Hidden Traps in US Re-export Trade: 90% of Businesses Fail on These 3 Points

Mr. Lian recently encountered a troublesome issue: a batch of goods transshipped to the United States through a third country was detained by customs due to missing technical documents, resulting in a loss of over $100,000. Mr. Lian electronic accessories, despite bearing compliant labels, were returned due to differences in testing standards. Behind these cases lie the complex and easily overlooked technical requirements of US re-export trade. This article will unveil these key rules to help you avoid "compliance minefields."

I. Technical Barriers in Re-export Trade: More Than Just a Paper Game

The US technical review of re-exported goods focuses on three dimensions:

• Origin Labeling: Even if transshipped through a third country, the product itself or its packaging must indicate the true country of origin. Vague labeling may trigger a "country of origin washing" investigation.
• Testing and Certification: Certifications such as FCC (for electronic products) and FDA (for food and medicine) require original reports. Certificates issued by third countries may require supplementary testing.
• Material Traceability: For chemical and textile products, complete supply chain documents from raw materials to finished goods must be submitted. Processing activities in the transit country also need to be recorded.

II. Three Major Details Often Overlooked

1. Labeling Language Trap: English labels must include mandatory content such as product composition and warnings. Spanish labels may be an advantage in certain states (e.g., California).

2. Data Storage Requirements: If electronic products are modified in a transit country, the memory data format must comply with US standards (e.g., date display in MM/DD/YYYY format).

3. Packaging Environmental Standards: Wooden packaging must undergo ISPM15 heat treatment. Cushioning materials added in the transit country must comply with EPA heavy metal restrictions.

III. Practical Advice from Zhongmaoda Experts

Based on the experience of Zhongmaoda's trade compliance team, the following actions are recommended:

• Establish a Re-export Technical Archive: Consolidate a comparison table of standards differences across the country of origin, transit country, and the US.
• Conduct Mock Customs Clearance in Advance: Obtain advance rulings through the Ruling Request function on the US Customs website.
• Make Good Use of Free Trade Agreements: When transiting through Canada or Mexico, USMCA provisions can be invoked to simplify certain testing procedures.

Conclusion: Technical Compliance is a New Competitive Advantage

As global supply chains continue to be reshaped, technical compliance in re-export trade has shifted from a cost item to a value creation point. Have you encountered customs clearance obstacles due to technical details? Share your experiences, and let's explore smarter solutions together.