Could Your Goods Pass the US Origin Test?

US Substantial Transformation Rules for UK & EU Exporters

ITM Specialist Trade Briefing | Live Online

13 October 2026 | 10:00am
90 minutes including Q&A
£100 + VAT per delegate

Do your UK or EU origin assumptions stand up to US Customs scrutiny?

For UK and EU businesses exporting to the United States, understanding origin is becoming increasingly important — particularly where supply chains include Chinese-origin materials, components or sub-assemblies.

The US substantial transformation test is not the same as the origin rules that UK and EU businesses may already be familiar with.

A product can potentially satisfy a UK or EU origin test while failing to meet the US test.

With increased attention on transshipment and supply-chain routing, businesses need to understand how US Customs and Border Protection (CBP) assesses substantial transformation — and how to document and defend their position.

This specialist 90-minute briefing is designed to give you a practical understanding of the CBP test, using real CBP rulings and worked examples relevant to UK and EU supply chains.

What will the session cover?

1. The US Dictionary
Why UK/EU value-added and tariff-shift approaches do not tell you whether your goods meet the US substantial transformation test — and what CBP actually looks at.

2. Building Your Origin Proof Pack
How to document the manufacturing story behind your product and build an evidence base around name, character, use and the essence of the product.

3. Three Recent CBP Rulings
A practical look at three rulings involving UK and EU supply chains:

N360870 – IGBT module: UK success
N351276 – Wire drawing: UK failure
N357106 – Track shoes: Italy success

What made the difference in each case?

4. Heat Treatment & Assembly
Which manufacturing processes may genuinely contribute to substantial transformation for metals, electronics and chemicals — and which processes CBP has consistently regarded as insufficient.

5. Detective Border Risk
What the newly operational CBP AI Detective Border means for supply chains involving third-country processing, including the importance of routing patterns, dwell times, product flows and production capacity.

6. Your Monday Morning Checklist
Five practical actions you can take immediately to assess and strengthen your US origin position.

Who should attend?

This briefing is particularly relevant to:

UK and EU manufacturers exporting finished or semi-finished goods to the US where Chinese-origin inputs or components form part of the product
Supply chain and procurement teams restructuring sourcing away from China and relying on third-country processing
Customs and trade compliance managers who need to understand how the US substantial transformation test applies to their products
Senior management teams responsible for US market access, supply-chain decisions and trade compliance risk

Why attend?

This is not a general overview of US trade policy. It is a practical practitioner briefing focused on the test CBP applies, the rulings that illustrate how it works and the steps businesses can take to document and defend their US origin position.

You will leave with a clearer understanding of:

How the US substantial transformation test differs from UK/EU origin approaches
Which aspects of your manufacturing process are likely to matter
Why apparently straightforward operations may not be enough
What evidence you should be retaining to support your origin determination
How recent CBP rulings may apply to your own supply chain
What actions you should take to assess your exposure

Your presenter

Douglas Mackay | Senior Customs, Trade & Indirect Tax Adviser

Douglas has more than 40 years’ international customs compliance experience, including former Director of Customs and VAT for a Tier 1 automotive manufacturer across 14 Asia Pacific plants, Senior Adviser at KPMG China and PwC China, and participation in the WCO Technical Committee on Customs Valuation.

He has presented internationally on substantial transformation rules, customs valuation and trade remedies enforcement.