The short answer

US law — 19 USC 1304, with the working detail in 19 CFR Part 134 — requires an origin mark on imported goods, and for jewelry Customs generally looks for it on the article rather than somewhere in the packaging. CBP can answer a missing mark with a marking duty set at 10 percent of value, or with seizure. The legal duty sits with the importer of record; applying the mark physically sits with whoever builds the goods.

The three places a mark can live

A hang tag, printed and tied on at the point you designate. A small tag folded over the chain beside the clasp. A stamp or engraving set inside a ring band, or onto a small plate. Which route clears your product is a judgment call for the importer and the broker to make together — CBP has the last word — and small items are exactly where that call gets close. Execution is the factory's half of the job: apply the mark at the agreed point, in the agreed wording, and confirm it at packing.

The adjacency rule behind "Designed in ..."

Locality language sells — "New York Studio", "Italian Style", "Designed in California" — and it is lawful, provided one condition is met. 19 CFR 134.46 closes the gap: a place name that is not the origin, appearing anywhere on the product or its packaging, obliges you to print the real origin right beside it. A card reading "Designed in California" therefore also has to read "Made in China", on that same panel. A neighbouring line satisfies the rule; the reverse of the card does not, and neither does a footnote on the website.

What a detention costs

Detention opens a response window, usually 30 days. Release commonly requires a bond from the importer, reported in the $250 to $5,000 band. A file nobody attends to can end in abandonment — no goods, freight already spent, a customer still waiting. The figures belong to CBP to confirm and they do move; the schedule damage is the expensive part. Surrounding customs questions — who is the importer of record, what duty applies — are worth settling before freight is booked, as set out in our notes on importer of record under DDP vs DDU and 2026 tariffs.

Who decides, who executes

The compliance call is the importer of record's to make, and on a factory-direct order that is normally you. DDP shifts delivery to the seller, and the importer-of-record role — with the marking duty attached — shifts with it. What a factory can do is mechanical: print, tag or engrave to instruction, and include the declaration set that ships with the goods, which our compliance documents guide lists in full. What no factory can do is carry the legal obligation on your behalf.

What the purchase order should specify

  • The wording, exactly — "Made in China".
  • The position, named component by component: hang tag, chain tag, inside the band.
  • The technique: print or engrave.
  • Every locality phrase planned for cards or packaging, each with its origin line next to it.
  • Artwork signed off before production starts, not after.

An illustrative scenario

The following is an illustrative scenario, not a claim about a named customer or a published Qiuqiu Atelier order.

A brand sent its first wholesale order to a US fulfillment warehouse with the origin appearing only on the poly bag and the carrier label, on the assumption that the retail packaging was what mattered. The entry was detained, and the response window burned while photographs and explanations crossed eight time zones. The material fix was trivial — a small chain tag per piece and one origin line added under the "Designed in New York" copy — and the schedule cost was not, landing three weeks into the selling season. The reprint and the following container both left with the marking specified in the purchase order. Neither drew a question.

Where our sample room fits

Marking is a short conversation when it happens early: what wording, which component, printed or engraved. Our private-label packaging work regularly carries buyer-specified tag and card text, including origin lines placed beside locality copy. The financial side of the entry — duty, valuation, brokerage — is mapped in the import duties guide and the landed cost walkthrough.

To have the marking built into the quotation rather than the rework, send the destination, the product type and the exact wording through the Qiuqiu Atelier quote form.

FAQ

Is a hang tag sufficient, or does the mark have to be engraved?

Either can be right, and it depends on the piece. For jewelry, tags and engraving are the two routes that work in practice, and CBP's test is whether the mark reaches the person who buys the piece. Where the item is very small or the construction unusual, get the answer in writing from CBP or your broker before production rather than after a hold.

How close must the origin line sit to "Designed in ..." wording?

Close enough to be read together. A line of separation is fine; a different panel is not. If the layout leaves no clean space beside the design credit, move the credit rather than shrink the origin.

Who is legally responsible when a shipment arrives unmarked?

The importer of record — normally the US-side buyer on a factory-direct program. That is also why the instruction belongs in the purchase order with an artwork approval step: the factory can execute only what the order describes.

What does a CBP detention cost while it is being resolved?

Direct costs: a bond in the $250 to $5,000 range and the time inside a response window that commonly runs 30 days. The larger cost is usually the calendar — storage, a missed launch, a customer waiting on goods that cleared late. Confirm current figures with CBP or your broker.

Can the factory apply the marking after production instead of before?

It can, and it is the expensive order of operations. Printing, tagging or engraving during the build is part of production; adding marks to finished goods means unpacking, rework and repacking, with a fresh quality risk at each step. Specify it up front and check it as the goods are packed.