Greetings:

Our company is currently reviewing its compliance with the Country of
Origin requirements administered by the US International Trade Commission.

We have been told from a consultant that we need to improve our program.
Based on these recommendations, we have created two phases.

Phase 1 -  Add Country of Origin identifiers for all shippable products
including end-use instrumentation and service kits.  This identifier would
be in the form of a marking.

Phase 2 - Add Country of Origin identifiers on all piece parts which
make-up the instruments.  For example, screws, tubing, power supplies, etc.
This identifier would be an update to our documentation data base.


Although there seems to be so some merit for Phase 1, Phase 2 seems
extensive.  We use more than 30,000 parts in our product lines.

How do most companies deal with  this requirement?

Has anyone been audited to this requirement?  How extensive was the audit?

Can anyone provide any background as to the intent of this regulation?

All opinions are appreciated.

Regards,

Mark Sweeny
Manager, Compliance Engineering
Applied Biosystems



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