For HTS classification and CBP country-of-origin purposes, the origin of a blended tea is generally the country where the substantial transformation occurred — typically where the blending and packaging took place if it meaningfully changes the character of the product. However, FDA food labeling rules may require disclosure of the actual leaf origins on the label. Importers should consult a licensed customs broker and review FDA labeling guidance, as the CBP origin determination and FDA label requirements can differ.

Pu-erh is a post-fermented tea that undergoes microbial fermentation after drying, which is distinct from the oxidation process used for black tea. CBP has generally classified pu-erh under the fermented tea headings in 0902, but the specific line depends on packaging size and whether it is considered 'partly fermented' or fully fermented. Given the classification ambiguity, importers of pu-erh should seek a binding ruling from CBP before large-scale importation.