Confusion existed as to whether United States Department of Homeland Security, Customs and Border Protection (CBP) regulations, Code of Federal Regulations (C.F.R.) Title 19, required permanent “country of origin” marking (e.g., “Product of Germany,” “Made in China”) on all kegs imported or sold into the United States. The Brewers Association (BA) sought clarification on this matter in the form of an official ruling from CBP.
The BA has received information that CBP has ruled that all stainless steel beer kegs imported into the United States, whether imported empty or filled, must be marked with their country of origin as “legibly, indelibly and permanently” as the nature of the article permits. See CBP Ruling N284767.
The Performance Guidelines for Refillable Kegs has been updated to reflect this ruling. The legal requirement to put country of origin on kegs imported into the U.S. will be noted in both Purchasing and Procurement, section 4 and Regulatory and Safety, section 6 of the guidelines. Additionally, the pertinent code itself will be listed in the reference section of the resource. These updates will strengthen the existing recommendation to trace all material used in the construction of refillable beer kegs to the point of origin.
The BA will be implementing a policy requiring all companies who exhibit stainless steel kegs at Craft Brewers Conference & Brew Expo America® to sign and date a document that certifies that any and all stainless steel beer kegs that are imported into the U.S. and that exhibitors use at any event hosted or sponsored by the Brewers Association, will be properly marked in accordance with CBP’s country of origin marking requirements.