Friday, March 06, 2015

Ladies and Gentlemen: Pitcairn Island Honey

Because I have some of the best and well-traveled readers (and their relatives) in the compliance business, I have received a picture of a Pitcairn Island country of origin label. An anonymous reader had this jar of honey in a cabinet.


So, compliance pros, what do you think of the marking? Does "Pitcairn Island, South Pacific Ocean" satisfy the U.S. Customs and Border Protection requirement for country of origin marking?

Let me know what you think in the comments.

3 comments:

MIKE S. said...

The Pitcairn Islands (evidently there are four of them) comprise a British Overseas Territory, according to the official website of the Pitcairn Islands (www.pitcairn.pn). The guidance of 19 CFR 134.1(a) tells us that the Pitcairn Islands are to be considered a country unto themselves. But the language of 134.45(d) gives CBP the discretion to reject the label on the honey jar if it feels the name is not sufficient to inform the ultimate consumer. I would guess that few people know anything about the Pitcairn Islands, let alone that they’re under UK rule, so as a hedge against a marking notice I think it would be prudent if “South Pacific Ocean” was replaced with “a British Overseas Territory”.

Larry said...

That sounds like prudent advice. That said, I don't think that "Pitcairn Island, South Pacific Ocean" is necessarily a violation. It is true and does not appear to be confusing in the way that "Jersey" might be without further clarification.

MIKE S. said...

But what if you're an Argentine who wants nothing to do with Britain? Identifying the islands as a British Overseas Territory would seem more true to the intent of marking.