United States Court of Appeals for the Federal Circuit
260 F.3d 1320 (2001)
Bestfoods (plaintiff) prepared peanut butter in Arkansas from peanut slurry. A majority of the slurry originated from the United States, and the remainder was from Canada. The United States Customs and Border Protection (Customs) (defendant) ruled that Bestfoods’s peanut butter needed to be marked as partially of Canadian origin. Customs ruled that even if the value of the Canadian peanut slurry used in the final product would otherwise be small enough to fall within the de minimis exception, which would allow for not marking a country of origin, the de minimis exception did not apply to agricultural products. Bestfoods successfully sued in the Court of International Trade, which held that the exception to the de minimis rule for agricultural goods was arbitrary and capricious. Customs appealed to the United States Court of Appeals for the Federal Circuit.
Rule of Law
Holding and Reasoning (Archer, J.)
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