Answer first
Core rule
The ultimate purchaser is generally the last U.S. person to receive the article in the form in which it was imported. A retail purchaser is the ultimate purchaser when the article is sold unchanged; a U.S. manufacturer may be the ultimate purchaser after a qualifying substantial transformation; minor processing that leaves the imported article's identity intact generally leaves the later consumer or user as ultimate purchaser. Part 102 supplies the corresponding branch for Canada, Mexico, and United States marking goods. This is the current-law baseline reviewed on 2026-08-18; for a CBLE question, confirm the CFR and other references designated for that exam sitting before choosing the exam answer.
Authority and lookup route
Locate the rule before returning to the facts. Links point to government or official publications.
Reference lookup task
Find the three §134.1(d) examples for manufacture, minor processing, and retail sale in imported form, then state who is the ultimate purchaser in each.
Route: Read §134.1(d)(1) through (3) in sequence and make the imported form, processing result, and recipient explicit.
Worked example
Imported kitchen timers are placed into new retail cartons in the United States without changing the timers themselves and are sold to consumers. Who is the ultimate purchaser of each timer?
- 1Follow the timer, not merely the carton, through the U.S. transaction.
- 2Recognize that repacking does not change the timer's imported identity.
- 3Apply §134.1(d)(2)-(3) rather than the manufacturing example.
- 4Identify the retail consumer as the last U.S. recipient of the timer in imported form.
Conclusion: The retail consumer is the ultimate purchaser of the timer.
Common traps
- Automatically naming the importer as ultimate purchaser.
- Treating repacking or a minor process as a substantial transformation.
- Tracking the retail container while losing sight of the imported article whose origin must be communicated.