AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Under 19 CFR Part 134, every article from Nigeria entering the US, or its container, must be marked conspicuously, legibly, indelibly and as permanently as the article allows with the English name of the country, normally "Made in Nigeria" or "Product of Nigeria". Unmarked goods attract an extra 10% of their appraised value unless exported or destroyed under CBP supervision, and CBP will not release them until they are marked.
The rule in one paragraph
US Customs and Border Protection (CBP) enforces the marking law through 19 CFR Part 134. Section 134.11 says every article of foreign origin, or its container where the article itself is excepted, must be marked "in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit", and the mark must tell the ultimate purchaser in the US the English name of the country of origin. For goods made in Nigeria, that means the word Nigeria, in English, on the product or on the packaging the shopper actually sees.
The ultimate purchaser is usually the last person in the US who receives the article in the form it was imported: the shopper who buys a bag of garri off a shelf, or the customer who orders a carved stool. A wholesaler or a store is not the ultimate purchaser if the goods reach the public unchanged.
What the mark must look like
Part 134 sets out several tests. The mark must be:
- Conspicuous: "capable of being easily seen with normal handling of the article or container" (134.1(k)).
- Legible: the purchaser must be able to read it without strain (134.41).
- Permanent enough: it must survive normal distribution and store handling. Stickers are allowed if they stay on through storage and display; hang tags must stay attached until delivery (134.44).
- In English, with the full country name: "Nigeria" in full unless CBP authorises otherwise. Recognised abbreviations and variant spellings are acceptable in principle (134.45), but "Nigeria" is short enough that there is no reason to abbreviate it.
Wording such as "Made in Nigeria", "Product of Nigeria" or simply "Nigeria" is common. An adjective on its own ("Nigerian") is acceptable under 134.45 unless it reads as a type of product rather than an origin: "Nigerian pepper soup spice" on its own may be read as a style of spice, so a separate "Product of Nigeria" line removes the doubt.
When a US name appears on the pack
This is the rule small importers most often miss. If the label carries a US place name or "American", for example your Houston company address or a brand like "Lagos-Atlanta Kitchen", section 134.46 requires the origin to appear near that name, in at least comparable size, using words such as "Made in" or "Product of". Section 134.22(c) applies the same idea to containers that show a US importer or distributor address: the origin of the contents must appear near it, as in "Contents made in Nigeria". A small "Nigeria" on the back while "Distributed by ... Houston, TX" sits on the front is the kind of label that gets goods held.
Containers, repacking and exceptions
Some articles are excepted from individual marking, for example goods incapable of being marked, goods that would be damaged by marking, and goods whose container reasonably shows the origin (134.32). The J-list in 134.33 excepts items such as buttons and nails. In every one of these cases the outermost container that normally reaches the ultimate purchaser must still be marked.
If you import in bulk and repack in the US, the marking duty moves with the goods. Under 134.25 and 134.26 an importer who expects goods to be repacked must certify to CBP that the new containers will be marked, or that the buyer will be told in writing of the duty to mark. Failing to do so can lead to liquidated damages. A typical case: 25 kg sacks of elubo repacked into 2 lb retail bags in New Jersey. Each retail bag needs "Product of Nigeria".
Food has a second layer. The FDA Food Labeling Guide says country of origin statements on food should be conspicuous and placed near the US name and address where one appears, and refers back to 19 CFR 134. For food, design the label once to satisfy both FDA labelling and CBP marking.
What happens if goods arrive unmarked
| Stage | What Part 134 says |
|---|---|
| Before release | Goods are not delivered until marked, or until estimated duties or security are deposited (134.3). |
| Notice to mark | CBP issues Customs Form 4647 telling the importer to mark, export or destroy the goods, under CBP supervision and at the importer's expense (134.51). |
| Extra duty | Unmarked articles owe an additional 10% of final appraised value unless exported or destroyed under supervision before liquidation (134.2). |
| Ignoring the notice | If goods are not marked or redelivered within 30 days of the notice, liquidated damages equal to the entered value may be demanded (134.54). |
| Removing a mark | Intentionally removing or altering a mark to conceal origin can bring criminal penalties of up to $5,000 and/or one year in prison (134.4). |
Worked example
Example only. A shipment of 400 carved wooden bowls is entered at $6,000. The bowls carry no mark and the cartons say only "Handmade". CBP issues a notice to mark. If you mark the bowls under supervision before liquidation, the 10% marking duty is avoided, but you pay for labour, storage and supervision. If the goods are released and you neither mark nor return them within 30 days, the exposure under 134.54 is liquidated damages up to the $6,000 entered value. If you do nothing and the goods are liquidated unmarked, the extra marking duty is 10% of $6,000, which is $600, on top of normal duty.
What to check first
- Ask your Nigerian supplier to print or stamp "Made in Nigeria" or "Product of Nigeria" at the factory: marking at manufacture is cheaper than relabelling at a US port.
- Check every place a US name appears on the label and put the origin statement beside it, in comparable type.
- For carvings, textiles and crafts, use a permanent method (burned, stitched or sewn label) rather than a loose tag where the item allows it.
- If you will repack, plan the retail label before the goods ship and keep your repacking certification on file.
- Send your broker a photo of the marked product with the commercial invoice so the entry matches what CBP sees.
Marking is separate from duty: being marked "Made in Nigeria" is also what makes goods products of Nigeria for tariff purposes. See the current US tariff on goods from Nigeria and, for clothing, textile labelling rules.
Where Pryme fits
Relabelling costs show up as unplanned dollar bills at the port, while the goods were paid for in naira. A Pryme Business Account opened from the US holds USD and NGN with local details for each (business multicurrency), and the app shows the rate and the fee before you approve a Swap to pay your supplier. Asking that supplier for a verifiable invoice through VerifyDoc.ai gives your broker a document that can be checked as unaltered.
Questions people ask
Does "Made in Nigeria" have to be on the product or the box?
On the article itself where it can be marked, and on the outermost container the buyer sees where the article is excepted. The mark must be conspicuous, legible and reasonably permanent (19 CFR 134.11, 134.41).
Can I write "Nigerian" instead of "Made in Nigeria"?
An adjective is acceptable under 134.45 unless it describes a type of product. For food names that include "Nigerian", add a separate "Product of Nigeria" line.
My label has my US company address. What else do I need?
Put the origin near that address in comparable size, for example "Product of Nigeria" or "Contents made in Nigeria" (134.22(c), 134.46).
What is the penalty for unmarked goods from Nigeria?
An additional 10% of appraised value unless the goods are exported or destroyed under supervision before liquidation, plus possible liquidated damages up to entered value if you ignore a notice to mark (134.2, 134.54).
Sources
- eCFR: 19 CFR Part 134, Country of origin marking (current text) · accessed Oct 2026
- FDA: Food Labeling Guide (guidance revised Jan 2013) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.