More Coffee Please: CBP Rules that Coffee’s Country of Origin is Determined by Where Beans are Roasted — Not Where Raw Beans Actually Originate

Seyfarth Synopsis: U.S. Customs & Border Protection recently issued a Final Determination that the coffee roasting process “substantially transforms” raw coffee for purposes of country-of-origin determinations and U.S. Government “Buy American” regulations. This clear new guidance should help corporations and their executives avoid civil, administrative, and criminal legal exposure as President Trump fulfills a campaign promise to crack down on illegal trade.

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