Knowella

Country of Origin Verification

The recurring failure is an origin claim resting entirely on a supplier's declaration, never checked against a bill of materials or manufacturing location, and never revisited when the supplier changes. Origin drives duty rates, labelling claims on the pack, and customer contracts — a claim you cannot evidence at audit is one that should never have been made.

KnowLogisticsRecordLOG-03939 fields across 4 sectionsFull researchSee the form

Reviewed by Siddarth SinghCSPLast reviewed 16 August 2026

Basis
FALCPA
Workspace
KnowLogistics
Form type
Record
Completed by
Trade compliance with technical, on new materials and on change
Trigger
A new material, or a change to an existing supplier or process

The short version

  • Origin is not one fact but a claim built on three tests — wholly obtained, substantially transformed, or supplier declaration only — and the template forces a choice of exactly one at Basis Of The Claim.
  • A preferential origin claim needs its rule of origin met, not just a country recorded — Preferential Rules Of Origin Met is distinct from Origin Evidenced for that reason.
  • The record is reverified on supplier change by design: an origin claim tied to one supplier's process does not transfer automatically to a replacement supplier.
  • The claim feeds two other records, not one — a Label Verification and an environmental claim — so an unevidenced origin claim propagates into a labelling defect and an environmental claim that also cannot be defended.

What this is

What is a country of origin verification?

What is a country of origin verification?

A country of origin verification is a record used in KnowLogistics that verifies and evidences the origin claimed for a material or product — the country a customs authority, a label or a customer contract will treat as where it was made. It sits inside Trade and Customs Compliance, alongside the export and import checks it feeds.

When is a country of origin verification completed?

It is completed when a new material is introduced and again on change — a new supplier, manufacturing location, or process. An origin verified two suppliers ago does not carry forward to the current one.

What is the difference between 'origin claimed' and 'origin evidenced'?

Origin Claimed is what the label or paperwork says. Origin Evidenced, in the Outcome section, is a separate judgement on whether that claim survived the checks in Evidence and Verification. A record can carry both fields without the second following from the first.

Scope

When is a country of origin verification required?

This record is one step in a larger programme. Using it for work belonging to a neighbouring template — an import check, an export declaration, a labelling review run without reference back — produces claims hard to defend.

Use this template when

  • A new material, substance or product is introduced and its country of origin needs establishing and evidencing
  • A supplier, manufacturing location or process for an existing material has changed
  • A preferential duty rate, a 'Made in' labelling claim or a customer contract depends on the origin being correct
  • You are running the Trade and Customs Compliance programme and origin is one of its steps
  • A linked record needs this one to exist — a Label Verification or an environmental claim depending on the origin behind it

Do not use it for

  • Import Documentation Check, which checks that an inbound shipment has the documents customs and the regulator will ask for, not the underlying origin claim itself.
  • Export Documentation Check, which checks that an outbound shipment carries the correct classification and declarations, and consumes this record's claim rather than re-establishing it.
  • Dangerous Goods Shipment Declaration, which classifies, packs and declares a dangerous goods consignment, and has nothing to say about where the goods were made.
  • Customs Broker Instruction, which turns a cleared shipment and its evidenced origin into instructions a broker acts on, once this record already exists.
  • Anything outside KnowLogistics, which belongs in the workspace that owns that process.

Compliance mapping

Which FALCPA requirements does this satisfy?

The template follows the sequence of establishing and defending an origin claim — state it, evidence it, verify it, use it.

ClauseRequirementWhere it lands
19 CFR Part 134 (Country of Origin Marking)The origin marked on a product or its packaging must reflect the country determined under the applicable rules, not a supplier's unverified assertion.Header
19 CFR Part 102 / 19 CFR Part 182A claim of 'wholly obtained' or 'substantially transformed' must be tested against the specific rule for that material, not asserted generically.Header
19 CFR 134.1(b)Where the basis of the claim is substantial transformation, the processing that transformed the material must be described and evidenced, not just asserted.Evidence
19 CFR Part 163 (recordkeeping)The supplier declaration behind an origin claim must be signed, dated and cover the period the claim applies to.Evidence
19 CFR Part 182 (cumulation)Where materials from more than one qualifying country are combined, cumulation rules must be considered before a preferential claim is made.Verification
19 CFR Part 163 (recordkeeping)Origin evidence must be retained for the required period and reverified on any change to the supplier or process it depended on.Verification
FALCPA, 21 U.S.C. § 343(w)Where the material or product carries an allergen declaration, the label's claims — including any origin statement — must be accurate and consistent with the evidence behind them.Outcome

What it does not cover

  • Supplier Declaration Held marked Yes, which confirms a document exists, not that Declaration Signed And Dated or Covers The Current Period are also true.
  • Bill Of Materials Reviewed marked Yes, which was checked against a prior version, not the bill of materials for the current process and supplier.
  • Preferential Rules Of Origin Met marked Yes, which was answered against the general trade agreement, not the specific rule for this material's tariff classification.
  • Reverified On Supplier Change marked N/A, which assumes the supplier hasn't changed without checking the Supplier field against the last cycle.
  • Labelling Claim Supported marked Yes, which was answered before Origin Evidenced and Preferential Rules Of Origin Met were both confirmed, the wrong order to actually support a label claim.

Global

Country of Origin Verification requirements by country

Origin rules diverge between a marking requirement, a preferential trade claim and a food label's allergen and origin statement, and a claim that satisfies one rarely satisfies all three without separate checking.

United States

19 CFR Part 134 (Country of Origin Marking) and 19 CFR Parts 102/182 (rules of origin for preferential claims)

Marking origin correctly and claiming a preferential duty rate are governed by different rule sets, and passing one does not establish the other.

Basis Of The Claim has to be tested against whichever rule set the claim is actually made under — marking, or preference.

European Union

Union Customs Code, Regulation (EU) 952/2013, Articles 59–63 (non-preferential origin) and the relevant agreement's protocol of origin

Non-preferential origin, for marking and trade statistics, and preferential origin, for a reduced duty rate, sit under separate provisions of the UCC framework.

A material can be non-preferentially 'from' one country while failing the specific preferential rule needed for a lower duty rate on the same shipment.

United Kingdom

The UK's retained and negotiated rules of origin under the Taxation (Cross-border Trade) Act 2018

Since leaving the EU's common external rules, UK preferential origin determinations are made against the UK's own rules, not assumed identical to the EU's.

An origin verification carried over unchanged from an EU-facing process does not automatically hold for a UK-facing claim.

How to complete it

How to complete a country of origin verification, step by step

The fields deciding whether an origin claim survives an audit are the ones requiring judgement, not the ones with an obvious tick.

Which of the three bases the claim actually rests on

Basis Of The Claim forces a choice between wholly obtained, substantially transformed, and supplier declaration only. Defaulting to whichever option was used last time, rather than testing the current material, is where the claim starts to drift from the evidence.

Whether the bill of materials was reviewed for this version, not a prior one

Bill Of Materials Reviewed only supports the claim if checked against the composition currently in production. A supplier process change that doesn't touch the finished spec can still change the origin answer underneath it.

Whether preferential rules of origin and cumulation were tested together

Preferential Rules Of Origin Met and Cumulation Rules Considered are separate fields for a reason — a material can meet a simple origin test and still fail once inputs from a second qualifying country combine under cumulation rules.

Whether the origin claim was confirmed before it supported a labelling claim

Labelling Claim Supported should follow Origin Evidenced, not run in parallel with it. A label printed on the strength of an origin claim that later fails verification is a labelling defect, not just a customs one.

What auditors find

Most common country of origin verification findings

The same gaps recur across origin verifications, and each one turns a claim that looked complete into one that fails the first time someone outside the business tests it.

FindingClauseWhat fixes it
Basis Of The Claim answered Wholly Obtained with no Manufacturing Location Stated or Processing Steps Described completed19 CFR Part 134Require Manufacturing Location Stated and Processing Steps Described before Basis Of The Claim can be saved, whichever option is chosen.
Supplier Declaration Held marked Yes with Covers The Current Period left blank19 CFR Part 163Make Covers The Current Period a required companion to Supplier Declaration Held, not an independent field.
Preferential Rules Of Origin Met marked Yes with Cumulation Rules Considered marked N/A on a material combining inputs from more than one country19 CFR Part 182Prompt for a second-country input check before Cumulation Rules Considered can be marked N/A.
Reverified On Supplier Change marked N/A with Supplier changed since the last Declaration Date19 CFR Part 163Compare the Supplier field against the prior record's supplier automatically, and block N/A when they differ.
Labelling Claim Supported marked Yes with Origin Evidenced marked No in the same recordFALCPA, 21 U.S.C. § 343(w)Block Labelling Claim Supported from reading Yes while Origin Evidenced reads anything other than Yes.
Retained For The Required Period marked Yes with no retention location or date recorded19 CFR Part 163Capture where and until when the evidence is retained, not only that retention took place.

Case in point

Case in point: the origin claim that outlived its supplier

A converter sourcing printed film for food packaging verified origin against its long-standing supplier, recorded Basis Of The Claim as Substantially Transformed, and marked the record Complete. Eighteen months later the supplier moved the printing step to a different country to cut cost, without notifying the converter — only the raw film supply agreement changed on paper.

The gap surfaced when a customer's own supplier audit asked for evidence of the manufacturing location on file, and the paperwork described a process no longer true. The fix was structural: Reverified On Supplier Change is now checked against the Supplier field at every review, not only when someone remembers a supplier changed.

The template

The template, field by field

The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.

39fields
4 sections
Reference
LOG-039
Archetype
Record
Record ID
COO-2026-000
Scoring
Origins evidenced
Direction
High is good
Singleton
Yes
Basis
FALCPA
Links
Links Supplier Onboarding and Label Verification
Tags
Customs, Origin
Sections
4
Fields
39
Follow up fields
3
Repeating sections
0
Links out
7
Field typesOwn ID, generated on saveCase thread and parentPick list from a registryLinked to another templateFollow up, dashed outlineScored

Header

13 fields
Text

Record ID*

Generated on save

Auto sequence. Format COO-2026-000.

The record's own ID. Other templates point at this value.

Single Choice

Status*

Scored

Drives who this goes to next.

  • Planned2 pts
  • In progress2 pts
  • Complete3 pts
  • Deferred0 pts
  • Open0 pts
  • Closed3 pts
  • Overdue0 pts
Date & Time

Date and Time*

Users

Completed By*

Pick List

Site*

From FDN-001 Site NameFilter: Status is Active
Text

Site ID*

Linked

Format SITE-000.

Links to FDN-001 Site ID

Single Choice

Material

OptionalFrom FDN-006 Product Name
LabelsSleevesFilmCartonsLeaflets
Text

Substance Or Product ID

OptionalLinked

Links to FDN-022 Product Code

Single Choice

Supplier

OptionalFrom FDN-005 Vendor Name
Text

Origin Claimed*

Single Choice

Basis Of The Claim*

Wholly obtained, substantially transformed, or supplier declaration only.

Wholly obtainedSubstantially transformedSupplier declaration only
Date & Time

Declaration Date

Optional
Info

A Claim You Cannot Evidence

Origin drives duty rates, labelling claims and customer contracts. Claiming it without a supplier declaration behind it is a claim that fails at the first audit.

Evidence

6 fields
Single Choice

Supplier Declaration Held*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Declaration Signed And Dated*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Covers The Current Period*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Manufacturing Location Stated*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Processing Steps Described*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Bill Of Materials Reviewed*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator

Verification

6 fields
Single Choice

Consistent Across Documents*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Consistent With The Certificate Of Origin*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Preferential Rules Of Origin Met*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Cumulation Rules Considered*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Reverified On Supplier Change*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Retained For The Required Period*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator

Outcome

14 fields
Single Choice

Origin Evidenced*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Preferential Claim Made*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Single Choice

Labelling Claim Supported*

Scored
  • Yes2 pts
  • No0 pts
  • N/Aexcluded from denominator
Text

Label Verification ID

OptionalLinked

Links to QUA-089 Verification ID

Text

Environmental Claim ID

OptionalLinked

Links to ENV-056 Record ID

Date & Time

Review Date*

Single Choice

Action Required*

Scored

Raise the action record, then enter its reference here.

  • No2 pts
  • Yes0 pts
Single Choice

Priority

OptionalScoredShows if Action Required equals Yes
  • High0 pts
  • Medium1 pt
  • Low3 pts
Text

CAPA ID

OptionalLinkedShows if Action Required equals Yes

Format CAPA-2026-00000.

Links to FDN-014 CAPA ID

Users

Action Owner

OptionalShows if Action Required equals Yes
Users

Trade Compliance*

Signature

Signature*

Users

Technical*

Signature

Second Signature*

LOG-039 · record IDs look like COO-2026-000 · Links Supplier Onboarding and Label Verification

Open in Knowella

Run it with agents

From a document you fill in to a programme that runs itself

The form is the easy part. Catching a supplier change that should trigger reverification, and holding the evidence behind a claim together across duty, marking and labelling, is the work that actually slips.

KnowLogistics

Holds the verification against your material and supplier registers, and keeps the link to Label Verification and the environmental claim current as either changes.

KnowQuality

Owns the Label Verification record this feeds, so a claim marked Labelling Claim Supported is checked against the label actually printed, not just the origin paperwork.

KnowComply

Keeps the applicable rules of origin and marking regulations current per destination, and flags where a preferential claim needs testing against a rule this record hasn't checked.

Ella
Ella

Watches for a supplier or process change that should trigger reverification, rolls exceptions into one view, and holds every write for approval before it touches a record.

This template lives in KnowLogistics — supply chain execution. Inbound, outbound, inventory, yard, claims, supplier lifecycle and customs.

Glossary

Country of Origin Verification definitions and key terms

Wholly obtained
An origin category for goods entirely grown, mined or produced in a single country with no material inputs from elsewhere — the strongest, simplest basis for a claim.
Substantial transformation
An origin test asking whether processing in a country changed a material's name, character or use enough to give it a new origin, distinct from wherever its raw inputs came from.
Cumulation
A rule under some trade agreements allowing materials or processing from more than one qualifying country to be combined and still count toward a preferential rule of origin.
Certificate of Origin
A document, often issued or countersigned by a chamber of commerce, certifying the country in which goods were produced — used to support marking and preferential duty claims.
FALCPA
The Food Allergen Labeling and Consumer Protection Act, a US law requiring major food allergens to be declared on a label in plain language — relevant here because a failed origin claim puts the rest of the label, including its allergen declaration, in question.

FAQ

Frequently asked questions about country of origin verification

What is the country of origin verification template based on?+

It draws on US country-of-origin marking and rules-of-origin provisions (19 CFR Parts 102, 134 and 182) for the duty and marking side, and FALCPA for the labelling-accuracy side, since a failed origin claim puts the label's other claims in question.

What sections does the country of origin verification contain?+

There are four sections — Header, Evidence, Verification and Outcome — holding 39 fields, 29 required, running from the claim itself through to whether it supports a preferential duty or labelling claim.

How often is a country of origin verification run?+

It is run when a new material is introduced and again on any change — a new supplier, manufacturing location or process. It is not a periodic review; it is triggered by the event that could change the answer.

Which programme does the country of origin verification belong to?+

It is part of Trade and Customs Compliance, alongside the Import and Export Documentation Checks it feeds — declarations you can defend, filed in your name and checked after filing.

How is a country of origin verification scored?+

Scoring is origins evidenced, high is good, based on fields actually answered. A record can score well and still rest on a supplier declaration alone if Basis Of The Claim isn't checked alongside the score.

Can the country of origin verification template be changed?+

Yes. Every field, option, score and conditional rule is editable, and its links to Label Verification and the environmental claim record come with it. Most teams install it as-is, run a cycle, then adjust.

Keep going

Related templates and programmes

Industries this is written for

Siddarth Singh

Written and reviewed by

Siddarth Singh

Founder & Chief Executive Officer, Knowella

Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.

  • Certified Safety Professional (CSP), Board of Certified Safety Professionals
  • MBA, University of Chicago Booth School of Business
  • MS and BS, The Ohio State University, Industrial and Systems Engineering
  • Six Sigma Black Belt
Verify with BCSP →

Sources and last review. Reviewed 16 August 2026 against:

  • 19 CFR Part 134 — Country of Origin Marking
  • 19 CFR Part 182 — USMCA Uniform Regulations (rules of origin)
  • 19 CFR Part 163 — Recordkeeping
  • FALCPA — Food Allergen Labeling and Consumer Protection Act (21 U.S.C. § 343(w))
  • Union Customs Code, Reg. (EU) 952/2013, Arts. 59–63 — non-preferential origin

This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.

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