How Z2Data Helps You Track Country of Origin to Manage Your Risk

Article Highlights:

• If there’s one data point that companies need to know to understand their tariff exposure—and what potential mitigating actions are available to them to reduce that exposure—it’s country of origin. 
• The term country of origin, or “COO,” refers to the country where a particular article was originally manufactured and produced. The COO classification on imported goods triggers specific tariffs, fees, and other customs rules. 
• Z2Data helps businesses track their COO by giving them instant access to the COO on over one billion off-the-shelf components, including passives, semiconductors, connectors, and more. 
• Because users can see all the COOs of a given MPN in the Z2Data database, importers may have the opportunity to leverage those insights to shift their supply chains to factories based in countries with lower tariff rates. This type of knowledge is not always freely provided by suppliers, and accessing it represents the first step toward working with manufacturers to create more favorable supply chains. 

The past year has transformed the way that importers and original equipment manufacturers (OEMs) think about sourcing and supply chains. In the first few years of the decade, many businesses were primarily focused on shifting away from geopolitical risks. This was embodied by the widely discussed China+1 sourcing strategy—the idea that companies needed to build alternative manufacturing bases outside of China, because of the risks that excessive dependence on the rival nation posed. During the height of China+1, businesses were shifting sourcing to countries like Vietnam, Thailand, Malaysia, and India, embracing nations with growing manufacturing hubs and eager, capable workforces. 

But 2025 has changed all that. As we enter the fourth quarter of the year, businesses are predominantly focused on the tariffs and other trade restrictions imposed by the Trump administration. In case you’ve lost track, the U.S. now has substantial tariffs on a number of key manufacturing countries, including: 

But 2025 has changed all that. As we enter the fourth quarter of the year, businesses are predominantly focused on the tariffs and other trade restrictions imposed by the Trump administration.

• China: 30% tariff currently implemented, along with additional reciprocal tariffs delayed until November 2025.
• European Union: 15% across-the-board tariff, plus a 50% sectoral tariff on steel, aluminum, and copper imports. 
• India: 25% reciprocal tariff, plus an additional 25% punitive tariff for purchasing Russian oil.
• Vietnam: 20% across-the-board tariff.

With importers paying an additional 15%, 20%, or even 50% to import products, parts, and subassemblies, it’s no surprise that the current tariff landscape has supplanted other factors as the preeminent risk variable in global supply chains. And if there’s one data point that companies need to know to understand their tariff exposure—and what potential mitigating actions are available to them to reduce that exposure—it’s country of origin. 

What Is Country of Origin (COO)?

The term country of origin, or “COO,” refers to the country where a particular article was originally manufactured and produced. A commodity’s country of origin is important because of its ramifications for trade and the importation process. The COO classification on imported goods triggers specific tariffs, fees, and other customs rules. 

In many cases, goods are now manufactured in multiple countries. Semiconductors, for example, may be designed in one country, fabricated in another, and sent to a third nation for assembly and packaging

In instances where there are multiple manufacturing locations, the U.S. classifies COO based on the final location where a “substantial transformation” took place. As longtime trade lawyer John M. Peterson noted in a recent paper in the Vanderbilt Law Review, “Historically, the Courts have taken the position that a good originates, for marking purposes, in the last country where it underwent a ‘substantial transformation’ prior to being imported into the United States.”

In instances where there are multiple manufacturing locations, the U.S. classifies COO based on the final location where a “substantial transformation” took place.

What Does “Substantial Transformation” Mean?

Substantial transformation is an official term that refers to a substantive change to an article or good. “Substantial transformation means that the good underwent a fundamental change in form, appearance, nature, or character,” the International Trade Administration explains. “Additionally, this change adds to the good’s value at an amount or percentage that is significant, compared to the value which the good (or its components or materials) had when exported from the country where it was first made or grown.”

In other words, in order to be characterized as a substantial transformation—and therefore trigger a new country of origin—the change must fundamentally alter the product and enhance its value in a meaningful way. 

In other words, in order to be characterized as a substantial transformation—and therefore trigger a new country of origin—the change must fundamentally alter the product and enhance its value in a meaningful way. 

Why Is COO So Important for Importers in 2025? 

For U.S. businesses, understanding the COO of their imports is now a critical aspect of diligent supply chain risk management (SCRM). There are a handful of reasons that country of origin has emerged as a top priority in 2025. 

• Determining Tariff Rates: The first and most obvious reason that COO is such a crucial data point in 2025 is due to the new tariff landscape. The Trump administration has implemented tariffs on countries all over the world, including significant rates on some of the U.S.’s largest trading partners. Businesses that want to understand their tariff responsibilities, and how much they’re now paying Customs and Border Protection (CBP) to import specific commodities and parts, need to be aware of the COO of their imports. 

• Understanding Geopolitical Tensions and Tariff Risks: Everyone who has been paying attention to the Trump administration’s trade actions over the past year knows just how dynamic—and often unpredictable—these developments have been. Because of this, companies looking to maintain effective risk management and tamp down onerous costs need to know more than just the current tariff rates. They should also be aware of where their greatest tariff risks lie. For example, while the current tariff rate on China may be 30%—relatively modest when compared with rates imposed on the nation earlier this year—any awareness of the broader geopolitical context suggests that figure is only temporary. Knowing the COO of their imports helps companies identify where their exposure to potential future tariff increases may be located. 

• Identifying Cost Differences Between Countries: While U.S. tariffs on the vast majority of countries have increased from 2024 levels, these levies are far from evenly distributed. All goods covered under the U.S. Mexico Canada Agreement (USMCA), for example, are exempted from tariffs and thus currently have a 0% duty rate. Articles imported from India, on the other hand, are currently subject to a 50% tariff rate. Firms that can examine the full picture of their countries of origin will be able to pinpoint large disparities like this, potentially creating opportunities to modify sourcing and shed hefty duty costs. 

How Does Z2Data Help Businesses Track COO and Manage Related Risks?

Z2Data helps businesses track their country of origin by giving them instant access to the COO of over one billion off-the-shelf components, including passives, semiconductors, connectors, and more. COO data is provided on a part’s profile page alongside other critical information, including manufacturing locations, REACH and RoHS compliance statuses, available crosses, and other key parametric details. 

Teams can use Z2Data to quickly identify the COO of a given single manufacturing part number (MPN) across one or multiple products. Simply upload a BOM, and Z2Data analyzes the MPNs against its database to return COO information. For teams responsible for sourcing COOs for existing or new products, Z2Data can save hours of manual research and supplier outreach. All COO information is validated by AI and human researchers before being added to the database, ensuring accuracy.

In Cases of Components with Multiple MPNs 

In many cases, an MPN might contain multiple COOs. This is because some manufacturers make specific components in multiple factories in different countries. A foreign supplier may produce a certain number of their capacitors in China, Japan, and Mexico, for example. Why does this matter for U.S. importers and OEMs? Because understanding all the COOs of a given component is an actionable insight, giving businesses information that can be leveraged to their advantage. 

Z2Data captures these nuances by showcasing the multiple COOs of a given MPN on its details page. On a full product BOM, you can also see all COOs by component—including single-country dependencies—helping you identify parts with the riskiest COO exposures. This allows teams to effectively see where their parts are—or could be—manufactured, details that can be critical when it comes to managing tariff risk.

For example, if a Tier 1 supplier is manufacturing a part in both China and the EU, the U.S. importer should want to do everything in their power to ensure that the specific parts they’re ordering are being shipped from the EU (where the tariff rate is 15%, half that of China). Z2Data can help companies identify this information on their parts and take actions to mitigate risks and costs associated with certain COOs. 

Determining COO and COD for Semiconductors

Semiconductors have a unique manufacturing process, and Z2Data shows this in a part’s profile. Semiconductors are often fabricated in one location, which is referred to as the country of diffusion (COD). Then they are transported to another facility for IC assembly, which is designated as the country of assembly (COA). 

While the U.S. has historically used the COA—which would technically function as the final location of substantial transformation—as the official COO for customs purposes, that rule has evolved in the 2020s. Now, the country of diffusion is generally considered to be the country where the part originated, and therefore the official COO designation for duty determinations. 

But there may be some “tariff optionality” with respect to a semiconductor’s COO/COD/COA. Companies that have more sourcing and origin data on their imported semiconductors may be able to leverage the information to their advantage. This “tariff optionality” is something that many U.S. importers are continuing to explore, as they refine their understanding of the parameters within the current tariff regime and what “tariff engineering” strategies may be at their disposal.

Z2Data helps customers navigate these rules by providing as much manufacturing location data as possible for chips. In the Z2Data platform, each semiconductor MPN has:

• Country of Origin
• Country of Fabrication
• Country of Assembly

Depending on how CBP and the federal government are interpreting COO, the country of origin could be considered either the country of assembly or the country of diffusion. CBP judges regularly hear arguments from importers seeking to justify their COO claims, and any precedents set in these rulings can shift how COO is applied. Due to this fluidity, being able to readily access reliable data on both interpretations is a meaningful resource for companies looking to achieve supply chain resilience.

Let Z2Data Help You Use COO To Your Advantage

In an era in which international trade is heavily regulated and the U.S. government is taking in upwards of $30 billion a month in tariff revenue, knowing where your imports are coming from matters. But COO data isn’t just static information, either, figures to be passively added to spreadsheets detailing overhead costs. Companies can actually use country of origin intelligence to their advantage, acting on insights to modify supply chains and reduce costs. Z2Data can help.

Businesses can use the COO intelligence in Z2Data’s parts database to understand both their current tariff responsibilities and looming tariff risks (that is, parts sourced from countries vulnerable to new or increased tariff rates in the near future). And the SCRM tool’s utility goes beyond that, too. Because users can see all the COOs of a given MPN in the Z2Data database, importers can leverage those insights to shift their supply chains to factories based in countries with lower tariff rates. This type of knowledge is not always freely provided by suppliers, and accessing it represents the first step toward working with manufacturers to create more financially favorable supply chains. 

Given the cost burdens embedded in today’s global manufacturing landscape, every edge—substantial, marginal, and everything in between—matters. Z2Data’s multifaceted COO data provides the insights and context to help businesses obtain that edge. To learn more about Z2Data and how its COO insights can help your organization understand its tariff exposure and potential mitigating measures, schedule a free trial with one of our product experts.