value per listing

Amazon’s page on delivering imports to Amazon defines country of origin as the country where the product was produced or manufactured or, where more than one country was involved, the country where it underwent its last substantial transformation. More specific rules might apply depending on the product type. Amazon says identifying the correct origin for each listing is your responsibility, and that if you do not know it you must contact the supplier or manufacturer.

How CBP country of origin marking works in practice

If you import, CBP looks to you for marking. If you buy from a U.S. distributor, your listing still has to match what is on the product.

What a compliant marking looks like

Section 134.41 favors marking worked in at manufacture, such as molding, etching or imprinting. The marking should stay on the article or its container in any reasonably foreseeable circumstance until it reaches the ultimate purchaser, unless deliberately removed. It must survive normal distribution and store handling, and the purchaser must be able to find it easily and read it without strain. Section 134.44 accepts any method and location that makes the origin appear conspicuously, and says paper stickers and tags must stay securely attached through storage and display.

FBA units pass through carriers, a fulfillment center and a delivery van before the customer sees them. A loose hang tag, or a sticker on a carton discarded at receiving, will not survive that trip.

Words that trigger extra marking

Two sections catch private label sellers. Under 134.46, if “United States,” “U.S.A.,” “America,” a U.S. place name, or a foreign place name other than the country of origin appears on an imported article or its container in a way that could mislead the buyer about origin, the actual country of origin must appear close to those words, in letters at least as large, preceded by “Made in,” “Product of” or similar wording. Under 134.47, if a U.S. location or “America” appears in a trademark, trade name or souvenir marking, the article must also carry a conspicuous, permanent origin marking preceded by similar wording.

A hypothetical “Brooklyn Kitchen Co.” importing cutting boards from Vietnam therefore needs “Made in Vietnam” near the brand name, at least as large, on the packaging the customer receives.

Exceptions, and why they rarely help a retail seller

Sections 134.32 to 134.35 list exceptions, such as articles that cannot be marked, crude substances, the “J-list” of excepted article types (whose outermost container generally still needs marking), and imports a U.S. manufacturer turns into an article with a different name, character or use. Most finished retail goods sold on Amazon fit none of these. Assume marking applies unless your broker or a CBP ruling says otherwise in writing.

Repacking, kitting and bundles

Under 134.26, an importer whose goods will be repacked into new retail packaging certifies to CBP that the marking will not be obscured or that the new package will be marked, and must notify any buyer who will repack in writing at the time of sale or transfer. If a prep center bundles your imports, the marking must still be visible to the customer after prep.

What happens when goods are not marked

Under 134.2, articles not marked as required are subject to an additional duty of 10 percent of the final appraised value, unless they are exported or destroyed under customs supervision before liquidation. Under 134.51, when CBP finds articles not legally marked, it notifies the importer on Customs Form 4647 (or its electronic equivalent), and the importer must arrange to mark them properly or return released goods to customs custody for marking, export or destruction. A marking problem found at the port costs money. One found by a customer can cost you the listing.

If the stakes are high, have our listing recovery team review the case before you respond.

The FTC Made in USA standard and the Labeling Rule

Amazon’s misleading and prohibited claims policy defines Made in USA claims as statements, explicit or implied, that a product is of U.S. origin, such as that it is made, manufactured, built, produced, created or crafted in the United States or in America. Amazon prohibits products that imply or claim Made in USA without meeting the FTC’s requirements, and links the FTC guidance and an Attestation of Compliance form.

What 16 CFR Part 323 says

The FTC’s Made in USA Labeling Rule took effect on August 13, 2021. Section 323.2 makes it an unfair or deceptive act to label a product Made in the United States unless the final assembly or processing occurs in the United States, all significant processing that goes into the product occurs in the United States, and all or virtually all ingredients or components are made and sourced in the United States. Section 323.3 extends that to mail order catalogs and mail order promotional material when they include a seal, mark, tag or stamp labeling the product Made in the United States. The rule defines that material to include materials disseminated by electronic means that solicit a purchase without the buyer examining the product. The FTC’s guidance says marketers are now subject to civil penalties for an unqualified Made in USA label on a product that is not all or virtually all made in the U.S., including in catalogs or online.

A “Made in USA” flag graphic in a main image, a badge in A+ content or a stamp on a packaging photo is exactly the kind of label this language covers.

How the FTC weighs foreign content

The FTC weighs cost, how far removed foreign content is from the finished product, and how important it is to form or function. It gives these examples.

• A watch with imported Swiss movements. The movements are a small share of cost but necessary to function, so an unqualified claim is likely deceptive.
• A gold ring made from imported gold. The gold is valuable and close to the finished product, so an unqualified claim is deceptive.
• A table lamp with an imported base. The base is a small share of cost but not far removed and significant to the product, so the claim is deceptive.
• A food processor whose motor is 50 percent of manufacturing cost and made with imported parts. No unqualified claim, even if most other parts are American.

Qualified claims, Assembled in USA and component claims

A qualified claim describes the extent, amount or type of domestic content, such as “60% U.S. content” or “Made in USA of U.S. and imported parts.” In the FTC’s treadmill example, U.S. parts are about three percent of part cost, so “Made in USA of U.S. and Imported Parts” is deceptive, while “Made in U.S. from Imported Parts” or “Assembled in U.S.A.” would not be.

For “Assembled in USA,” the FTC says principal assembly must take place in the U.S., the assembly must be substantial, and the product’s last substantial transformation should have occurred in the U.S. Simple “screwdriver” assembly of foreign parts usually does not qualify. Part or process claims, such as “Designed in USA, Made in Finland,” must clearly refer to that part or process. “Created in USA” for a product made abroad is deceptive.

Products with their own origin laws

The FTC notes that automobiles and textile, wool and fur products have separate origin disclosure laws, and 323.5 preserves other federal origin labeling laws, such as for meat and poultry. Check the specific rule for your product type.

Amazon’s country of origin attribute and how to set it

Setting origin in bulk

Amazon says to download the Category Listings report, which gives you a spreadsheet of your listings for each store. Find the country of origin column in the Compliance section (row 3) of the Template tab. Fill in missing values from the dropdown list and correct existing ones if needed. Before saving, select Edit (partial update) in the Listing Action column for every listing, and check that the Quantity and Price columns are correct. Then upload it. A stale price or quantity in the file creates a new problem.

Setting origin for one listing

For a single listing, Amazon says to go to Inventory, then Manage All Inventory, click the three dots next to the product, select Edit listing, and find the Country of origin field under the Safety and compliance tab. If you cannot see it, select Suggest change to product information. Depending on the product type, the field can appear under Safety and compliance, Offer or Product details.

What Amazon’s FAQ settles

• One origin per listing. If a product has more than one country of origin, Amazon says you must create separate listings and give one origin for each.
• Per store. Origin must be provided for each listing in each store separately.
• Locked fields. On shared pages Amazon may restrict editing, but you can still update origin through the Category Listings report.
• No certificate upload. Amazon says you do not need to provide a certificate in Seller Central to prove origin. You still hold the proof yourself.
• No “EU.” Origin must be the exact country where the product was completely produced or underwent its last substantial transformation.

The two factory problem

Suppose a hypothetical seller buys one phone stand from factories in Vietnam and China under one SKU. The units carry two markings, but the listing can show only one. Amazon’s answer is separate listings with one origin each, and its detail page rules forbid false product identification information. Our guide to barcodes and GTINs covers the identifier side of creating a second listing.

How wrong origin claims lead to listing removals and complaints

Origin problems show up as a claims violation, a detail page accuracy issue or a customer complaint.

Under the misleading and prohibited claims policy

Amazon’s policy says claims about a product’s performance, composition, ingredients or origin must be backed by verifiable evidence and documentation, and gives “Made in Italy” for a product only assembled in Italy as an example of a problem claim. It covers claims on all detail pages, including images, descriptions, packaging and marketing materials, in all categories. Amazon says claims that are prohibited and found to be misleading may lead to enforcement actions, including product removal, listing restrictions and account penalties. Appeals of a compliance requirement go through Account Health.

Under the product detail page rules

Amazon’s detail page rules require product information to be accurate and trustworthy and not mislead customers about a product’s qualities or characteristics. Listings identified as purposefully inaccurate or deceptively described to get around Amazon’s restrictions may lead to corrective action, including immediate termination of selling privileges. Repeatedly adding and removing prohibited claims to get around controls is evasive behavior, which Amazon says has no path to reinstatement without valid proof of adherence to all applicable laws and policies. Toggling a “Made in USA” badge on and off after each removal is the fastest way to turn a listing problem into an account problem.

Customer and competitor complaints

A customer who finds “Made in China” on a box bought from a page with a flag badge has reason to complain and return it. Other sellers and brand owners see shared pages too, and Amazon’s rules point them to the Report Abuse form in Account Health for incorrect information on branded pages. Our guide to writing accurate product descriptions covers the wider copy rules that apply here.

For a closely related case, read Amazon Seller Reputation and Account Health.

Where to verify origin before you list or claim it

Check each statement against a source you can produce later. Our team runs this check when reviewing a catalog.

Using CBP rulings without over-relying on them

CBP issues binding advance rulings and publishes them in CROSS. Under 19 CFR 177.1(c), an importer or other person with a direct and demonstrable interest may request one. Under 177.9, a ruling covers the transaction it describes, and other persons should not rely on a ruling issued to someone else. When a product involves real processing in two countries, settle origin with a ruling or a written view from a licensed customs broker.

How to document country of origin

Amazon’s claims policy requires origin claims to be backed by verifiable evidence, so the evidence has to exist before Amazon asks for it.

What a complete origin file contains

• Supplier origin statement. It names the product or SKU, the factory’s legal name and address, and the country of manufacture, and for multi country products, what is done where.
• Commercial invoices. Final invoices showing origin and a description matching the listing. Our guide to invoices Amazon accepts covers the format.
• Entry records. For your imports, kept generally 5 years from entry under 19 CFR 163.4.
• Marking photos. Dated photos of current units and packaging.
• Bill of materials. For any U.S. origin claim, each part’s country, cost and role.
• Process description. For “Assembled in USA” claims, what U.S. work makes it substantial.
• Listing snapshots. Dated report and page copies after each change.

What does not count as evidence

A competitor’s listing, a sales rep’s chat message, a pro forma quote or your own statement is not evidence. Never alter, backdate or create a document. If the supplier will not confirm origin, or documents show another country, change the listing to match the truth.

When a listing is removed for an origin problem

Structure it like any good appeal. State what happened, what you fixed with proof, and what stops it recurring. Our guide to writing a plan of action covers the format.

Diagnose. Classify the reason first

Read the notice in Account Health and identify the policy named. A Made in USA claims violation and an origin attribute accuracy issue are usually contained listing fixes. An authenticity question that mentions origin is an account warning that needs supply chain evidence. Then check the whole catalog, because an unsupported flag badge on one listing is probably on others.

Find the real root cause

“We made a mistake” is not a root cause. Real root causes are specific. The template was copied from a U.S. made product. The factory moved and nobody updated the listing. A designer added a flag graphic that was never checked against the bill of materials.

Corrective actions you can prove

List what you already did, with dates and evidence, such as the corrected value (report snapshot), removed claims (before and after images), corrected packaging or relabeled stock, the supplier’s origin statement and the catalog audit. Finish the fixes before you describe them.

Preventive controls with an owner and a date

Name the control, its owner and its start date. For example, no listing goes live until the operations lead attaches the supplier’s origin statement, a named person checks artwork against 19 CFR 134.46, and any U.S. origin claim needs a bill of materials review. Amazon says compliance appeals go through Account Health. Our guide on fixing listing issues covers the wider listing recovery process.

When the honest answer is to stop claiming

If the product cannot meet the FTC standard, remove the claim and do not hunt for a supplier letter that says otherwise. Wrongly marked stock must be corrected or removed. A truthful, smaller claim beats a removed listing.

For a closely related case, read Amazon Seller Challenge.

Common country of origin mistakes new sellers make

These patterns cause most origin listing problems, and each one is avoidable.

• Copying the origin from the existing page. The displayed value may be another contributor’s. Check your own units and supplier.
• Treating “designed in” as “made in.” The FTC accepts “Designed in USA, Made in Finland” but treats “Created in USA” for a product made abroad as deceptive.
• Counting only cost. The FTC’s watch, lamp and ring examples show a cheap imported part can defeat an unqualified claim.
• Light assembly treated as transformation. Fitting a handle to an imported pan is the simple assembly the FTC says usually does not support “Assembled in USA.”
• Markings that do not survive prep. A discarded carton sticker or a bundle wrap can leave the customer with an unmarked unit.
• Forgetting images and A+ content. Sellers fix the bullet and leave the flag badge in image four.
• Mixing factories under one listing. One origin per listing means two countries need two listings.

Three rules side by side

A routine that keeps origin right

Origin errors creep in when something changes and the listing does not, so tie the check to the moments of change.

• At product development. Put the marking wording and method in the purchase order and packaging brief, check any U.S. place name in the brand against 19 CFR 134.46 and 134.47, and decide what claim the evidence supports before artwork is final.
• Before each listing goes live. Attach the supplier’s origin statement to the SKU record, set the attribute from it, and review copy and images for origin wording. If you import, our guide to importing from China and customs entry covers the entry side, where the origin on your customs records comes from.
• On every production run. Confirm the factory and country have not changed and photograph a unit’s marking. A factory move is the most common silent cause of a wrong value.
• Every quarter. Compare the Category Listings report for each store against the supplier file, save it with a date, and search your images for flags and U.S. origin wording.

For a closely related case, read Trademark Classes for Amazon Sellers.

Frequently Asked Questions

What country of origin should I enter on Amazon?

Amazon says to enter the country where the product was produced or manufactured, or, if more than one country was involved, where it underwent its last substantial transformation. Get it from the supplier or manufacturer in writing.

Can one Amazon listing have two countries of origin?

No. Amazon says each listing can have only one country of origin, so a product made in two countries needs separate listings.

Do I need to upload a certificate of origin to Amazon?

Amazon says you do not need to provide a certificate in Seller Central. Its claims policy still requires origin claims to be backed by verifiable evidence, so keep the documents.

What does 19 CFR Part 134 require?

Unless an exception applies, every imported article or its container must be marked conspicuously, legibly and permanently with the English name of its country of origin for the ultimate purchaser in the United States.

When can I say Made in USA on Amazon?

Only when the product is all or virtually all made in the U.S., with final assembly and significant processing in the U.S. Amazon prohibits Made in USA claims that do not meet the FTC’s requirements.

Does a flag image count as a Made in USA claim?

It can. Amazon’s policy covers implied claims in images and packaging, and 16 CFR 323.3 covers seals, marks, tags or stamps in online sales material.

Get Help With Origin Related Listing Removals

If a listing was removed over an origin claim, our team can review your listing, packaging and supplier file and help you build a truthful, documented response. See how we approach listing recovery, submit your case or book a consultation.

This article is educational information about Amazon policies and U.S. origin rules as published at the time of writing. It is not legal or customs advice. Rules for specific product types, including textiles, food and automobiles, may differ. Confirm current requirements with CBP, the FTC, Amazon and a licensed customs broker or attorney before acting.

If the account itself is restricted, start with our Amazon suspension service. You can also see all our marketplace suspension services.

Sources

• Amazon: Delivering imports to Amazon (country of origin section and FAQ)
• Amazon: Misleading and prohibited claims
• Amazon: Product detail page rules
• FTC: Complying with the Made in USA Standard
• FTC: Made in USA Labeling Rule, 16 CFR Part 323 (Federal Register)
• 19 CFR Part 134, Country of Origin Marking (sections 134.1, 134.2, 134.11, 134.26, 134.32, 134.33, 134.35, 134.41, 134.44, 134.46, 134.47, 134.51, 134.52)
• 19 CFR Part 177, Administrative Rulings (sections 177.1, 177.9)
• 19 CFR Part 163, Recordkeeping (section 163.4)
• CBP: Rulings and Legal Decisions (CROSS)
• CBP: Informed Compliance Publications