How will the US determine if a good is of Singapore Origin and subject to the US’ 12.5% Section 301 tariff? How is Regional Value Content (RVC) determined, especially for operations like final assembly?

Q: How will the US determine if a good is of Singapore Origin and subject to the US’ 12.5% Section 301 tariff? How is Regional Value Content (RVC) determined, especially for operations like final assembly?

Updated as of 20 August 2026. According to the US Code of Federal Regulations Title 19 (Customs Duties) Part 134.1 (Definitions), “country of origin” means the “country of manufacture, production, or growth of any article of foreign origin entering the United States.” When a good does not come entirely from a single country, the origin of the good is determined using the “substantial transformation” criterion. This means that the good underwent a fundamental change in form, appearance, nature, or character. This fundamental change normally occurs as result of processing or manufacturing in the country claiming origin. Minimal processing or assembly operations do not usually result in a substantial transformation. This applies to all non-textile goods. For more information, including the rules for textile goods, companies may refer to the US CBP’s Informed Compliance Publication, “What Every Member of the Trade Community Should Know About: Rules of Origin” . You may also wish to: Consult the US CBP Customs Rulings Online Search System (CROSS) for past US CBP rulings on goods similar to those intended for export to the US. Apply to the US CBP for an advance ruling to determine your good’s country of origin before it is exported to the US. For more information, click here . Consider working with trade compliance experts and/or seeking appropriate legal advice to ensure compliance.

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Updated as of 20 August 2026.

According to the US Code of Federal Regulations Title 19 (Customs Duties) Part 134.1 (Definitions), “country of origin” means the “country of manufacture, production, or growth of any article of foreign origin entering the United States.”

When a good does not come entirely from a single country, the origin of the good is determined using the “substantial transformation” criterion. This means that the good underwent a fundamental change in form, appearance, nature, or character. This fundamental change normally occurs as result of processing or manufacturing in the country claiming origin.

Minimal processing or assembly operations do not usually result in a substantial transformation. This applies to all non-textile goods. For more information, including the rules for textile goods, companies may refer to the US CBP’s Informed Compliance Publication, “What Every Member of the Trade Community Should Know About: Rules of Origin”.

You may also wish to:

Consult the US CBP Customs Rulings Online Search System (CROSS) for past US CBP rulings on goods similar to those intended for export to the US.
Apply to the US CBP for an advance ruling to determine your good’s country of origin before it is exported to the US. For more information, click here.
Consider working with trade compliance experts and/or seeking appropriate legal advice to ensure compliance.

How will the US determine if a good is of Singapore Origin and subject to the US’ 12.5% Section 301 tariff? How is Regional Value Content (RVC) determined, especially for operations like final assembly?

You may also wish to:

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Related questions

Can I export goods to the US under the USSFTA’s Integrated Sourcing Initiative (ISI) to be exempt from the 12.5% Section 301 tariff?

How do I achieve ‘Singapore origin’ status for my goods under the USSFTA?

Are there any changes to how the US will determine if a good is of Singapore origin for the purposes of the US’ implementation of the Section 301 tariff?

Can companies producing goods in other countries export these goods to Singapore first, and then from Singapore to the US, to qualify as Singapore-originating?

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