Bestfoods v. United States
United States Court of Appeals for the Federal Circuit
260 F.3d 1320 (2001)
Bestfoods (plaintiff) made peanut butter in Arkansas mostly from American peanut slurry, with a small remaining share from Canada. Customs (defendant) ruled the peanut butter had to be marked as partially of Canadian origin, rejecting Bestfoods's argument that the Canadian content was small enough to fall under Customs's own "de minimis" exception (which normally excuses marking components under 7% of a finished good's value) — because Customs had chosen not to extend that exception to agricultural products. The Court of International Trade sided with Bestfoods, holding the agricultural carve-out was arbitrary and capricious, and Customs appealed.
Whether agricultural goods made with a de minimis amount of imported ingredients must still bear a country-of-origin marking disclosing those foreign ingredients.