Domestic vs. Foreign Origin

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By: Melannie Belton

Exporters often ask: “How should I report a shipment for goods with the same schedule B, but composed of domestic and foreign origin?”

You want to be sure that you are accurately identifying the origin of your goods in order to properly file. So, if you are unsure as to whether your item should be reported as domestic or foreign, keep the following in mind:

Made in the USA and China

  • Domestic goods include commodities that are grown, produced, or manufactured in the United States, including goods exported from U.S. FTZs, Puerto Rico, or the U.S. Virgin Islands. Shipments of foreign origin that were previously imported and are further manufactured or processed in the United States, or have been enhanced in value or changed from its original form will be reported as domestic.
  • Foreign goods include commodities that are grown, produced, or manufactured in foreign countries and have not undergone changes in form or condition or enhancement in value by further manufacturing in the United States, in U.S. FTZs, in Puerto Rico, or in the U.S. Virgin Islands. This includes merchandise that has entered the United States and is being re-exported in the same condition as when imported.

After properly identifying the origin of your goods, you need to determine how the information should be filed in the AES. In Section 30.6 (a)(11) of the Foreign Trade Regulations, it states that items of domestic or foreign origin under the same Schedule B number should be reported separately.

If your items of domestic or foreign origin are valued less than $2,500 separately, those items do not require an AES filing and the low value exemption citation, NOEEI 30.37(a), can be used. However, when either the domestic and/or foreign component of the shipment is valued over $2,500 an AES filing is required. Report ‘D’ for domestic and ‘F’ for items that are foreign.

For additional regulatory clarification or assistance on this or other regulatory issues, contact Regulations at 1-800-549-0595 Opt. 3.

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5 Responses to Domestic vs. Foreign Origin

  1. Pam says:

    Please clarify if I have items under the same schedule B “D” valued at $1500 and “F” valued at $3000, must they both be reported in the AES record or only the “F” which is valued over $2500?

  2. Dustin says:

    Can imported blank t-shirts that are screened in the US be classified as domestic? The screening does increase and enhance the value of the blank t-shirt. Thanks!

  3. Global Reach - Sean says:

    @ Pam: Assuming an export license is not required, only commodity “F” would require filing since it is over $2,500. Commodity “D” would be exempt under Section 30.37(a).
    @ Dustin: According to Section 30.6(a)(11)(i), domestic goods include “articles of foreign origin that have been enhanced in value…” Therefore, the t-shirts would be considered a domestic product for AES purposes.

  4. Gel says:

    If I am a distributor and I bought this commodity from a manufacturer in Arizona, where their headquarter is, but which has a facility in a “U.S. export processing zone” in Ireland, where the commodities came from, when I export this commodity to my buyer in Asia, as is or without any enhancements done in the US, should I declare my goods as of domestic origin or of foreign origin?

  5. Global Reach - Sean says:

    @ Gel: If the goods are produced in a foreign country and undergo no change in form or value while in the U.S. they would be considered foreign. Based on your description the goods would be listed as foreign.

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