Country of Origin Guidelines
Why Country of Origin Matters to Us
At Wolf & Badger, we're proud to be a certified B Corp. That means we care deeply about fair, ethical and transparent supply chains. While assigning a Country of Origin (COO) is a legal customs requirement, it's also a key part of building trust with customers and maintaining the integrity of your supply chain.
When you set a COO for your product, we ask that you do so accurately and transparently. Where possible, please also consider highlighting:
- Where was your product assembled
- Where key materials were sourced, especially if they come from communities known for artisanal, traditional, or vulnerable labour
This supports our shared mission to create a fairer, more responsible global marketplace.
How to Assign Country of Origin Correctly
A product’s Country of Origin is typically determined by one of two criteria:
- Where the product was wholly obtained or produced
- Where the last substantial transformation took place
If a product is entirely made in one country from materials sourced in that same country, the COO is straightforward.
However, if materials come from multiple countries and the product is assembled, altered, or packaged elsewhere, things can get more complex. In these cases, we follow the substantial transformation rule.
What Is "Substantial Transformation"?
Substantial transformation is a principle used in international trade. It means a product’s COO is the country where it gains a new form, function, or character through manufacturing or processing.
Example:
A UK brand imports Italian leather and turns it into shoes in Portugal.
Portugal is the COO because the leather is cut, stitched, and made into a new product there.
If those shoes are then packaged or labelled in the UK, the COO remains as Portugal because packaging does not change the product's essential character.
What Does Not Count as Substantial Transformation?
The following do not qualify as substantial transformation:
- Repacking or relabelling
- Simple assembly (e.g. screwing or glueing pre-made components)
- Cleaning, sorting, or ironing
- Dilution or mixing that doesn’t alter the product’s nature
Examples in Fashion and Lifestyle
| Product | Components | Final Assembly Location | Country of Origin |
|
Cashmere sweater |
Yarn from Mongolia |
Knitted in Italy |
Italy |
|
Handbag |
Leather from Spain |
Made in Portugal |
Portugal |
|
Skincare serum |
Ingredients from various countries |
Blended and bottled in France |
France |
|
Sunglasses |
Pre-made frames and lenses from Italy |
Assembled in Germany |
Italy |
|
Ceramic vase |
Made and fired in Poland |
Branded and packaged in the UK |
Poland |
|
Linen napkins |
Fabric woven and dyed in Lithuania |
Hemmed in the Netherlands |
Lithuania |
Additional Documentation
We also recommend keeping supporting documents on file, such as:
- Supplier invoices showing material origins
- Manufacturing records
- Certificates of Origin (especially if needed for trade compliance)
Useful resources:
https://www.trade.gov/rules-origin-substantial-transformation
https://taxation-customs.ec.europa.eu/customs/international-affairs/origin-goods_en