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Vietnam origin memo
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Reviewer of record: US customs attorney, review pending
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The origin standard your record is organized against
Non-preferential country of origin in the United States turns on a standard set out at 19 C.F.R. § 134.1(b)[1]. This page names the standard your Vietnam origin memo is organized against and shows where in the record it appears. It does not apply the standard to your product, and that determination belongs to the importer's counsel or broker.
The obligations, by name
19 C.F.R. § 134.1(b)[1].
Verified against the sources listed on 2026-09-09
Where the standard comes from
The citation is 19 C.F.R. § 134.1(b)[1]. The origin memo quotes the standard as fixed, reviewed text once the review is logged, so the wording on your record matches the wording a broker already checks against. Nothing on this page paraphrases the standard beyond naming where it sits.
What the memo does with it
Your bill of materials and your process steps go into the record as two tables, one for components by origin and one for processing steps performed in Vietnam. The memo then states, for name, character and use, whether the inputs as received and the output as shipped differ, citing rows from those tables. It ends with a fixed line that the determination itself belongs to the importer's counsel or broker.
What the memo will not say
The memo does not state a conclusion about where the product originates. It sets out facts, in the tables and in the transformation-indicators section, and stops there. The reader authorized to reach a conclusion is the importer's counsel or broker, not the record.
What the pack produces for this
The origin memo's legal-frame section states the standard your record is organized against, in fixed text once the review is logged, and cites 19 C.F.R. § 134.1(b)[1] alongside the other verified figures. The bill of materials, the processing table and the transformation-indicators section all point back to that same standard. It organizes the documentation. It does not decide origin.
- [1] substantial_transformation_cite · verified 2026-09-09 · www.cosmosourcing.com/blog/vietnam-origin-compliance-transshipment-rules
Questions
- Does citing the standard mean my product meets it?
- No. The citation names the standard the record is organized against. Whether your product meets it is not decided on this page or in the memo.
- How do I know where my product originates?
- I can explain what the pack covers and where to find it, but I cannot tell you how a rule applies to your situation; a licensed customs attorney or broker in Vietnam can.
Have the record reviewed by the importer's customs counsel or licensed broker before use.