US Compliance · COO Labeling

Country of Origin Marking for Knitwear Imports to the USA

'Made in Turkey' on a care label isn't optional — it's a federal requirement. Here's what the rules actually say, and what you need from your manufacturer to stay compliant.

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Under 19 CFR Part 134 and the Textile Fiber Products Identification Act (TFPIA), every article of clothing imported into the United States must be marked with its country of origin — in a conspicuous, legible, and permanent manner — so that the ultimate purchaser can identify where the garment was made. For knitwear imported from Turkey, this means a "Made in Turkey" (or "Made in Türkiye") label that survives normal use and care. Getting this wrong exposes the importer of record to marking violations, CBP holds, and potential penalties.

Disclaimer: This is general information, not legal advice. Country of origin rules are technical and fact-specific. Confirm your labeling obligations with a licensed customs broker or trade attorney.

Premium knitwear yarn — certified supply chain, Kiwi Giyim Turkey — Premium yarn cones sourced from OEKO-TEX certified Turkish and Italian spinners

What Determines Country of Origin for Knitwear?

For textile and apparel products, CBP uses the "yarn-forward" rule under US trade preference programs — meaning the garment's origin is determined by where the yarn was formed into fabric and cut/sewn into the final garment. Under the general "substantial transformation" test (applicable for duty and marking purposes where no preferential program applies), a garment is considered a product of the country where it underwent its most significant manufacturing operation.

For Turkish-knitted sweaters made from imported yarn: the flat-knitting and garment finishing in Turkey typically constitute the substantial transformation. The garment is "Made in Turkey" even if the yarn itself was spun elsewhere — provided the knitting and assembly occur in Turkey. If a Turkish factory imports pre-made fabric panels from another country and only sews them, the analysis becomes more complex. At Kiwi Giyim, yarn is knitted into garment form on-site — the origin is Turkey, clean and documentable.

Label Requirements: What CBP Expects

Permanent and Conspicuous

The COO marking must be visible, legible, and designed to remain on the garment through normal retail and consumer use. Hangtags alone don't satisfy the requirement — it must be on the garment itself (typically the care label).

Care Label Integration

The country of origin statement is most commonly combined with the care/fiber content label. CBP and the FTC expect the COO to appear on the same label as fiber content, or on a separate permanently attached label in a standard location (neck, side seam, or waistband).

Exact Wording

"Made in Turkey" is the standard form. "Product of Turkey" is also acceptable. Abbreviations ("Turk.") are generally not. CBP has published guidance on acceptable country name formats — confirm with your broker if you use any non-standard phrasing.

English Required

The marking must be in English on garments sold in the US. Bilingual labels (e.g., English + Turkish for export markets) are fine, but English must be present and equally prominent.

Documentation Your Commercial Invoice Must Include

Beyond the physical label, the commercial invoice for US Customs entry must include a country of origin statement. CBP's regulations require the invoice to declare where each article was produced. A typical invoice line reads: "Country of origin: Turkey" for each HTS line item. Some importers also request a separate Certificate of Origin from the manufacturer — while Turkey doesn't have a preferential trade agreement with the US (so there's no preference-claiming certificate), a standalone COO signed by the factory and notarized or legalized can support a customs audit if CBP questions the origin claim.

COO Compliance Checklist

Confirm the factory's production process

Verify that knitting and garment completion occur in the declared country. A factory that buys pre-knitted panels from a third country and only attaches labels is not a Turkish-origin producer.

Approve the care label before bulk production

Send a sample to your customs broker or compliance team for label review before the factory prints 5,000 units. Retroactive relabeling is expensive and may not be permitted depending on how the error is caught.

Include COO on the commercial invoice

Each HTS line item on the invoice should state "Country of origin: Turkey." Your customs broker will review the invoice before filing the entry summary.

Request a factory-signed COO declaration

For audit protection, get a written statement from the manufacturer on company letterhead confirming the production process, yarn sources, and country of origin. Keep this on file for at least five years.

Label the outer cartons

Master cartons and inner boxes must also be marked with the country of origin. CBP inspects packaging as well as garments during examinations.

Need a Factory That Makes Documentation Simple?

We knit in Gaziantep, Turkey from start to finish — and we supply the documentation that makes "Made in Turkey" easy to defend at the border. Let's talk about your order.

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