Goods produced in Hong Kong must now be labeled “produced in China”

On July 14, President Trump signed an Executive Order on Hong Kong Normalization that makes imported goods produced in Hong Kong now considered to be products of China. U.S. Customs and Border Protection (CBP) issued regulations Aug. 11 implementing these changes, stating that imported goods from Hong Kong may no longer be marked to indicate ‘‘Hong Kong’’ as their origin, but must be marked to indicate ‘‘China.’’ The regulations initially provided a shorter-than-expected 45-day transition period, but CBP subsequently extended this period 45 days more, until Nov. 9, 2020. CBP also subsequently clarified in frequently asked questions that the “Made in China” U.S. marking rules do not subject Hong Kong goods to Section 301 tariffs, because such Hong Kong goods “should continue to report International Organization for Standardization (ISO) country code ‘HK’ as the country of origin when required.”