GS1 Barcode Compliance: Country Origin Code Confusion Continues to Abound

I was passed the URL for this blog with a post entitled, “How To Identify Imported Goods Before Purchasing!!!!” It seems fairly certain of itself:

The first three digits of the barcode that start with either 690, 691, or 692 indicate that the product is made in China. The first three digits of the barcode that start with 471 indicates the product is made in Taiwan.

It then goes on to list five additional pairings of two digits that presumably identify the Country of Origin (COO) for any given product in five or so major countries. But . . . we already know that that blog is wrong and we’ve blogged on the topic (about how easy it is to be misled on the topic) multiple times.

The latest iteration got a little hot around here when we posted on the news story where a fellow in Malaysia discovered a Chinese company had registered a GS1 compliant code in the Phillipines to ship tainted product using that non-Chinese country code. We reported on this a couple of different ways, including the news story that quoted a Singapore GS1 official. This upset some people who commented on that post (while we took no position on the issue, we did take the position of only publishing the milder posts; i.e., the ones without swearing).

So earlier this month, I wrote an email that included the following to a high-level contact at GS1 US to see if the emerging GS1 standard had ever hoped to solve this COO question:

I was wondering if you’ve encountered in any of your journeys the subjective impression that, since the GTIN contains a manufacturer ID and that is purchased from a GS1 franchise, you have an implied country-of-origin designation. This has come up as a topic from a blog post we did awhile back on a fellow in Malaysia with a tainted milk product he knows was made in China but the manufacturer used a Philippine-registered manufacturer ID. This may have been done by the manufacturer to avoid the current storm around generally tainted Chinese dairy.

The answer I got implies to me at least that the average consumer can’t be certain of the COO based on GS1 product barcodes (and others, which I’ll detail in a moment):

There is a table on the GS1 website that states the country of origin designation on the first 2 digits of the company prefix, , e.g. the US is 00 to 13. The rule is that the company should register in the country where their corporate headquarters is. However because of mergers, buyouts etc one cannot really rely on the company prefix to tell the country of origin of the product…  One of the ways to distinguish is to use an application identifier for the country of origin of manufacturer.  AI 422 is a 3 digit all numeric code  in the GS1 system   keyed off the ISO country of origin code table.  

In other words, it is possible  to get the correct COO number for the product from its GS1 compliant barcode — that is, a completely valid, registered GS1 barcode — but not guaranteed or mandated. Moreover, a GS1 barcode may not necessarily identify the location of the corporate headquarters for the company making the product.

But what about EAN numbers. Well, back to the blog mentioned above, in the comments section there’s a link to a site called snopes.com which a reader says helps validate country of origin questions.  Guess what? To the assertion that the first three digits of a barcode always reveals the country of origin, they say, ‘False.’ They are right about that. Secondly, they also clarify that the same is true for EAN, which we also knew.

Folks, this is a big problem that will need to get fixed. I’m just not sure that GS1 compliant barcodes or GS1 compliance at all is the enforcement technique here. The fact is, we don’t always have honest players in the supply chain (witness deliberately tainted everything — beans, toothpaste, candy, dried apples, scallops, and that’s in addition to milk and eggs –  coming out of dozens of various Chinese manufacturers).

If you disagree, feel free to comment. If you agree, and have a solution, please comment. Thank you.